Link Interac Inc. (hereinafter “The Company”), to achieve a more meaningful society through providing “whole person” educational services that enrich the hearts, minds, and lives of people of all ages; and to contribute to more harmonious and closely knit relations among all people by promoting a deeper understanding of the world’s languages, cultures, and learning; conducts worker dispatch, recruitment, and foreign language education related businesses.
In our provision of these services, the safe management of information assets including personal information is an important matter to The Company; to ensure that it is practiced, all executives and employees of The Company will unite to strive to handle personal information appropriately, according to the Personal Information Protection Policy.
1. The Company, in the handling of personal information handled in all businesses (including retained personal data) and personal information of individuals such as employees, shall comply with laws and ordinances related to the handling of personal information, nationally established guidelines, and other rules. In addition, we have established a personal information protection management system that complies with the Japanese Industrial Standard JIS Q 15001:2017 (Personal Information Protection Management Systems – Requirements) to protect personal information.
2. In the acquisition and use of personal information, The Company will identify the purpose of use, handle the information appropriately within the scope necessary to accomplishment of that purpose, and will not handle the information in a manner which exceeds the scope necessary to accomplish the purpose of use that has been identified (use outside the identified purpose). In addition, The Company will take appropriate control measures to prevent use outside the identified purpose.
3. The Company will acquire personal information using legal and fair methods.
4. The Company will not provide personal information it has acquired to a third party, except when it has acquired the consent of the individual in question, or in cases including those in which such provision is according to laws and ordinances.
5. The Company will enable the person who provided the personal information to be appropriately involved in each situation where personal information is acquired, used, and provided. In addition, if The Company receives complaint or consultation regarding the handling of personal information, it shall expeditiously investigate the facts of the case and appropriately respond within a reasonable period of time and in good faith.
6. In the management of personal information, The Company will take organizational, human, physical, and technological safety control measures in striving to prevent and correct leakage, loss, or damage to personal information.
7. The Company will establish a personal information protection management system, continuously reviewing and improving it to ensure its operation.
Established: 1 October 2016
Last revision: 1 December 2022
Link Interac Inc.
President Miki Yamaguchi
1. Personal Information
2. Purpose of Use of Personal Information
Personal information handled in worker dispatch and recruitment work (※)
- To propose and provide information to registrants who wish to receive such services in worker dispatch business
- To provide personal information to clients to whom we have obtained the registrant’s permission for disclosure in worker dispatch business
- To propose and provide job information to job applicants who wish to receive our services in the recruiting business
- To provide job information to job applicants who wish to be considered for employment in the recruitment process
- To manage the recruitment and screening of job applicants in the recruiting business
- To provide personal information to business associates to whom we have obtained the job applicants’’ permission in the recruiting business
2
Personal information of customers who use our services
- To provide information regarding services, and provide the services of Link and Motivation Group (hereinafter “The Group”)
- For the handling of inquiries, and for The Group to contact relevant parties
3
The conduct of consigned work
4
Personal information related to participants in events, conferences, and seminars (※)
To inform, operate, manage, and conduct surveys regarding events, conferences, seminars, etc. put on by The Group
To provide to the sponsors and joint organizers of events, conferences, seminars, etc. put on by The Group
To inform regarding services provided by The Group
5
Personal information regarding executives and employees of transaction partners (※)
Sales activities and transaction partner management by The Group
6
Personal information of individuals to which The Company consigns work (※)
Work requests
Contract management
7
Personal information of job applicants (※)
Hiring management and selection procedures by The Group
To inform, operate, manage, and conduct surveys regarding events, conferences, seminars, etc. put on by The Group
To provide to the sponsors and joint organizers of events, conferences, seminars, etc. put on by The Group
For The Group to conduct various surveys regarding job search activities
For The Group to perform informal appointment procedures, official hiring, and/or human resource management regarding individuals who have been hired as a result of the hiring selection process
For The Group to draft hiring strategies
For the handling of inquiries, and for The Group to perform various contacts
8
Personal information regarding employees (including informally appointed persons) and resigned employees (※)
For employment and human resource management in The Group
※ Retained personal data is indicated by “（※）” in the table above.
3. Measures Taken for Security Management
In compliance with relevant laws, regulations, and guidelines, the Company will take necessary and appropriate measures (hereinafter referred to as “security control measures”) as follows to safely handle information and prevent leakage, loss, or damage of personal data.
[1] Basic Policy, etc.
The Company has established the “Personal Information Protection Policy” as our basic policy to ensure the proper handling of personal data.
[2] Rules for the handling of personal data
The Company has established internal rules governing how personal data is handled, who is responsible or in charge, and their roles.
[3] Organizational security control measures
The Company has appointed a “Personal Information Protection Manager” as the person in charge of handling personal information in our organizational structure, established a personal information protection management system, and implemented internal controls for the protection of personal information. The Company has also established a system to ensure that our employees (including temporary employees) comply with internal regulations regarding safety management measures, and that if an employee becomes aware of a fact or indication that the law or internal regulations have been violated, he or she reports it to the Personal Information Protection Manager and other responsible personnel. When personal information that we manage is given to an outsourcing partner that handles personal information, the Company strictly supervises the outsourcee and monitors the outsourcee to ensure that the security control measures for personal information are strictly maintained.
[4] Personnel security control measures
The Company regularly educates and trains our employees on the proper handling of personal information.
[5] Physical and technical security control measures
In areas where personal data is handled, the Company controls the access of employees and third parties, and implements measures to prevent theft, such as locking and storing documents, media, and equipment that contain personal data. The Company also implements access control to personal data and information systems that handle personal data, computer virus countermeasures, unauthorized software countermeasures, and information system monitoring.
Examples: prohibiting the storage of personal data in locations other than the designated storage locations, applying high-level policies regarding authentication passwords, and obtaining and analyzing the operation history of personal data.
[6] Understanding the external environment
The Company stores some of the personal data we handle in servers located in the United States, which are managed by Box Inc. As such, the Company has also implemented security control measures based on our understanding of the personal information protection system in the United States. For an overview of the personal information protection system in the United States, please refer to the conclusions of the “Survey of Personal Information Protection Systems in Foreign Countries” published by the Personal Information Protection Commission.
4. Joint Use of Personal Information
The Company, in order to carry out general services through The Group, may jointly use personal information (excluding Personal Identification Number) as described below.
1. Items of personal information used jointly
[Personal information of transaction partners and other external individuals]
– Name (including employer, department, title, etc.), address, telephone number, fax number, email address, etc.
– Items regarding inquiries
– Items regarding provision of services (account information necessary to use services, as well as view, search, location information, and other information which constitutes activity history, etc.)
[Employee and other internal information]
– Name and other employment and evaluation management information
2. Scope of who jointly uses information
All companies of The Group (The latest list of Group companies is here. Further, this is included in The Group.)
3. Purpose of use of those who jointly use information
Joint use is limited to cases necessary within the scope of “2. Purpose of Use of Personal Information.”
4. Person responsible for management of jointly used personal information
Link Interac Co., Ltd. Personal Information Protection Manager
5. Methods of acquiring information
As a principle, the personal information acquired in the course of use of services of The Company is shared via a web system made confidential by means including encryption.
5. Disclosure and Correction, etc. Procedures
The Company will receive requests from the individual in question to disclose retained personal data, notify of purpose of use, make corrections, etc. if the retained personal data is factually incorrect, and discontinue using, etc., or discontinue providing to a third party (hereinafter “Disclosure, etc.”).
[1] Where to request Disclosure, etc.
(1) Complaint / Consultation Contact
(2) Send by post the designated form with required attached documents to the following address:
Kabukiza Tower 15F, 4-12-15 Ginza, Chuo-ku, Tokyo 104-0061
Link Interac Inc. Customer Consultation Desk
[2] What to submit
(1) Personal information Disclosure, etc. Request
(2) Documents for identification of the individual in question (driver’s license, passport, etc.)
(3) If contact is made by a legal representative, include documentation confirming that the legal representative has the right of legal representation in addition to item (2) above
If contact is made by a voluntary representative, include a letter of proxy designated by The Company and the seal registration certificate of the individual in question in addition to item (2) above
*Please submit the documents with permanent domicile and any other sensitive personal information redacted prior to submission. If such information is not redacted upon receipt at The Company, The Company will redact to avoid acquiring the personal information.
[3] Fees
The Company will, according to the Act on the Protection of Personal Information, collect a fee of 500 yen for each Disclosure, etc. request made. Please enclose a fixed-amount money order for 500 yen with each request submitted. Please also bear the cost of fees incurred when making the purchase thereof. (Further, please understand that The Company may change the amount of fees without notice.)
*If the fees enclosed are insufficient, or if no fees are enclosed, The Company will notify the request sender; however, if payment is not made within the designated period, The Company will assume that the Disclosure, etc. request has not been made.
The specific procedure for a Disclosure, etc. request is listed in “5. Consultations / Complaints regarding Handling of Personal Information”. Please inquire to The Company’s Customer Consultation Contact.IN
6. Consultations / Complaints Regarding Handling of Personal Information
For inquiries including consultations or complaints regarding The Company’s handling of personal information
Please contact the Personal Information Consultation Desk listed below.
Link Interac Inc.
Kabukiza Tower 15F, 4-12-15 Ginza, Chuo-ku, Tokyo 104-0061
President Miki Yamaguchi
Personal Information Protection Manager Legal Affairs Crisis Management Group Manager
For inquiries, complaints, or consultations regarding the Personal Information Protection Policy
Please contact the Customer Consultation Contact listed below for inquiries, complaints, or consultations regarding the Personal Information Protection Policy.
Link Interac Inc. Customer Consultation Desk
Kabukiza Tower 15F, 4-12-15 Ginza, Chuo-ku, Tokyo 104-0061
Email: [email protected]
*The term “retained personal data” means “such personal data over which The Company handling personal information has the authority to disclose, to correct, add or delete the content, to discontinue its utilization, to erase, and to discontinue its provision to a third party (excluding the data which is specified by a Cabinet Order as harming public or other interests if its presence or absence is known and the data which will be erased within a period of no longer than six months).”
External Transmission of User Information
Classification
Purposes of Our Company’s Use
Destination
Service Name
Purposes of External Transmission Recipients’ Use
Examples of Transmitted Information
Destination’s Privacy Policy
Opt-out
URLs of visited sites and screen names of accessed applications.
Titles of visited sites or applications.
URLs of previously visited sites before accessing our site
Date and time of access
Attribute information of site visitors
Web browser type, version, and device information
Browsing environment information such as device screen size
Device’s language settings
URLs of visited sites and screen names of accessed applications
Titles of visited sites or applications
Date and time of access Web browser type, device type, and version
Information on user actions, such as clicks or taps
Browsing environment information, such as device screen size
Device’s language settings
URLs of visited sites and screen names of accessed applications.
Titles of visited sites or applications.
Date and time of access
Web browser type, device type, and version
Information on user actions, such as clicks or taps
Browsing environment information, such as device screen size
Font Optimization
URLs of visited sites and screen names of accessed applications.
Date and time of access
Web browser type, device type, and version
For inquiries, complaints, or consultations regarding the external transmission of information on this site, etc., please contact the Customer Service Desk below.
Contact Us
株式会社Link Interac Inc.
Customer Service Contact
Kabukiza Tower 15F, 4-12-15 Ginza, Chuo-ku, Tokyo 104-0061, Japan
E-mail：[email protected]
GDPR Privacy Policy
Link Interac Inc. is referred to hereafter as “Company”, “we”, or “us”. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Important Information and Who We Are
Purpose of this Privacy Policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when applying for a position with one of our companies or our clients.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
The Company
Link Interac Inc. is a legal entity, as set forth above. This privacy policy is issued on behalf of Link Interac Inc. Link Interac Inc. is the controller and is responsible for this website.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
DPO Contact Details
Full name of legal entity: Link Interac Inc.
Email address: [email protected]
Postal address: Kabukiza Tower 15F, 4-12-15 Ginza, Chuo-ku, Tokyo 104-0061
Telephone number: 03-6853-8265
Changes to the Privacy Policy and Your Duty to Inform Us of Changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
- Contact Data includes home address, business address, email address, and telephone numbers.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, your interests, preferences, and feedback.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Video Clips includes video of you demonstrating your teaching abilities, making a self-introduction etc. This video may be viewed by us for assessment, marketing and training purposes. The video may be provided to our customers for their evaluation of your suitability as an employee. You have no intellectual property rights in and to the video nor shall you be entitled to any compensation by virtue of our or our clients using and viewing the video.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you without your express consent (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences without your express consent.
If You Fail to Provide Personal Data
3. How is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
-
Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- submit an application for employment;
- create an account on our website;
- subscribe to our services or publications;
- or give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. If collected, we collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies, like Facebook and Google. A cookies (or browser cookie) is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Other Sources. We may receive personal data about you from references that you provide us.
4. How We Use Your Personal Data
We will use your personal data only when the law allows. Most commonly, we will use your personal data in the following circumstances:
- Where we are evaluating your qualifications for possible employment with one of our related entities or customers.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
The types of lawful basis that we will rely on to process your personal data include the following:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
We will get your consent before sending third party direct marketing communications to you via email or text message. We will also get your express consent before processing any particularly sensitive personal data such as data related to health or to prior criminal convictions. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
(a) Identity
(b) Contact
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(b) Necessary for our legitimate interests (to evaluate your suitability for employment with our affiliates or customers)
(a) Facilitating offers of employment to you from our affiliates or customers
(b) Notifying you about changes to our terms or privacy policy
(c) Asking you to leave a review or take a survey
(b) Contact
(c) Profile
(d) Marketing and Communications
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated)
(b) Contact
(c) Technical
(b) Necessary to comply with a legal obligation
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(b) Usage
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Promotional Offers From Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This may be how we decide which services and offers, including potential offers of employment, may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or entered information about yourself as part of the application process with or through us and you have not opted out of receiving that marketing.
Third-Party Marketing
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your applying for employment with us or one of our customers.
Cookies
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Entities partnered with Link Interac Inc. based in Japan for any or all of the purposes set forth on the table above.
External Third Parties - Our clients for which you are considered a potential hire.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
Whenever we transfer your personal data to another country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission or other relevant authorities that give personal data appropriate protection.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide appropriate protections to personal data.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data Security
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention: How long will you use my data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
You can request details of retention periods for different aspects of your personal data by contacting us.
In some circumstances you can ask us to delete your data, as set forth in Your Legal Rights, below.
We will also anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes and may use this anonymized information indefinitely without further notice to you.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
-
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights, please contact us at the address set forth above.