This is a reference translation. The Japanese version is the original and prevails in the event of any discrepancy.
Nefront, Inc. (the “Company”) sets out the following Privacy Policy (this “Privacy Policy”) regarding the handling of customers’ personal information in the AI drawing management system Filefront and the Company’s other services (collectively, the “Service”). Terms used in this Privacy Policy have the meanings given under the Act on the Protection of Personal Information of Japan (the “Personal Information Protection Act”).
Article 1 Acquisition of personal information
The Company acquires the customer’s personal information, to the extent necessary for the Company to provide the Service, either by means of information provided by the customer or by means of information the Company collects as the customer uses the Service. The Company acquires personal information by proper means, and does not acquire personal information by deception or other wrongful means.
Article 2 Purposes of use of personal information
1. The Company uses the customer’s personal information it has acquired to the extent necessary to achieve the following purposes of use.
(i) To provide the Service to the customer or to other customers — including accepting registration for the Service, verifying identity and calculating usage fees, and including providing services that meet the customer’s needs by analyzing information such as usage of the Service and customer attributes acquired by the Company — and to maintain, protect and improve the Service
(ii) To give notice of information about the content of the Service, update information, information on events and campaigns, and information on changes to the terms and other rules
(iii) To respond to inquiries and provide guidance regarding the Service
(iv) To respond to illegal acts, unauthorised access, and acts that violate the Company’s terms or other rules in relation to the Service
(v) To create analyses or statistical data regarding use of the Service
(vi) To plan, design or implement the Service going forward
(vii) For other marketing purposes
2. Except where permitted by the Personal Information Protection Act, the Company will obtain the customer’s prior consent before using personal information beyond the purposes of use set out in the preceding paragraph.
Article 3 Provision to third parties and entrustment of acquired personal information
1. Except in the cases below, the Company will not provide personal information acquired from the customer to a third party without obtaining the customer’s prior consent.
(i) Where based on laws and regulations
(ii) Where necessary to protect a person’s life, body or property, and it is difficult to obtain the customer’s consent
(iii) Where particularly necessary to improve public health or promote the sound upbringing of children, and it is difficult to obtain the customer’s consent
(iv) Where it is necessary to cooperate with a national government body, a local government, or a party entrusted by either, in performing duties prescribed by law, and obtaining the customer’s consent risks impeding the performance of those duties
(v) Where the recipient is an academic research institution or similar and needs to handle the personal information provided for academic research purposes
(vi) Where the Company’s business, including the provision of personal information, is succeeded to by reason of a merger, company split, business transfer or other cause
(vii) Where personal information is provided in connection with the Company entrusting the handling of that personal information to the extent necessary to achieve the purposes of use
(viii) Where personal information is provided for joint use in accordance with the Personal Information Protection Act
(ix) In other cases permitted by the Personal Information Protection Act
2. Except in the cases below, the Company will not provide personal information it handles to a third party in a foreign country without obtaining the customer’s prior consent.
(i) Where any of (i) to (v) of paragraph 1 above applies
(ii) Where the information is provided to a third party in a country designated by the Personal Information Protection Commission as having a personal information protection regime recognised as being of a standard equivalent to that of Japan in terms of protecting the rights and interests of individuals
(iii) Where measures consistent with the intent of the Personal Information Protection Act are ensured, by appropriate and reasonable means, in respect of the recipient’s handling of that personal information
(iv) Where the recipient of the personal information has obtained certification under an international framework concerning the handling of personal information
(v) In other cases permitted by the Personal Information Protection Act
3. The Company may entrust all or part of the handling of personal information to a subcontractor, to the extent necessary to achieve the purposes of use. In doing so, the Company thoroughly examines the subcontractor’s suitability, stipulates matters such as confidentiality obligations in the contract, and establishes a structure in which personal information is properly managed.
Article 4 Security control measures
The Company takes necessary and appropriate measures to prevent the leakage, loss or damage of the personal information it handles, and otherwise for the security control of personal information.
Article 5 Disclosure, correction and suspension of use of personal information
1. Where a customer requests disclosure or similar (meaning notification of the purposes of use, disclosure, correction, addition or deletion, erasure, suspension of use or of provision to third parties, and disclosure of records of provision to third parties; the same applies below) under the Personal Information Protection Act, the Company will, in accordance with that Act and the items below, and after confirming that the request comes from the customer themselves, carry out the disclosure or similar without delay.
(1) Notification of the purposes of use, or disclosure of personal information or of records of provision to third parties
The customer may request the Company, in accordance with procedures the Company prescribes separately, to notify the purposes of use or to disclose personal information or records of provision to third parties. However, the Company may be unable to comply with a request in the following cases.
(i) Where disclosure risks harming the life, body, property or other rights and interests of the customer or of a third party
(ii) Where disclosure risks seriously impeding the proper conduct of the Company’s business
(iii) Where disclosure would violate laws and regulations
(iv) Where it cannot be confirmed that the request for disclosure comes from the customer themselves
(v) Where the request otherwise fails to meet the requirements of the Personal Information Protection Act
Where notification of the purposes of use, or disclosure of personal information or of records of provision to third parties, is requested, a disclosure fee prescribed separately by the Company applies.
(2) Correction, addition and deletion
The customer may request correction, addition or deletion of personal information in accordance with procedures the Company prescribes separately. In that case the Company will investigate without delay, to the extent necessary to achieve the purposes of use, and will correct, add to or delete that personal information based on the result.
(3) Suspension of use, erasure, or suspension of provision to third parties
The customer may request suspension of use, erasure, or suspension of provision to third parties of personal information in accordance with procedures the Company prescribes separately. In that case the Company will respond appropriately in accordance with the Personal Information Protection Act.
2. When making a request under the preceding paragraphs, please contact the inquiries desk in Article 7, attaching the following information and any other information or materials the Company prescribes.
(i) Name, address, telephone number and email address
(ii) Details of the request
(iii) Identity verification documents
Article 6 Links
Businesses other than the Company that are linked to from the Company’s website may acquire personal information on their own websites. This Privacy Policy does not apply in such cases, and the Company bears no obligation or responsibility whatsoever in relation to the handling of personal information by businesses other than the Company.
Article 7 Inquiries desk
For opinions or questions regarding this Privacy Policy, other inquiries about the handling of personal information, and requests under the items of Article 5, paragraph 1, please contact the email address below.
Email address: info@nefront.com
Article 8 Revisions
When this Privacy Policy is revised, the Company will promptly give notice of the revision date and the content of the revision on its website.