Privacy Policy

Prometech Group, Inc. and its domestic group companies (hereinafter collectively referred to as “Prometech Group”) understands the importance of protecting  personal information, and will observe the Act on the Protection of Personal Information (the “Act”) and endeavor to handle and protect personal information in an appropriate manner in accordance with this Privacy Policy (the “Privacy Policy”).  Unless otherwise expressly provided for herein, the defined terms in the Privacy Policy shall have the same meaning as defined in the Act.

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1.　DEFINITION

In the Privacy Policy, personal information shall mean “personal information” defined in paragraph 1 of Article 2 of the Act.

2.　PURPOSE OF USE

Prometech Group shall use personal information for the following purposes:

(1) Provision of Prometech Group’s products or services;
(2) Notifications and responses to customer inquiries, with respect to Prometech Group’s products or services;
(3) Announcement regarding Prometech Group’s products or services, etc.;
(4) Dealing with breach of Prometech Group’s terms of use, policy, etc. (the “Terms”), with respect to Prometech Group’s products or services;
(5) Notifications of amendment to the Terms of Prometech Group’s products or services;
(6) Improvement of Prometech Group’s products or services and development of new products or services, etc.;
(7) Employment management and internal procedures of Prometech Group (this shall apply to personal information of Prometech Group’s directors, auditors and employees) and selection and communication in recruitment activities (this shall apply to personal information of the applicants);
(8) Shareholders management and procedures required by applicable laws such as Companies Act (this shall apply to personal information of shareholders, holders of share options etc.);
(9) Creation of statistics data which is processed so that no particular individuals shall be identified, in connection with Prometech Group’s services or products; or
(10) other purposes related to the above purposes.

3.　CHANGE OF PURPOSE OF USE

Prometech Group may change the purpose of use of personal information to the extent that the purpose of use after the change is reasonably deemed related to the original purpose of use.  When the purpose of use has been changed, Prometech Group shall notify the person identified by personal information (the “Principal”) of, or publicly announce the purpose of use after the change.

4.　RESTRICTION ON USE

Prometech Group shall not use personal information, without the consent of the relevant Principal, beyond the scope necessary for the achievement of the purpose of use, unless permitted by the Act or other laws or regulations; provided, however, that this provision shall not apply if:

(1) the use of personal information is based on laws and regulations;
(2) the use of personal information is necessary for the protection of the life, body or property of an individual and it is difficult to obtain the consent of the relevant Principal;
(3) the use of personal information is specially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the relevant Principal; or
(4) the use of personal information is necessary for cooperating with a national government, a local government, or a person or entity entrusted thereby in executing the affairs prescribed by laws and regulations and acquisition of the consent of the relevant Principal may impede the execution of the affairs concerned.

5.　PROPER ACQUISITION

5.1 Prometech Group shall acquire personal information by a proper means, and shall not acquire it by a deception or other wrongful means.

5.2 Prometech Group shall not acquire special care-required personal information (as defined in Paragraph 1 of Article 2 of the Act) without obtaining in advance a Principal’s consent except:

(1) in case of any of the items of Article 4;
(2) in cases where the special care-required personal information is being made available to the public by a Principal, a government organization, a local government, a person set forth in each Item of Paragraph 1 of Article 76 or other persons prescribed by rules of the Personal Information Protection Commission;
(3) in cases where Prometech Group acquires externally obvious special care-required personal information by visual observation or by photographing; or
(4) in cases where Prometech Group acquires special care-required personal information in the manner which does not fall under provision to a third party pursuant to the proviso to Article 7.1.

6.　SECURITY CONTROL

Prometech Group shall sufficiently and appropriately supervise Prometech Group’s employee to ensure the security control of personal information against the risk of loss, destruction, alteration or leakage.  When Prometech Group entrusts a third party with the handling of personal information in whole or in part, Prometech Group shall sufficiently and appropriately supervise the third party to ensure the security control of personal information.

7.　PROVISION TO A THIRD PARTY

7.1. Prometech Group shall not provide personal information to a third party without the prior consent of the relevant Principal, unless the disclosure falls under any of Items of Article 4; provided, however, that the following cases shall not be regarded as the provision to a third party:

(1) Cases where Prometech Group provides a third party with personal information for the purpose of entrusting handling of personal information within the scope necessary for the achievement of the purpose of use;
(2) Cases where personal information is provided as a result of the succession of business in a merger or otherwise; or
(3) Cases where personal information is used jointly with others in accordance with the provisions of the Act.

7.2 Notwithstanding Article 7.1, except in cases set forth in each Item of Article 4,in cases where Prometech Group provides personal information to a third party (excluding a person having a system conforming to standards prescribed by the rules of the Personal Information Protection Commission pursuant to Article 24 of the Act) in a foreign country (excluding those prescribed by the rules of the Personal Information Protection Commission pursuant to Article 24 of the Act),Prometech Group shall obtain a Principal’s prior consent on the provision to a third party in a foreign country.

7.3 When Prometech Group provides personal information to a third party in accordance with the provisions of Article 25 of the Act, Prometech Group shall make and keep a record of the provision.

7.4 When Prometech Group receives the provision of personal information from a third party, Prometech Group shall make confirmation required by Article 26 of the Act and make and keep a record of the confirmation.

8.　JOINT USE

8.1 Prometech Group may use personal information jointly with its domestic (Japanese) group companies for the purposes of use specified in each Item of Article 2.

8.2 The address, name and the representative of the entity responsible for the management of personal information to be used jointly in accordance with the preceding paragraph are as follows.

Hongo Daiichi bldg. 8F, 3-34-3, Hongo Bunkyo-ku, Tokyo, 113-0033, Japan
Prometech Group, Inc.
Executive Vice President  Takahiko Suzuki

9.　DISCLOSURE

In cases where Prometech Group is requested by a Principal to disclose the personal information under the Act, Prometech Group shall, after confirming that the request is made by the principal, disclose the personal information to the Principal without delay (in cases where Prometech Group does not have such personal information, Prometech Group shall notify the Principal to that effect); provided, however, that this provision shall not apply to cases where Prometech Group is not obliged to disclose such personal information under the Act or other laws or regulations.

10.　CORRECTION, ETC.

In cases where Prometech Group is requested by a Principal to correct, add or delete the personal information under the Act on the ground that such personal information is contrary to the fact, Prometech Group shall, after confirming that the request is made by the principal, conduct a necessary investigation without delay within the scope necessary for the achievement of the purpose of use, and on the basis of the result, correct, add or delete the personal information and notify the Principal to that effect (in cases where Prometech Group decides not to make such correction, addition or deletion, Prometech Group shall notify the Principal to that effect); provided, however, that this provision shall not apply to cases in which Prometech Group is not obliged to make such correction, addition or deletion under the Act or other laws or regulations.

11.　DISCONTINUANCE OF THE USE, ETC.

In cases where Prometech Group is (i) requested by a Principal to discontinue using or to erase the personal information under the Act on the ground that such personal information is being handled beyond the purpose of use publicly announced in advance or has been acquired by a deception or other wrongful means, or (ii) requested by a Principal to discontinue providing the personal information under the Act on the ground that such personal information is provided to a third party without the Principal’s consent, and where it is found that the request has a reason, Prometech Group shall, after confirming that the request is made by the principal, discontinue the use of or erase the personal information, or discontinue the provision of the personal information, without delay and shall notify the Principal to that effect; provided, however, that this provision shall not apply to cases in which Prometech Group is not obliged to make such discontinuance of use or erasure, or discontinuance of provision, under the Act or other laws or regulations.

12.　HANDLING OF ANONYMOUSLY PROCESSED INFORMATION

12.1 When Prometech Group produces Anonymously Processed Information, Prometech Group processes personal information in accordance with standards prescribed by the rules of the Personal Information Protection Commission. The "Anonymously Processed Information" means the information as defined in Paragraph 9 of Article 2 of the Act which is limited to those constituting Anonymously Processed Information database etc. as defined in Paragraph 10 of Article 2 of the Act.

12.2 When Prometech Group produces Anonymously Processed Information, Prometech Group takes action for the security control of such information in accordance with standards prescribed by rules of the Personal Information.

12.3 When Prometech Group produces Anonymously Processed Information, Prometech Group discloses to the public the categories of information relating to an individual contained in the Anonymously Processed Information pursuant to rules of the Personal Information Protection Commission.

12.4 When Prometech Group provides the Anonymously Processed Information (including Anonymously Processed Information produced by Prometech Group and provided by third parties. The same shall apply hereinafter except as otherwise provided for in the Privacy Policy) to a third party, Prometech Group discloses to the public the categories of information concerning an individual contained in Anonymously Processed Information to be provided to a third party and its providing method, and states to the third party explicitly to the effect that the information being provided is Anonymously Processed Information in advance pursuant to rules of the Personal Information Protection Commission.

12.5 In handling Anonymously Processed Information, Prometech Group shall, in order to identify a principal concerned with personal information used to produce the Anonymously Processed Information, neither (i) collate the Anonymously Processed Information with other information, nor (ii) acquire information relating to those descriptions etc. or individual identification codes deleted from the personal information and information relating to a processing method carried out pursuant to the provisions of Paragraph 1 of Article 36 of the Act in connection with Anonymously Processed Information provided by third parties.

12.6 Prometech Group shall make efforts to (i) take  necessary and appropriate measures for the security control of Anonymously Processed Information and necessary action to ensure the proper handling of Anonymously Processed Information such as dealing with a complaint about the handling of Anonymously Processed Information, and (ii) to disclose to the public the contents of such measures.

13.　USE OF COOKIES AND OTHER TECHNOLOGIES

Cookies (including similar technologies.  The same shall apply hereinafter.) and the following external services may be used in Prometech Group's website in order to track the status of use.  Cookies are used in the following external services to collect browsing history without personally identifiable information and such information is managed in accordance with privacy policies of each company providing these external services.  If you wish to refuse the use of cookies by external services, you may follow the procedures described on each company's opt-out page.  You may also disable all cookies by changing the web browser’s settings.  Please note that disabling all cookies may affect the operation of the website.

(1)Google Analytics

Google Analytics Terms of Service
GOOGLE PRIVACY POLICY
Google Analytics Opt-Out Add-on

(2)BowNow

BowNow Privacy Policy
BowNow Opt-Out Add-on

14.　CONTINUOUS IMPROVEMENT

Prometech Group shall endeavor to review timely the status of the operation regarding handling of personal information and to improve such operation continuously.  Prometech Group may amend this Privacy Policy as necessary.

【Established on October 1st, 2023】
Prometech Group, Inc.
Prometech Software, Inc.
GDEP Solutions, Inc.

CONTACT

With respect to requests for disclosure, etc., comments, questions, complaints and other inquiries regarding the handling of personal information, please use the inquiry form below.

GDPR Privacy Policy

This GDPR Privacy Policy (this “Privacy Policy”) states the policy for Processing of Personal Data obtained from persons (the “User” or “Users”) residing in EU that use the product or service (the “Service”) of Prometech Group, Inc. and its domestic group companies (hereinafter collectively referred to as “Prometech Group”).  Upon the User’s agreement to this Privacy Policy, the User shall be deemed to have given a voluntary and express consent to the subject matters of the User’s consent stipulated in this Privacy Policy (including, without limitation, the purposes of Processing of Personal Data and transfer of Personal Data to third countries).

* For more information about Prometech Group, please visit here.

1.　Definitions

The following terms as used herein shall have the meanings as set forth below.  Definitions of the terms that are not defined herein shall be subject to the applicable definitions provided in GDPR.

(1) “EU” means European Union that includes the member states of European Union, as well as Iceland, Lichtenstein and Norway under Agreement on the European Economic Area (EEA).
(2) “GDPR” means REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC（General Data Protection Regulation）.
(3) “Applicable Privacy Laws” means applicable privacy laws including GDPR and domestic laws related thereto of relevant countries.
(4) “Personal Data” means “personal data” as defined in GDPR.
(5) “Processing” means “processing” as defined in GDPR.
(6) “Controller” means “controller” as defined in GDPR.
(7) “Representative” means “representative” as defined in GDPR.

2.　Scope of this Privacy Policy

This Privacy Policy shall be applied to the Processing of the Personal Data of the Users in relation to the Service that shall be governed by the Applicable Privacy laws.

3.　Users under the age of 16

If any User under the age of 16 uses the Service, it shall make sure to obtain the guardian’s consent to this Privacy Policy or to give the consent to this Privacy Policy under the guardian’s permission thereto.

4.　Controller

The Controller for the Processing of the Personal Data and contact details are as follows.

Prometech Group, Inc., Corporate Planning Department
Hongo Daiichi bldg. 8F, 3-34-3, Hongo Bunkyo-ku, Tokyo
E-mail ： web@prometech.co.jp

5.　Representative of Controller

The Representative of the Controller and its contact details are as follows.

Particleworks Europe S.r.l.
CEO Massimo Galbiati
Via della Stazione 27, fraz. Mattarello, 38123 TRENTO | Italy
E-mail ： info@particleworks-europe.com

6.　Personal Data to be Collected

6.1 Prometech Group may obtain the following Personal Data from the Users.

(1) Name and address
(2) Email address
(3) User name and password
(4) IP address, information of browser and OS, cookie information, history information of website access
(5) Telephone number and FAX number
(6) Name of company, university, department, or position which the Users belong to
(7) Address of company or university which the Users belong to
(8) Contents of the inquiries on web sites

6.2 Prometech Group may collect the Personal Data in the following cases.

(1) When the User subscribes for the Service
(2) When the User otherwise uses the Service
(3) When Prometech Group receives from affiliated parties information regarding transaction record or payment between the User and Prometech Group or the affiliated parties
(4) When the Users make inquiries on web sites