Bullet Group Inc.
4F ShinjukuSankochoBld. 5-15-5 Shinjuku,
Shinjuku-ku, Tokyo, 160-0022, Japan
Bullet Group Inc.
CEO Atsushi Ogata
Bullet Group, Inc. (hereinafter "the Company") with regard to the protection of personal information handled by the Company, we will fully recognize our social responsibility, protect the
rights and interests of the person, and comply with laws and regulations concerning personal information.
In addition, in order to embody the following policies, we hereby declare that we will establish a personal information protection management system, and we will work as a whole company on continuous improvement of it always recognizing the latest trends in IT technology, changes in social demands, variation in the business environment, etc.
- 1.With regard to personal information handled in the Company’s business and employment, personnel management, etc., we will appropriately acquire, utilize and provide personal information within the scope of the purpose of utilization specified in advance, and never handle personal information beyond the scope necessary to achieve the purpose of utilization (unintended utilization). We will also take appropriate measures for such handling.
- 2.We will comply with laws and regulations, guidelines issued by the government, and other standards concerning the handling of personal information.
- 3.We will take reasonable safety measures against risks such as unauthorized access to personal information, leakage, loss or damage of personal information, and devote management resources that match the actual situation of the business to continuously improve the security system of personal information. In addition, we will establish internal rules in which inappropriate matters shall be corrected etc. in order to protect personal information in the best condition.
- 4.We will establish internal rules for handling complaints and consultations regarding deal with personal information, and will respond promptly and sincerely to such complaints and consultations.
- 5.We will review the personal information protection management system timely and appropriately, taking into account changes in the environment surrounding the Company for continuous improvements of the system.
Article 1 Personal Information
"Personal information" refers to personal information as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter the "Personal Information Protection Act"). Other terms in this Policy follow usage in the Personal Information Protection Act.
Article 2 Purpose of Use of Personal Information
The Company will acquire and handle the personal information noted in Table 1, to the extent necessary for the purpose of use. In cases in which personal information is used beyond the extent of the purposes of use indicated in Table 1, the Company will enact any of the following measures:
- 1. When the purpose of use following change is reasonably deemed to be related to the purpose of use prior to change: The purpose of use will be amended, and affected parties will be notified or public announcement will be made.
- 2. Other cases: The purpose of use will be amended with the consent of affected parties, and the affected parties will be notified or public announcement will be made.
Table 1 Targets of personal information and purposes of use
|Target||Purpose of use|
|Users of the Company's services or applicants for use of the Company's services|
|Employees of cooperating companies, etc.||To create skill sheets and provide these to customers and to business partners|
|Sole proprietorship business partners|
|Contact persons in business partner operators|
|Employees of the Company, etc.||For personnel management, etc.|
|Persons making inquiries to the Company||To respond to inquiries regarding the Company's business|
Article 3 Management and Protection of Personal Information
- 1. The Company will not use personal information in a manner that may encourage or incite illegal or improper acts.
- 2. The Company will conduct strict management of personal information in accordance with laws and regulations, and, taking safety into consideration, will enact measures for the prevention and remediation of risks including unauthorized access, loss, destruction, falsification, and leakage of personal information.
- 3. The Company will conduct inspections of its handling, management systems, and initiatives concerning personal information, and will engage in continuous review and improvement of these.
- 4. The Company will delete or dispose of personal information when it is no longer necessary considering its purpose of use. Said deletion or disposal will be performed to the extent necessary for the execution of work, using methods that are necessary and appropriate to prevent the risk of outside leaks, etc.
5. The Company will not disclose or provide personal information to any third party without the consent of individuals concerned. However, the following cases are excluded:
- 1) When required by laws and regulations
- 2) When necessary to protect human life, person, or property and when obtaining the consent of users is difficult
- 3) When particularly necessary for the improvement of public health or the promotion of sound development of children and when obtaining the consent of users is difficult
- 4) When necessary to cooperate with a national government body, a local government body, or a party entrusted by these for the execution of affairs stipulated by laws and regulations and when obtaining the consent of users may interfere with said execution of affairs
- 5) When a third party to which information is provided is an academic research institution, etc. and when it is necessary for said third party to handle the personal information for purposes of academic research (including cases in which the purpose of handling the personal information is partly for academic research purposes but excluding cases in which a risk exists of improperly infringing on the rights and interests of individuals)
Article 4 Outsourcing of the Handling of Personal Information
The Company may outsource the handling of personal information, in whole or in part, to the extent necessary to achieve the purpose of use. In such cases, the Company will thoroughly screen subcontractors for eligibility, will stipulate matters including those concerning obligation of confidentiality in contracts, and will perform necessary and appropriate supervision of subcontractors.
Article 5 Disclosure of Personal Information
1. When disclosure of personal information held by the Company or of records provided to a third party has been requested by the individual concerned, the Company will disclose these
to said user without delay. However, if any of the following apply to the disclosure, the Company may not disclose the information, in whole or in part. When the decision has been
made to not disclose the information, the Company will provide notification of this fact without delay.
- 1) A risk exists to the life, person, property, or other rights and interests of the individual concerned or of third parties
- 2) A risk exists of significant impediment to the proper implementation of the Company's work
- 3) The disclosure would otherwise violate laws or regulations
- 2. For information on procedures, fees, etc. concerning requests for disclosure of retained personal information, contact the inquiry desk specified in Article 14.
Article 6 Correction, etc. of Personal Information
- 1) In cases in which the content of personal information held by the Company is not factual, the individual concerned may make a request to the Company for the correction, addition, or deletion of personal information (hereinafter "correction, etc.").
- 2) Upon receipt of a request as set forth in the preceding paragraph, the Company will conduct the necessary investigation without delay and, if it determines as a result that reason for the request set forth in the preceding paragraph exists, will implement correction, etc. of said personal information concerned without delay.
- 3) When the Company has made a determination on whether to implement corrections, etc. in accordance with the preceding paragraph, the Company will contact the individual concerned without delay.
Article 7 Suspension of Use of Personal Information, etc.
- 1. In cases in which an individual connected to personal information considers grounds to exist as provided for in Article 35 of the Personal Information Protection Act, the individual may make a request to the Company for the suspension of use, deletion, or suspension of provision to third parties of the personal information held by the Company (hereinafter "suspension of use, etc.").
- 2. Upon receipt of a request as set forth in the preceding paragraph, the Company will conduct the necessary investigation without delay and, upon determining as a result that grounds exist for the request set forth in the preceding paragraph, will implement suspension of use, etc. of the personal information concerned without delay. However, in cases in which suspension of use, etc. of personal information would require extensive expenses and in which implementing suspension of use, etc. is otherwise difficult, and when it is possible to enact alternative measures necessary to protect the rights and interests of the user, the Company will enact said alternative measures.
- 3. When the Company has made a determination on whether to implement suspension of use, etc. in accordance with the preceding paragraph, the Company will contact the individual concerned without delay.
Article 9 Compliance with Laws, Regulations, and Norms
The Company will comply with the laws and regulations of Japan and other norms that apply to personal information held by the Company.
Article 10 Handling of Complaints and Requests for Consultations
The Company will accept complaints and requests for consultation from individuals regarding the handling of personal information, and will respond appropriately and promptly to these. The Company will also respond appropriately to requests for disclosure, correction, addition, deletion, etc. of personal information, or refusal of the use of personal information or its provision to third parties, from the individuals concerned.
Article 11 Security Control Measures
- 1. Through the enactment of organizational, physical, human, and technical measures, including restriction of access to files recording personal information, keeping of access logs, and implementation of security measures to prevent unauthorized access from outside, the Company will prevent the unauthorized access, loss, destruction, falsification, and leakage of personal information received from individuals concerned. In the unlikely event of an incident such as a leak of users' personal information, the Company, in accordance with the Personal Information Protection Law and other laws, regulations, and related guidelines, will promptly make reports to supervisory authorities, etc. and, following the instructions of the relevant supervisory authorities, etc., will enact necessary measures including measures to prevent the occurrence of similar incidents and measures to prevent recurrence.
- 2. For details of measures enacted for security control other than as noted in the preceding paragraph, please inquire to the Company.
Article 12 Pseudonymized Information, Anonymized Information, and Information Related to Personal Information
The Company will enact necessary measures in accordance with laws and regulations when handling pseudonymized information, anonymized information, and information related to personal information.
Article 13 Company Name, Personal Information Protection Manager
The name of our company, the position and affiliation of the personal information protection manager, and contact information are as follows.
● Company Name
● Name or title, affiliation, and contact information of the personal information handling manager
Privacy Officer : Corporate IT Office / Personal Information Protection Manager
TEL : 03-5315-0602
Article 14 Inquiry Desk
Please contact the following for inquiries regarding the Company's handling of personal information.
Name of accredited personal information protection organization:
Japan Institute for Promotion of Digital Economy and Community (JIPDEC)
Point of contact for complaints:
Personal Information Protection Consultation Service Office
Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo, 106-0032
03-5860-7565 / 0120-700-779
The above contact information is not a contact for any inquiries about our services.
Revised October 1, 2023
Revised April 19, 2023
Revised January 1, 2023
Revised November 1, 2019
Enacted September 2, 2013