This is the privacy policy (“Privacy Policy”) for any application or web service owned or operated (collectively the “Platform”) provided by Ginco, with its registered office address at 3-27-4 Hatchobori, Chuo-ku, Tokyo 104-0032, Japan (“our”, “we”, or “Ginco”). Ginco is the controller of your personal data collected through the Platform and we are committed to protecting and respecting your privacy.

1.Introduction

This Privacy Policy explains who we are, why and how we process personal data collected through your use of the Platform and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.
When you supply any personal data to us we have legal obligations towards you in the way we use that data. We must collect the information fairly and explain to you how we will use it.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice that we may provide at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data.
This Privacy Policy supplements other notices and legal documents including the Terms of Service (“Terms”) and is not intended to override or replace them.
If, for any reason, you do not agree to the terms of this Privacy Policy, please stop using the Platform.
We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law.
Please note that the Platform is not intended for use by nor directed at anyone under the age of 18 and we do not knowingly collect data relating to children. If you believe we have collected personal information about your child, you may contact us at contact@ginco.co.jp and request that we remove information about them.

2.What information we collect 

What is personal data?

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, or your contact details.

How and what types of data we collect from you when you use the Platform

When you use the Platform to register an account, fill in forms provided on the Platform, subscribe to our services, or report a problem with the Platform, we may collect, store and use certain personal information that you disclose to us.
The information we collect from you may include (but is not limited to): your IP address, email address, telephone number, feedback, and log-in information.
We shall also collect information about you when you visit and interact with the Platform by technologies such as cookies. The following are examples of information we may collect:
・information about your device, browser or operating system;
・time zone setting;\n・your IP address;
・information about interactions you have with the Platform (such as scrolling and clicks);
・information about the way you use and the actions you take within the Platform;
・length of time on the Platform and time spent within certain sections;
・response times; and\n・download errors.
Please refer to your device’s help material to learn what controls you can use to remove cookies. If you do this, it may affect your use of our website or mobile application.
We may also partner with third parties who may collect anonymous usage or statistical data through your use of the Platform (including, for example, sub-contractors in technical, payment and/or delivery services, business partners, advertising networks, analytics providers).
We may also collect information about how you use the Platform through Google Play’s Android Advertising ID technology and Apple iOS’s Advertising Identifier. This is used only by us and our trusted third party service providers (see “Service Providers” below) for advertising and user analytics. The advertising identifier will only be connected to personally identifiable information where you have provided us with your explicit consent. We will respect your user selections for this technology and will not use the data in any way which you have asked us not to. We are committed to abiding by Google and Apple’s terms of use and you may contact us (at contact@ginco.co.jp ), Google or Apple directly if you have any questions regarding our use of this technology.

Updating your information

If you want to update the information you have previously given to us, you can contact us at contact@ginco.co.jp

3.How and why we use/share your information

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
Where you have asked us to do so, or consented to us doing so;
Where we need to do so in order to perform a contract we have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.

Marketing

You will receive marketing messages from us if you have given us your consent to do so or if you have provided feedback on our Platform and have not opted out of receiving marketing messages (and it is within our legal rights, when balanced against your rights and freedoms as an individual, to serve you with marketing).
To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.

Sharing your information

Depending on how and why you provide us with your personal data, we may share it in the following ways:
with selected third parties including subsidiaries, business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you (see “Service Providers” below); or
with analytics that assist us in the improvement and optimization of the Platform.
We may also disclose your personal information to third parties in the following events:
if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets;
if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply the Terms; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.
Our third party service providers currently include: Slack, Notion, GoogleWorkspace, Github, DocuSign, Zendesk and Backlog.

Other Disclosures

During your use of the Platform, your app store provider, mobile network operator, third party APIs or others may also collect personal information about you regarding your use of the Platform such as your identity, your usage and location.
These third parties shall act as separate and independent controllers of that personal data and shall process it in accordance with their own privacy policy.

Links to third party sites

The Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. We may also provide links to third party websites that are not affiliated with the Platform. Third party websites are out of our control and are not covered by this Privacy Policy. If you access third party sites using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

4.How long we keep your information

We retain personal data for as long as necessary to fulfill the purposes for which we collect or receive the personal data, except if required otherwise by applicable law.
Typically, we will retain most of the personal data for the duration of your use of the website, until you removed your account plus an additional 180 days as a maximum, unless a longer applicable statutory retention period applies.

5.Security

Ginco takes the protection of your information very seriously. We have put in place appropriate physical, electronic and managerial security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed, including use of secure servers, passwords and industry standard encryption for data both in transit and at rest.
Where we have given you a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.

6.International Data Transfers

Japan

As Ginco is based in Japan, we securely process personal data mainly in Japan. On January 23, 2019 the European Commission has adopted an adequacy decision on Japan, allowing personal data to flow freely between the two economies on the basis of strong protection guarantees.

Third countries

If applicable, Ginco shall put the appropriate legal framework in place, notably Standard Contract Clauses (SCC) approved by the European Commission.

7.Your Rights

You have the following rights in relation to your personal information and data stored with us:
a)   the right to obtain, at reasonable intervals and free of charge, information on whether your personal data is being processed and to receive the personal data that is being processed in an intelligible form;
b)   the right to rectify, block or erase your personal data if the data is incorrect, incomplete, inaccurate, irrelevant, outdated or processed in violation of the law;
c)   the right to object on legitimate grounds to the processing of your personal data. Please contact us using our contact information stated below to exercise these rights;
d)   to exercise these rights, please contact us using our contact details set out below. We may request you to provide a proof of identification.

Withdrawal of consent

Where we are relying on consent to process your personal data you may withdraw consent at any time. 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.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request.
If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

8. Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at contact@ginco.co.jp

9.Updates to this Privacy Policy

We may update this privacy statement anytime. We encourage you to periodically review this Privacy Policy to be informed of how we use your information.
Data Subjects have the right to contact the competent supervisory authority to report a complaint or if they feel that WED has not addressed their concern in a satisfactory manner.

10.Right to contact the appropriate authority

You have the right to contact the competent supervisory authority to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner.

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Effective Date: December 15, 2023
Ginco Inc.
3-27-4 Hatchobori, Chuo-ku, Tokyo 104-0032, Japan
contact@ginco.co.jp