Enacted on May 25th 2018
Last Revised on January 4th 2019
NTT Communications Corporation,
with registered office and business address
at OTEMACHI PLACE WEST TOWER 2-3-1 Otemachi, Chiyoda-ku, Tokyo, Japan
President Toru Maruoka
The Company will comply with laws and standards concerning the protection of Personal Data, and take all necessary measures to protect your Personal Data.
- Categories of Personal Data Collected and Sources
We may collect or otherwise obtain access to your Personal Data as follows:
- if we are engaged to provide our services by a corporate client that you work for (or are being considered as a potential service provider), your employer may provide your business contact information to us for the purposes of managing our service agreement ("Business Contact").
If we process your Personal Data as a Business Contact then the categories of Personal Data that we collect and process are your name, business email address and phone number, job title and function. We use this information for our legitimate business interests for purpose of managing our contractual relationship with your employer in accordance with the terms of that engagement, including for the purpose of:
- notifying any changes in charges and services;
- managing the contract and providing our services in accordance with the applicable engagement terms or service agreement;
- responding to proposals and provide consultation services;
- providing promotional materials or gifts and conduct sales promotions in relation to corporate services;
- conducting customer satisfaction surveys;
- improving Company's services and for developing new services; and
- answering any questions or provide consultation as may be requested.
In addition to the purposes set out above, we may from time to time specify other purposes as part of the ongoing services or a customer satisfaction survey but in such case, we will clearly notify you of this in the relevant communication
Please note that where we process your Personal Data as a Business Contact, we may need to retain your Personal Data even if your employment ceases or our contract with your employer is terminated or expires. We will retain and process your Personal Data in these circumstances for the purpose of compliance with applicable laws and regulations such as our corporate income tax laws and regulations and potential legal claims and it will be destroyed or deleted once it is no longer required.
- Data Security
We will protect Personal Data that you provide, or your employer provides on your behalf through continuous efforts to:
1) maintain internal regulations and internal management system to protect Personal Data,
2) provide employee training, and
3) take appropriate measures against illegal access, loss, destruction, falsification, and disclosure of Personal Data.
- Disclosure and Provision of Personal Data
2) In respect of sub-section 1 above, subject to compliance with applicable laws and regulations, we will verify that each subcontractor and/or Group Company to which Personal Data is to be disclosed by us has implemented the measures necessary to protect Personal Data, and take all appropriate and necessary actions including but not limited to entering into appropriate agreements (or internal arrangements as appropriate) with such subcontractors and/or Group Company to protect Personal Data.
4) Notwithstanding anything to the contrary stated above, we may disclose and provide Personal Data to government authorities, including but not limited to any court or police if required or requested properly pursuant to any applicable law or order.
- Transfers outside the EEA
If your Personal Data is transferred outside the EEA to any jurisdiction that does not have equivalent data protection laws then we will ensure that such arrangements are governed by data transfer agreements or mechanisms designed to ensure that your Personal Data is protected (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission).
Except as set out in the final paragraph of Section 2, we will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
- Contact Point for Rights of Personal Data
If you have any questions or comments in relation to your Personal Data, please contact to the following contact point. Company will respond to your requests in a timely manner.
<Contact Point for Rights and Inquiries for Personal Data>
NTT Communications Corporation
OTEMACHI PLACE WEST TOWER 2-3-1 Otemachi, Chiyoda-ku, Tokyo, Japan
You may have a right of access to the Personal Data that we hold about you and you may also require any inaccurate information to be corrected and/or deleted. You may also have the right to object to our use of your Personal Data for our legitimate business purposes in some situations. If you wish to exercise any of these rights, please contact us at the details set out above.