Handling of Personal Information by the Company
Based on its “Personal Information Protection Policy,” the Company is committed to the appropriate protection of personal information. The following provides information regarding personal information acquired or retained by the Company for use in its business.
(1) Name and Address of the Business Operator Handling Personal Information, and Name of the Representative in the Case of a Corporation
Business Operator: Impact Circle Inc.
Representative Director and CEO: Satoshi Takahashi
Address: 16F Sumitomo Fudosan Shibakoen Tower, 2-11-1 Shibakoen, Minato-ku, Tokyo
(2) Name or Job Title, Department, and Contact Information of the Personal Information Protection Manager or Their Representative
Personal Information Protection Manager: Naoki Ozawa
Email: info@impact-circle.co.jp
(3) Purpose of Use of Personal Information
The purposes of use of personal information handled by the Company in its business activities are as follows.
① Retained Personal Data
- Business Partner Information
For business management, various communications, billing, and payment management. - Employee Information
For use in operations related to employee management, including business, labor, and personnel management, payroll-related operations, employee benefits, and similar matters. - Job Applicant Information
For use in recruitment-related operations, including the provision of recruitment information, judgment of hiring suitability, and communications related to recruitment activities. - Retiree Information
For communication with retirees and responding to inquiries from retirees. - Inquiry Information
For responding to inquiries. - Information of the Individual and Their Representative in Cases of Requests for Disclosure, etc.
For responding to requests for disclosure, etc.
② Other Personal Information Acquired
- Personal Information Acquired Through Entrusted Business Operations
For contracts and related communications, performance of entrusted business operations, aftercare, and similar purposes. - Information Acquired from Job Posting Websites
For judging and notifying applicants of hiring decisions.
(4) Contact for Inquiries Regarding Personal Information
For complaints, consultations, and inquiries regarding the handling of personal information, including matters related to retained personal data, please contact the inquiry desk listed below.
(5) Name of Authorized Personal Information Protection Organization to Which the Company Belongs and Contact for Filing Complaints
None.
(6) Procedures for Disclosure, etc.
The Company will promptly respond to requests from the individual regarding retained personal data, including notification of the purpose of use, disclosure, correction, addition or deletion of content, suspension of use, erasure, suspension of provision to third parties, and disclosure of records of provision to third parties.
When such a request is made, the Company will verify that the requester is the individual concerned or their representative, and will respond within a reasonable period and scope.
(7) Method and Contact for Receiving Requests for Disclosure, etc.
Requests for disclosure, etc. regarding retained personal data should be made to the inquiry desk listed below.
Upon receiving your inquiry, the Company will send its prescribed “Request Form for Disclosure, etc. of Retained Personal Data” by post, fax, email, or other means. Please fill in the required information, enclose the necessary documents, and submit the form by post, email, or other appropriate means. The requester shall bear any mailing costs.
After verifying that the requester is the individual concerned or their representative, the Company will respond using the requested disclosure method.
(8) Measures Taken for the Security Management of Personal Information
In order to handle personal information strictly and appropriately, the Company has established rules and regulations concerning personal information based on a personal information protection policy compliant with JIS Q 15001, and operates a personal information protection management system.
To ensure the appropriate handling of personal information, the Company implements security control measures from four perspectives: organizational, human, physical, and technical.
- Organizational Measures
- The Company appoints a person responsible for handling personal information and clearly defines the responsibilities and authority of employees regarding the security management of personal information.
- The Company supervises employees and has established a reporting and communication system to the responsible person in the event of an emergency such as a personal information leakage.
- The Company regularly checks the status of personal information handling through internal audits.
- Personal information that is no longer necessary in light of its purpose of use will be promptly and appropriately deleted or disposed of.
- Human Measures
- The Company conducts personal information protection training once a year for all employees.
- The Company obtains confidentiality agreements covering personal information.
- Physical Measures
- The Company implements entry and exit controls, prohibits the handling of personal information in places other than those authorized by the Company, and takes measures to prevent unauthorized persons from viewing personal information.
- When devices, electronic media, documents, and other items containing personal information are moved within the office or carried outside the Company, the Company takes precautions against theft or loss and implements measures to ensure that personal information cannot be easily identified.
- Technical Measures
- IDs with access privileges are managed by the Personal Information Protection Manager, who handles their issuance, renewal, and deletion. Access privileges of users who no longer use the information are promptly revoked.
- Understanding of External Environments
- Applicable if personal information is provided overseas. Delete this section if not applicable.
- The Company entrusts the storage of information, including part of its personal data, to cloud service providers. Such personal data is stored in the United States under the management of the relevant service providers. Based on information provided by the Personal Information Protection Commission and other sources, the Company understands the personal information protection system in the United States and implements appropriate security control measures.
For details regarding specific security control measures, please contact the inquiry desk listed below.
Established: March 3, 2026
【Inquiry Desk】
Name of Desk
Personal Information Inquiry Desk
Contact Information
Person in Charge: Naoki Ozawa
Address: 16F Sumitomo Fudosan Shibakoen Tower, 2-11-1 Shibakoen, Minato-ku, Tokyo
Email: info@impact-circle.co.jp