What data do we collect about you?

We collect data about you when you register with us, place an order for products or services or e-mail communication. We also collect data when you voluntarily complete customer surveys, provide feedback and participate in competitions.

We may obtain following categories of personal data about you from other sources than you, such as cookies on website, our outsourcees, etc.:

• Identification data such as first name, surname, pictures, IP address;
• Contact data such as e-mail address, telephone number, postal address;
• Individual data such as age, date of birth, gender, citizenship;
• Payment data such as bank account details;
• Education and employment data, such as university, specialization, function, past employers;
• Marketing data, such as your preferences in receiving marketing;
• Usage data, such as information about how you use website, products and services.
• Special category of personal data if you work for us such as information about your health

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the services but we will notify you if this is the case at the time.

Where we process personal data

When we collect your personal data in the European Economic Area ("EEA"), we may transfer and store personal data outside the EEA.
Please note that privacy laws in countries outside of the EEA may not be the same as, and in some cases may be less protective than, privacy laws in your country. We transfer data relying on the following adequate mechanism under European Union privacy laws.

• Transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by European Commission:
  https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
• Specific contracts approved by European Commission which give personal data the same protection it has in Europe:
  https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
• Transferring your personal data to companies if they are part of the Privacy Shield which requires them to provide similar protection to personal data.

When we transfer personal data to servers controlled by a third-party data hosting company either within the EEA or operating outside of the EEA, we conduct security checks on these companies to ensure adequate safeguards are in place to protect the transfer of personal data. We take steps reasonably necessary to ensure that personal data is transferred securely. Unfortunately, the transfer of data via the internet, server, database, network or email is never fully secure or error-free. Although we do our best to protect personal data, we cannot guarantee the security of the personal data you transfer to us, and you accept the inherent risk associated with such transfer.

How will we use the data about you?

Providing products and services etc.-

We use personal data of customers for the purposes of providing, maintaining and, improving our products and services. This includes using the information to:

• provide a product or service, technical support and further information of a product or service;
• respond to questions;
• protect against wrongdoing;
• enforce our website terms and conditions of use and other agreements;
• analyze trends and site usage which may help designing of new products.

We lawfully process personal data of customers (including Identification data, Contact data, Individual data and Usage data) based on the grounds of your consent, the execution of the contract, the compliance with legal obligation and the legitimate interests such as sales of products or service, customer support, product development.

Marketing -

We use personal data of customers/potential customers for the purposes of marketing activities. This includes using the information to:

• provide, administer and communicate about products, services, events, surveys and promotions;
• send marketing messages or communications;
• display contents we believe might be of interest to you;
• serve advertisement, including advertisement prepared by a third-party, through our websites

We lawfully process personal data of customers/potential customers (including Identification data, Contact data, Individual data, Marketing data and Usage data) based on the grounds of your consent and legitimate interest, such as business development, sales increase, branding.

Relation Management -

We use personal data of staffs, hiring candidates or outsourcees for the purposes of administering, managing or controlling of HR issues, recruitment or business operations. This includes using the information to:

• create and keep the HR record;
• evaluate the performance;
• administer and manage pension or insurance;
• interview a candidate and conduct a selection;
• do a contract management with outsourcees. including payment of fees.
  

We lawfully process personal data of staffs, hiring candidates or outsourcees (including Identification data, Contact data, Payment data, Education and employment data Special category of personal data) based on the grounds of your consent, the execution of the contract (whether explicit or not), the compliance with legal obligation, the legitimate interests such as human resource development, well-organized HR system, efficient business operation etc. and carrying out the obligations in the field of employment and social security.

You have the right to request us to not use your personal data for marketing communications. You can opt out of receiving marketing communications by sending e-mail to the e-mail address listed at the bottom of this policy.

Disclosure to third parties

We consider your data to be a vital part of our relationship with you. We do not sell your personal data to third parties, including to third-party advertisers.

There are, however, certain circumstances in which we may disclose, transfer or share your personal data with certain different categories of recipients without further notice to you, as set forth below:

Subsidiaries and affiliates -

We may share personal data with our subsidiaries and affiliates to provide our product, services or information to our customers. We may also share personal data of our staffs, hiring candidates or outsourcees with our subsidiaries and affiliates for our administration or management of HR issues, recruitment or operational control.

Suppliers, consultants and other third parties -

We may share personal data in the ordinary course of business when we engage suppliers to help provide products and services to you. For example, we may engage marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others. In this context, we provide personal data to such third parties solely for the purposes of delivering our products and services.

Legal Requirement -

We may disclose your personal data to regulatory or law enforcement agency, government authority, or other third parties in order to comply with a legal obligation, to prevent loss of life or injury, or to protect our rights or property. Where possible we will tell you in advance of such disclosure.

Transferees or Buyers of Business Transfer or Asset Sale -

In the event that we sell or transfer any business or asset, or if eSOL is or substantial part of its assets are acquired by a third party, any relevant personal data held by us may be disclosed to a buyer, transferee or acquirer accordingly. The buyer, transferee or acquirer will use your personal data in the same manner as set out in this privacy policy.

With your consent -

We may share your information with any other third-party after obtaining your consent on the sharing.


We may share aggregated demographic data with our partners or third party providers. This data is not linked to any information that can identify any individual person.

Your rights as data subjects

As data subject, you have the following rights with respect to personal data we hold about you:

• Right of access to your personal data (i.e. you can receive a copy of the personal data we hold and check if we are lawfully processing it);
• Right to rectification of incorrect of incomplete personal data (i.e. you can request us to correct any incomplete or inaccurate personal data we hold);
• Right to erasure of your personal data, (i.e. you can ask us to delete or remove your personal data we hold);
• Right to restriction of processing of your personal data, (i.e. you can ask us to suspend the processing of your personal data);
• Right to data portability (i.e. you can receive the personal data concerning you in a structured, commonly used and machine-readable format and to transmit those data to another controller);
• Right to object to all or part of the processing, when legally allowed;
• Right to withdraw consent at any time when we process your personal data based on your consent;
• Right to lodge a complaint with a supervisory authority in European Union.

If you wish to exercise any of the rights set out above, please contact us and send your identity document. We may ask you to submit any further information necessary for us to respond to you.

How long do we store personal data?

Your personal data is stored for different periods of time depending on the purposes of such data.
We will keep your personal data necessary for the employment management, customer management or outsource management during the period while employment relation, customer relation or outsource relation continues.
We will keep your personal data necessary for the marketing purpose or customer management purpose for up to 3 years from the last contact with you.
Personal data may be archived longer than the period described above as to comply with obligations under the law or to enforce a legal claim.

Security

We have appropriate security measures in place to protect against loss, misuse or alteration of data that we have collected. We use industry-standard encryption technologies when transferring and receiving personal data, we use network access control technology to limit access to the systems on which personal data is stored, and we monitor for possible vulnerabilities and attacks. Unfortunately, we cannot guarantee that the technical, physical and organizational measures we take will prevent every security threat, nor can we guarantee that your personal data will not be improperly accessed, used, altered or destroyed.

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. This information is used to track visitor use of the website and to compile statistical reports on website activity. You can set your browser not to accept cookies. However, in a few cases some of our website features may not function as a result.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 17 July 2018.

How to contact us

Please contact eSOL as a data controller if you have any questions about our privacy policy or information we hold about you:

- by email : esol-info@esol.co.jp

- or write to us at : eSOL Co.,Ltd., Administration Department, Harmony Tower, 1-32-2, Honcho, Nakano-ku, Tokyo, Japan.