Privacy Policy
GMO Flatt Security Inc. (hereinafter referred to as the “Company”) establishes this privacy policy (hereinafter referred to as the “Policy”) regarding the handling of personal information of users of https://flatt.tech (hereinafter referred to as the “Website”), users of services provided by the Company (hereinafter referred to as the “Company Services”), and candidates for employment with the Company (collectively referred to as “Users, etc.”, with individual service users referred to as “Service Users”).
Article 1 (Personal Information)
"Personal Information" refers to “personal information” as defined under the Act governing personal information in Japan, the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter the “Personal Information Protection Act”), and means information relating to a living individual that can identify a specific individual by name, date of birth, or other description contained in such information, or which includes personal identifiers.
Article 2 (Method of Collecting Personal Information)
The Company may request Users, etc. to provide personal information such as name, date of birth, and email address when using the inquiry function on the Website or when using the Company Services. The Company may also collect such information from the Company’s business partners with whom the Users, etc. have engaged.
Article 3 (Purpose of Collecting and Using Personal Information)
The purposes for which the Company collects and uses personal information are as follows. The Company shall use such information only within the scope of these purposes. If the Company intends to use personal information beyond the stated purposes, it shall obtain prior consent from the Users, etc. by appropriate means.
(1) Personal Information Directly Obtained by the Company
(i) Personal information of Service Users:
For service contracts, user management, and related operations
To respond to inquiries
To provide information on new features, updates, campaigns, and other marketing purposes including email newsletters
For security purposes or investigation and reporting of incidents
For important operational communications including maintenance notices and terms updates
To identify and communicate with users who violate terms or use services improperly
To enable users to review or update their registration or usage information
For identity verification or legal procedures
For requests such as interviews, surveys, campaigns, or monitors
To respond to opinions and inquiries
For related incidental purposes
(ii) Personal information of individuals who request materials or contact the Company:
For marketing and promotional purposes as mentioned above
For investigation or communication in case of security incidents
For operational communications such as maintenance and policy updates
To identify and deal with improper service usage
To respond to opinions and inquiries
For related incidental purposes
(iii) Personal information of participants in events or seminars:
For event/seminar management
For sending and managing surveys
For marketing and promotional purposes as mentioned above
To respond to opinions and inquiries
For related incidental purposes
(iv) Personal information of recruitment candidates:
To provide recruitment information
To respond to inquiries from candidates
To contact candidates regarding applications or employment opportunities
To assess suitability during recruitment
To improve recruitment processes
For appropriate management of candidate data
To use the information for future hiring plans or statistical data
To conduct employment procedures if a contract is concluded
For employment management after onboarding
(2) Personal Information Obtained through Commissioned Work
(i) Personal information entrusted by Service Users in connection with commissioned services:
To provide and manage the Company Services
To respond to inquiries
For security and incident response purposes
For operational communications
To identify and deal with improper service usage
For identity verification or legal procedures
To respond to opinions and inquiries
For related incidental purposes
Article 4 (Provision of Personal Information to Third Parties)
Except as permitted under the Personal Information Protection Act and other laws, the Company will not provide personal information to third parties without prior consent from the Users, etc.
Notwithstanding the above, the following cases are not considered “third-party provision”: When outsourcing handling of personal information within the necessary scope of achieving usage purposes In the event of business succession due to mergers or other reasons When jointly using personal information with specified entities, where details of such shared use and responsible parties are disclosed or made readily accessible to the individual in advance
Article 5 (Disclosure of Personal Information)
Upon request from the individual, the Company will promptly disclose their personal information. However, if any of the following apply, the Company may withhold disclosure in part or full, and will notify the individual accordingly. A fee of 1,000 yen per request may apply. If disclosure may harm the life, body, property, or rights of the individual or third party If it may significantly hinder proper execution of the Company’s operations If it would violate laws and regulations
Non-personal information such as history or characteristic information will not be disclosed in principle.
Article 6 (Correction and Deletion of Personal Information)
Users, etc. may request correction, addition, or deletion (“Correction, etc.”) of their personal information if it is found to be incorrect.
Upon determining that the request is valid, the Company will promptly make the necessary corrections.
The Company will notify the individual once corrections are made, or if a decision is made not to act on the request.
Article 7 (Suspension of Use of Personal Information)
If the individual requests suspension or deletion of their personal information (“Suspension, etc.”), the Company will promptly investigate the matter.
If it determines that such request is valid, the Company will promptly implement the Suspension, etc.
The individual will be notified of the results of such actions or decisions.
If implementation of Suspension, etc. is difficult or costly, alternative measures may be taken to protect the rights of the Users, etc.
Article 8 (Acquisition of Other Information)
The Website and certain Company Services collect IP addresses, access frequency, browser/OS/device information using log files, cookies, and web beacons.
The Website and some services use Google Analytics, a web analytics service provided by Google. Data collected is anonymized and does not identify individuals. Users can disable cookies in their browser settings. For details, see:
https://policies.google.com/technologies/partner-sites?hl=en
Article 9 (Changes to the Policy)
Except as otherwise provided by law or specified herein, the Company may revise this Policy without prior notice.
Unless specified otherwise, the revised Policy will take effect when posted on the Website.
The Company complies with applicable Japanese laws and regulations, and continually reviews and improves this Policy.
Article 10 (Contact Information)
For inquiries regarding this Policy:
Address: Cerulean Tower, 6F, 26-1 Sakuragaoka-cho, Shibuya-ku, Tokyo, Japan
Representative: Koki Ide
Company Name: GMO Flatt Security Inc.
Email: contact@flatt.tech
Enacted: June 2, 2019
Revised: October 24, 2020
Revised: March 31, 2022