Actiphy, Inc. Personal Information Protection Policy
Actiphy, Inc. (hereinafter,“Actiphy”), a developer and distributor of computer software such as the storage management tools, disaster recovery programs, etc., has gained a high reputation and earned the trust of its customers, including individuals and corporate clients in information system divisions of business organizations. Based on its philosophy that personal information obtained from its customers, employees, and other stakeholders in the course of business activities is a valuable asset, Actiphy recognizes that the top priority in its business operation is to closely protect and appropriately handle personal data.
In order to constantly provide our customers with secure and reliable services, Actiphy abides by the laws, regulations and guidelines pertaining to protection of personal information. Actiphy has established a Personal Information Protection Policy, which it carefully implements.
Established: July 1st, 2020
Revised on April 1, 2022
8 Kanda-kon’yacho, Chiyoda-ku, Tokyo 101-0035
President & CEO: Jiang Guancheng
- Definition of Personal Information
Personal Information refers to information of a living individual and includes name, date of birth, address, telephone number and any other types of information that can identify specific individual. Furthermore, Personal Information includes information that can be correlated with other information and thereby identify the specific individual.
- About Pseudonymisation and Anonymization
When processing personal data by using pseudonymisation (the processing of personal data in such a way that the personal data can no longer be attributed to a specific person whilst allowing the recipients to link different pieces of information together by taking measures pursuant to the related laws and regulations) or anonymization (the process of removing personal identifiers completely and irreversibly that may lead to an individual being identified by taking measures pursuant to the related laws and regulations), Actiphy shall abide by the following code of practices.
- Appropriately process personal data observing the laws and regulations.
- For the prevention of information leakage regarding how to handle the deleted information or data processing method, take safety control measures observing the laws and regulations.
- Publicize the items of the information included in the created anonymization processed data.
- Do not identify specific individual in reference to personal information, based on which Pseudonymisation / Anonymization processed data were created.
- Collection, Use and Provision of Personal Data
Actiphy collects, use and provide personal data only in an appropriate and fair manner. Actiphy identifies the purpose of use of them and takes measures to never use them beyond the intended purpose.
- Maintenance of Security and Accuracy of Personal Data
In order to maintain security and accuracy of personal data, Actiphy deploys security measures, strives to prevent illegal access or loss, destruction, falsification and leakage of personal data, and takes corrective measures.
When the situation occurs pertaining to security of personal information including the loss, destruction and leakage of personal data which the risk is high that damage the rights or interests of the owner of the personal information as specified in the Personal Information Protection Commission Rules, Actiphy shall report the occurrence of the situation to Personal Information Protection Commission.
- Review and Improvement of Subcontracted Work
Regarding subcontracted work, Actiphy reviews and improves subcontracted work so that protection of personal information should be undoubtedly ensured. When drafting a subcontract agreement, the subcontractor’s obligation to observe Act on the Protection of Personal Information must be included. Also, Actiphy takes all necessary measures to manage and supervise such subcontractors for protection of personal information.
- Establishment of Management Framework for Personal Information Protection and keeping all officers and employees familiar with the framework
Actiphy has established the Personal Information Security Officer who assumes the clearly defined responsibility of protecting personal information. Actiphy also deploys a management framework for practicing activities in relation to personal information protection and continuously takes corrective measures.
Actiphy keeps all officers, employees, and other staff members familiar with the management framework for practicing activities in relation to personal information protection.
- Observation of Personal Information Protection Law
In handling personal data, Actiphy abides by “Act on the Protection of Personal Information” (Act No. 57 of 2003), the laws, regulations and guidelines pertaining to protection of personal information.
- Continual Improvement of Personal Information Security Management System
Actiphy established Personal Information Security Management System which Actiphy steadily implements, maintains and continually improves to protect and appropriately use personal data.
- Revision of Personal Information Protection Policy
Actiphy may revise the Personal Information Protection Policy and provides information on important changes on this website.
- “Personal Information Security Management System”：Personal Information Security Management System is a comprehensive management structure designed to protect personal information, including establishment of Personal Information Protection Policy, planning, deployment, implementation, examination and review of a management framework for practicing activities in relation to personal information protection.
Actiphy,Inc. Handling of Personal Information
Purpose of use of personal information
Actiphy intends to collect personal data and to use it in the course of business activities for the following purposes:
- To notify and communicate information regarding business transactions with Customer
- To promote sales of the products which Actiphy distributes
- To send information about the products and services which Actiphy provides or to introduce a related service
- To offer a downloadable product/catalog, an upgrade version of the product or product support which Actiphy provides
- To introduce seminars/events and to confirm participation in the seminars/events For the purpose of market research, marketing or development of a new product/service, to conduct questionnaire surveys and to collect the results only after Actiphy has obtained consent from Customer
- When an inquiry is received, to confirm the identity of Customer and the details of the inquiry
- To examine qualification of a candidate who applied for a recruited job
- Some other purpose which Actiphy has obtained consent from the customer
When the need to use the collected personal data for any purpose that goes beyond the above stated purpose arises, Actiphy clearly specifies the purpose of use and contacts for inquiries.
If you do not agree to provide personal information
Although it is not necessary to answer all of the items but we may be unable to provide our services if necessary information is missing.
Disclosure, Correction, Addition or Deletion、Cessation of Use, Erase and Cessation of Disclosure to Third Parties
Actiphy complies with requests from an individual such as disclosure, correction, addition or deletion, cessation of use, erase and cessation of disclosure to third party of personal information of the individual, only after confirming that the requester is identical to the individual, with no particular reason to refuse, to reasonably limited extent, maintaining a reasonable schedule.
Actiphy, if requested to disclose personal information by an individual of such information, shall charge the handling fee as listed below:
- Medium：In writing (in Japan)
- Fee：300 JPY per an individual of Personal Data (tax included)/ 430 JPY for postage (Simple Registered Mail)
Inquiry Contact for Personal Information
A customer or a stakeholder is asked to directly inquire for his/her personal information to the following contact via E-mail or postal mail. Actiphy will respond to the individual inquiry via E-mail or in writing.
- E-mail Address: email@example.com
- Postal Address: Actiphy,Inc.
Personal Information Protection Promotion Bureau Actiphy,Inc.8 Kanda-kon’yacho, Chiyoda-ku, Tokyo 101-0035
Terms and Conditions of Use of Actiphy’s website
- Maintenance of Security
Personal information of customers who visit Actiphy’s website is saved in the database built behind the system (firewall) protecting from external invasion. Also, personal data received from customers at the time from data entry to registration is protected by (SSL/TLS) encryption.
- Access Log
Actiphy’s website keeps log records of visiting histories. The access-log contains the visitors’ domain names, IP address, a type of browser used, access dates, links used, etc., but such information does not identify individuals. The access-log is utilized only for the purpose of maintaining our web server and statistically analyzing customers’ usage of our website.
- Personal Information Protection at Linked Third Parties’ Websites
The use of the license server operated by Actiphy, Inc.
- Personal Information required for online activation
Actiphy’s Online Activation License Server is designed not to collect personal information. Under the supervision of a lawyer who specializes in GDPR (General Data Protection Regulation), the information required for online activation including operating environment and other information is processed by utilizing the technologies such as hashing, k-anonymization, deletion of detailed information, so that the processed information cannot be matched with each other within the whole. The processed information is stored and automatically disposed of in a short period of time.
A Person in Charge for Personal Information Protection
Accounting & Human Resources Manager (firstname.lastname@example.org)