Personal Information Protection Policy

We operate in the business domains of system integration, IT service, and information security that support the business foundation of our customers. We believe that implementing information protection systems to support the businesses of our customers, developing computer systems, and providing software that our customers can use comfortably, are of paramount importance in these business domains.

We have established this Personal Information Protection Policy as a code of conduct that all of our officers and employees should observe to ensure proper handling of personal information, etc. (meaning personal information, information related to personal information, pseudonymized personal information, and anonymized personal information; hereinafter, except where otherwise defined, such terms will have the meanings given to them in the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as the "Personal Information Protection Act") of Japan) that we obtain from our customers in the course of our business activities. and shall strive to ensure compliance with this Policy.

1. Acquisition, use, and provision of personal information

We will obtain consent of the relevant individual again, in case personal information is to be used or provided to third parties beyond the scope necessary to achieve the purpose of use.
When creating pseudonymized personal information or anonymized personal information, we will process personal information in accordance with legislative standards. We will apply security measures equivalent to those applied for personal information to processed or acquired pseudonymized personal information and anonymized personal information, and use such information in a lawful manner.
It is up to the discretion of the relevant individual to withhold consent to provision of personal information to third parties, but in such a case, the relevant individual may experience disadvantages, such as the purpose of use not being achieved. We ask for your kind understanding.

2.Compliance with laws and regulations, national guidelines, and standards concerning personal information, etc.

We will ensure that our employees comply with laws and regulations, national guidelines, and other standards applicable to the protection of personal information, etc., when handling personal information, etc. We will also ensure that our personal information protection management system complies with such laws and regulations, national guidelines, and other standards.

3. Safety measures applied to personal information and personal data

We will strictly manage personal information and personal data, and take the following measures to prevent and mitigate various risks including leakage, loss, and damage of or to such information.

(Organizational safety management measures)

We will establish a personal information management system, appoint a person responsible for the handling of personal information and personal data, and, when obtaining personal information through our website or other means, clearly indicate in advance who will be taking responsibility for the management of such information on the specific web page through which the personal information is to be obtained.
We have also implemented rules for the handling (acquisition, protection, storage, entrustment, provision, and disposal) of personal information and personal data, and have established a system to ensure compliance with such rules by all of our officers and employees.
In addition, we have established a system that provides for regular internal audits, external assessments, and continuous improvement efforts, to maintain the effectiveness of the management system.

(Human safety management measures applicable to employees)

Our Rules of Employment include provisions on confidentiality obligations regarding personal information and personal data, which employees are required to comply with. In addition, we provide regular training to employees on issues involved in the handling of personal information and personal data.

(Physical safety management measures)

Even in areas where personal information and personal data are handled, measures are taken to prevent unauthorized persons from viewing personal information and personal data, and measures are taken to prevent theft or loss of devices, electronic media, documents, etc. that handle personal information and personal data. In addition to taking measures to prevent personal information and personal data from being easily revealed when carrying such equipment, electronic media, etc., including when moving within the office.

(Technical safety control measures)

In order to prevent information leaks due to unauthorized access, etc., we have taken measures such as controlling access to information systems that handle personal data, and introducing technical measures such as countermeasures against unauthorized software and encryption.

(External environment study)

When storing personal information and personal data outside Japan, we will implement safety management measures after fully familiarizing ourselves with the policies related to personal information protection in the relevant country.

4. Provision of personal data to third parties

In general, we do not provide acquired personal data to third parties without the consent of the relevant individual. We will only provide personal data with the consent of the relevant individual.
However, we may provide personal data to third parties without your consent in the following cases:

(1) Where disclosure is required under laws and regulations
(2) Where necessary to protect vital interests, such as life, health, or property of a person (including legal persons)
(3) Where particularly necessary for the improvement of public health, or the sound upbringing of children in the process of mental and physical development
(4) Where necessary to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations.

In addition, we may provide information that has been processed to a state that renders it impossible to identify individuals, to third parties as statistical data. However, in the following cases, the person receiving the personal data shall be deemed not to constitute a third party.

(1) When entrusted based on our purpose of use
(2) When personal data is provided as part of a succession of business due to a merger or other reason.

5. Entrustment of personal data

When we are to use personal data via entrustment to a third party, we shall select a company that meets the personal information management standards stipulated by us, and only provide data after concluding a confidentiality agreement with that third party. We will also exercise appropriate supervision over the entrusted party.

6. Acquisition of information related to personal information on websites

We collect information related to personal information of users on our website in order to improve our services. Collected information will be used solely for usage analysis, compiling of reports to the site operator, and provision of other services.

Details of the collection method

- Cookies
　 Our website uses cookies.
　 Cookies are a technology that allows websites to temporarily store data on your computer through the web browser and retrieve it at a subsequent point in time. You may reject cookies by adjusting your browser settings, but if you do so, you may not be able to utilize some of the functions of our website.
However, we bear no responsibility for ensuring the safety of personal information on websites linking from our website. Please make sure to read the privacy policies and other notices of the websites linking from our website to verify the protection of personal information provided on such websites.

- Use of Google Analytics
　 Our website uses Google Analytics to analyze your usage of our website. 　 Google Analytics uses cookies to collect, record, and analyze your usage of our website.
　 For more information on Google Analytics, please read Google Analytics' Terms of Use and Privacy Policy.

< Google Analytics Terms of Use >
< Google Analytics Privacy Policy >

7. Disclosure requests, corrections, deletions, and response to complaints and consultation requests regarding handling of information

We have established the following contact point for requests (request for notification of the purpose of use; disclosure; correction, addition, or deletion; suspension of use or elimination; suspension of provision to a third party; and disclosure of records provided to a third party), complaints, and consultation requests concerning personal information and personal data held by us, and will endeavor to respond to such requests, etc., as much as practical and in a timely and sincere manner.

Personal Information Contact Desk
Focus Systems Corporation
2-7-8 Higashi Gotanda, Focus Gotanda Bldg., Shinagawa-ku, Tokyo 141-0022
TEL: 03-5421-7785　 FAX: 03-5421-3201　E-Mail: PrivacyMark@focus-s.com

8. Continuous improvement of our personal information protection management system

We will continuously aim to improve our personal information protection management system in line with changes to the environment surrounding us and the information that we handle.

Established June 1, 2004
Revised March 30, 2018
Revised March 7, 2022
Revised January 29, 2024

President Keiichi Mori