As a software platform vendor that develops and provides information technology services, we recognize that personal information is a valuable asset of individuals.
We are committed to the proper acquisition, use, and provision of personal information, compliance with laws and regulations concerning personal information, and the prevention and rectification of incidents such as the unauthorized disclosure of personal information.
To this end, we have implemented a personal information protection management system and are committed to its ongoing improvement.

1. Proper acquisition, use and provision of personal information

   We will ensure the proper acquisition, use, and provision of personal information. Upon acquiring personal information, we will specify the intended purpose of its use to the extent possible and implement measures to prevent any usage beyond what is necessary to achieve that purpose.
   Furthermore, in principle, we will not provide personal data to third parties without the consent of the individual to whom it belongs. Additionally, when sharing personal data with third parties or outsourcing operations, we will establish contracts to prevent its unauthorized disclosure or redistribution and ensure proper oversight.

   * For details on the purpose of using personal information, please refer to our “Handling of Personal Information” below.

2. Prevention and rectification of incidents such as personal information leaks

   We prevent the unauthorized disclosure, loss, or destruction of personal data by implementing security management systems appropriate to the sensitivity of the information.
   If such an incident occurs, we will work to resolve it, incorporating both internal and external feedback.

3. Compliance with laws and regulations and other norms regarding personal information

   We will comply with all laws and regulations concerning personal information, such as the “Act on the Protection of Personal Information,” along with other national guidelines and standards, taking into account their enactment and subsequent revisions.

4. Concerning the continual improvement of the personal information protection management system

   We appoint a Personal Information Protection Manager, granting them responsibility and authority for the implementation and operation of our personal information protection management system.
   We will continuously review the content of this system and strive for its improvement.

5. Contact information

   We will strive to respond appropriately to inquiries and grievances regarding personal information.

   For inquiries regarding our handling of personal information and the personal information protection management system, please contact us using the contact information listed below.
   For requests concerning the disclosure, correction, or suspension of use of retained personal data, as well as requests for disclosure of records of provision to third parties, please refer to the “Information regarding retained personal data” listed below.

• Name of the Company, address, and name of representative

  i Cubed, Inc.

  Personal Information Inquiry Desk
  i Cubed Systems, Inc.
  Dai Ichi Myojo Building 4F, Tenjin 4-1-37, Chuo Ward, Fukuoka City, Fukuoka 810-0001

  Tsutomu Sasaki, President and CEO

• Purpose of use of personal data retained by our Company

  Please refer to the “Handling of Personal Information” section below regarding the purposes for which we use the personal data we retain.

• Concerning measures taken to ensure the secure management of personal data retained by our Company

  - Formulation of basic policy

  To ensure the proper handling of personal information, we have established a privacy policy regarding matters such as compliance with relevant laws, regulations, and guidelines, as well as a contact point for addressing inquiries and grievances.

  - Establishment of rules governing the handling of personal data

  We have established standard procedures for the collection, use, and storage of personal data, as well as other related processes.

  - Organizational security management measures

  We conduct routine internal reviews of our personal data handling practices in addition to undergoing audits by other divisions and external parties.

  - Personnel-related security management measures

  We conduct regular training for employees concerning guidelines for handling personal data.

  - Physical security management measures

  We have implemented measures to prevent the theft or loss of equipment, electronic media, documents, and other items that contain personal data.

  - Technical security management measures

  We have implemented mechanisms to protect information systems that handle personal data from unauthorized external access or malicious software.

• Contact information for filing grievances regarding the handling of retained personal data

  Inquiries regarding personal information

  Personal Information Inquiry Desk
  i Cubed Systems, Inc.
  Dai Ichi Myojo Building 4F, Tenjin 4-1-37, Chuo Ward, Fukuoka City, Fukuoka 810-0001

  i Cubed, Inc.

  Personal Information Inquiry Desk

  privacy@i3-systems.com

• Name of affiliated authorized personal information protection organization and contact information for resolving grievances

  Our Company is not affiliated with any authorized personal information protection organizations.

• Procedures for disclosure, etc. of retained personal data (*The same shall apply to disclosure procedures for “records related to provision to third parties” and “records when receiving provisions from third parties” created by our Company)

  1. Where to make a request for disclosure, etc.

     Please send the prescribed documents listed in the next item to our Company.

  2. Required forms and other procedures for requesting disclosure, etc.

     • Our Company’s designated Retained Personal Data Request Application Form (Please select between receiving the disclosure via email attachment or as a hard copy document.
       If no selection is made, we will provide a written response.)
     • One copy of a government-issued ID with a photo that can be used for identification purposes

  3. Method for verifying that the person making a disclosure request, etc., is an authorized representative

     If the person making a disclosure request is the legal representative of a minor or an adult ward, or an agent authorized by the individual to make the disclosure request, please enclose the verification documents prescribed by our Company or a power of attorney document in addition to the documents specified in the preceding paragraph.

  4. No fee will be charged for disclosure requests, etc.

1. Purposes for which we use personal information

   We use personal information for the purposes listed below.

   Regarding personal information acquired in connection with the CLOMO business

   Personal information items to be acquired	Purpose of use
   Personal information regarding devices (owner’s name, owner’s email address, phone number, latitude, longitude, location information acquisition date and time, outgoing phone number, incoming phone number, incoming and outgoing call date and time, etc.) Personal information regarding users (name, employee code, UPN, portrait photo, company address, company phone number, company extension number, company fax number, sub-email address, organization code, job title, etc.)	Initial setup, account management, and other operational support for CLOMO Troubleshooting and operating instructions for CLOMO
   Personal information related to the 24/365 service (name of reporter, contact information, etc.)	Provision of remote access services such as remote wipes

   *With regard to the CLOMO service, any user data entered or stored by the user on cloud servers such as Microsoft Azure through programs or services provided by our Company is considered data directly managed by the user on those cloud services, which are operated by third parties such as Microsoft Corporation. Our Company assumes no responsibility for overseeing such data.

   *In CLOMO service programs provided by our Company, if a user chooses to control apps from third parties such as Google LLC or Apple Inc., data such as operation logs and location information for those apps may automatically be transferred to those respective third-party providers.
   However, we will not incorporate such automatic forwarding programs into the CLOMO service unless instructed to do so by the user.

   Personal information acquired when responding to inquiries and conducting sales activities

   Personal information items to be acquired

   Purpose of use

   Name, company name, company address, affiliated department, email address, etc.

   Support for inquiries regarding requests for materials, trial version applications, etc. Solicitation activities via telephone or email regarding the use of various services provided by our Company or third parties affiliated with us Delivery of news emails about our Company and our services Contract renewal and other communications (to the client company’s representative) Sales support (for coordinators at our partner companies)

   (3) Personal information acquired upon hiring

   Personal information items to be acquired	Purpose of use
   Name, email address, phone number, address, gender, date of birth, education and work history, awards and disciplinary records, certifications held, presence and number of spouse and dependents	For consideration when hiring

   (4) Regarding personal information acquired in connection with outsourced operations

   Personal information items to be acquired	Purpose of use
   Name, email address, phone number, address, gender, date of birth, education and work history, awards and disciplinary records, certifications held, presence and number of spouse and dependents	Order processing Appropriate handling of tax matters, such as preparing payment records

   (5) Concerning personal information of employees

   Personal information items to be acquired	Purpose of use
   Name, email address, phone number	Business communications
   Name, address, date of birth, Individual Number, dependent information, etc.	Employment and personnel management, job assignments, creation of employee rosters, provision of employee benefits, withholding tax procedures, social insurance procedures, legally required procedures, and other employment administration tasks
   Savings account	Payment of salary, etc.
   Health-related information	Health-related information (for health management, ensuring suitable working conditions, managing leave of absence, determining work assignments, managing working hours, and other employment administration tasks)

2. Outsourcing of personal data

   We may delegate the handling of personal data to third parties for purposes that have been specified in advance. In such cases, we will ensure appropriate management and supervision of the delegated parties.

3. Information regarding retained personal data

   For details concerning the intended use and disclosure procedures for personal data retained by our Company (including third-party provision records), please refer to “Information regarding retained personal data.”