Orb Inc. (hereinafter referred to as the “Company”) utilizes platform software based on proprietary distributed ledger technology to provide “community currency solutions” to revitalize the community economy of regions and companies. In order to continue to provide services that satisfy our customers, to protect information assets in our highly information-oriented society from threats such as accidents, disasters, and crimes, and to live up to the trust of our customers and society, we will continue to adhere to the following personal information protection policy. In order to live up to the trust and expectations of customers, business partners, partner companies, employees, job seekers, and other related parties who use our services, we handle personal information based on the philosophy of respecting individuality . We will strive for careful and appropriate management.
1.personal information
“Personal information” is information about a living individual that can identify a specific individual by name, date of birth, or other descriptions contained in the information, as defined in the Personal Information Protection Act. Refers to “personal information” as defined in the following.
2．Regarding acquisition, use and provision of personal information
① Our company acquires the following personal information and uses it to the extent necessary to achieve each purpose of use.
■Information about business partners
・For contract procedures, customer management, provision of products and services, and related business operations.
・For the development and improvement of products and services and marketing activities.
・To provide information on events, products and services, and other information.
■Information regarding members/users of the unique currency platform (Orb-DLT) operated by the company
・For the provision, operation and improvement of the unique currency platform (Orb-DLT) service.
・For the development and improvement of products and services and marketing activities.
・To provide information on events, products and services, and other information.
■Information about event participants
・For event-related communications and other operational management purposes.
・For the development and improvement of products and services and marketing activities.
・To provide information on events, products and services, and other information.
■Information of those who inquired by phone, website, etc.
・To respond to inquiries, etc.
・For the development and improvement of products and services and marketing activities.
・To provide information on events, products and services, and other information.
■Information about shareholders
・Work related to shareholder exercise of rights and fulfillment of obligations based on laws, provision of information in IR activities, implementation of various measures, and other shareholder management.
■Information regarding job applicants
・For providing information and contacting job applicants.
・For selection of applicants for employment and other recruitment management purposes.
■Information regarding officers and employees (including those who have resigned or retired)
・For personnel management, wage management, labor management, social security and tax procedures, implementation of education and training, welfare benefits,health and safety management, business communications, and other tasks necessary for business operations.
personal information acquired before March 1, 2024 will be the purpose of use for consent was obtained at the time the personal information was acquired.
② If personal information is included in commissioned work, it will be used and managed within the scope stipulated in the contract, etc.
③ When outsourcing work involving personal information to an external party, we will require the same management as our company through contracts, etc.
④ Acquired personal information will not be provided to third parties unless we have the consent of the individual or as required by law.
3. joint use
Among the personal information acquired after March 1, 2024, our company will use the personal information listed in 1 below to the extent necessary to achieve the respective purpose of use, and share it with our group listed in 2 below. for joint use. Please note that specific personal information will not be shared.
① Items of personal information to be jointly used for contract work and the purpose of its use.
| Items of personal information to be jointly used | purpose of use | |
|---|---|---|
| Information about business partners | Name, email address, phone number, place of work, address of work, department/position, transaction status, cookie/device/advertising identification information, etc. In addition to the above, information related to thecontent of your inquiry. |
For business management and credit and other risk management of our group. For the development and improvement of products and services and marketing activities. To provide information on events, products and services, and other information. In addition to the above, for appropriate responses to inquiries. |
| job applicants | Name, address, date of birth, gender, emailaddress, telephone number, educational background, work history, qualifications, and other information submitted by job applicants. | For business management of our group. To provide information and contact job applicants regarding recruitment in our group. |
| Information regarding officers and employees (including those who have resigned or retired) | Name, email address, phone number, company/department, position, photo. | For business communications within our group. |
| In addition to the above, information held by our company. | For business management and personnel management of our group. | |
Our group (referring to Change Holdings Co., Ltd. and its domestic subsidiaries (https://www.changeholdings.co.jp/company/about/#group))
③ The name and address of the person responsible for the management of personal data and the name of its representative.
7th floor, JR Tokyu Meguro Building, 3-1-1 Kamiosaki, Shinagawa-ku, Tokyo 141-0021
Orb Inc.
Representative Director Masahiro Okabe
4．Compliance with laws, national guidelines, and other norms
When handling personal information, our company will comply with laws and regulations regarding the protection of personal information, guidelines established by the government, and other norms.
5．Regarding prevention and correction of leakage, loss or damage of personal information
Our company will take necessary and appropriate preventive and corrective measures to prevent or avoid the leakage, loss, or damage of personal information.
① We will take reasonable security measures for information systems and strive to protect personal information.
② In order to ensure the security of personal information held, we have established a personal information protection management system that complies with the Japanese Industrial Standards “Personal Information Protection Management System – Requirements” (JIS Q15001), and have established a personal information protection management system for all executives and employees. We will provide education to raise awareness of the importance and social significance of protecting personal information, and strive to ensure thorough implementation.
③ When outsourcing the processing of personal information, we will appropriately supervise the outsourcing company based on our internal regulations.
6. Disclosure of personal information
When we are requested by a person to disclose personal information, we will disclose this to the person without delay. However, if disclosure falls under any of the following, we may not disclose all or part of the information, and if we decide not to disclose it, we will notify you to that effect without delay.
・When there is a risk of harming the life, body, property, or other rights and interests of the person or a third party.
・When there is a risk of significant hindrance to the proper implementation of our business.
・In cases where it would violate other laws and regulations.
7. Correction and deletion of personal information
If the contents of the personal information held by the Company are not true, the person shall notify the Company of the personal information by contacting the contact information listed in “9. Complaints and consultations related to personal information.” You can request corrections, additions, or deletions (hereinafter referred to as “Corrections, etc.”).
If we receive a request from a person and determine that it is necessary to respond to the request, we will correct the personal information without delay.
If we make a correction, etc., or if we decide not to make a correction, etc., we will notify the person without delay.
8. Suspension of use of personal information, etc.
The Company will not accept complaints from individuals regarding their personal information because it is being handled beyond the scope of the purpose of use, because it is being used in a manner that is likely to encourage or induce illegal or unjust acts, or because it is being used in a manner that is likely to encourage or induce illegal or unjust acts. If we are requested to suspend or erase the use of such information (hereinafter referred to as “suspension of use, etc.”) because the information was acquired through other means , we will conduct the necessary investigation without delay.
Based on the investigation results, if it is determined that there is a reason for the request , we will suspend the use of the personal information without delay. If the Company suspends use, etc., or decides not to suspend use, etc., the Company will notify the person without delay. In cases where it is difficult to suspend use, etc., and if we can take alternative measures necessary to protect the rights and interests of the person, we may take such alternative measures.
9．Complaints and consultation regarding personal information
We have established a “Personal Information Consultation Desk” for complaints and consultations regarding personal information, and will respond promptly and in good faith. In addition, please contact the following contact point for inquiries regarding disclosure, correction, etc. related to personal information.
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■ Inquiries regarding personal information7th floor, JR Tokyu Meguro Building, 3-1-1 Kamiosaki, Shinagawa-ku, Tokyo 141-0021
Orb Inc. Personal Information Consultation Desk
TEL: 050-1780-1973 (Weekdays: 10:00-17:00, except 12:00-13:00)
E-mail：info@imagine-orb.com（24 Hours）
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10．Continuous Improvement of Personal Information Protection Management System
We strive to continuously improve our management system to ensure that appropriate protection of personal information is maintained.
March 1 , 2024
7th floor, JR Tokyu Meguro Building, 3-1-1 Kamiosaki, Shinagawa-ku, Tokyo 141-0021
Orb Inc.
Masahiro Okabe
Representative Director