Privacy Policy

SIMPLEX QUANTUM, Inc. (the “Company”) declares that, for personal information of its clients, business partners or others concerned used by the Company for business purposes, the Company hereby establishes this Privacy Policy on the terms as follows (this “Privacy Policy”) to set forth voluntary rules and systems in compliance with laws, regulations and other rules on the protection of personal information and also in light of international trends, and that it will implement and maintain this Privacy Policy to contribute to the protection of the rights of the public.

The Company shall cause its officers, employees and others concerned to be fully aware of the importance of personal information, and continuously educate, supervise and review such persons.
In principle, the Company shall obtain consent from the principal of personal information before obtaining the principal’s personal information.
The Company shall not obtain personal information in any improper manner.
The Company shall clearly define the purpose of use to the extent necessary for the performance of business operations, and shall properly acquire, use and provide personal information. The Company shall take measures to ensure that any personal information acquired by the Company is used by persons in charge only to the extent necessary in the course of business and is not used for unintended purposes.
The Company shall keep personal information accurate and updated, and strive to prevent or correct any loss, destruction, falsification, leakage, etc. of personal information.
The Company shall faithfully and promptly respond to inquiries, complaints, and disclosure or other requests concerning personal information from clients.
The Company shall handle personal information within the scope of the purpose of use clearly presented to its clients. The Company shall not disclose or provide to third parties any personal information provided by its clients unless the clients have agreed to the disclosure or provision or there is a justifiable reason.
The Company shall comply with the Act on the Protection of Personal Information as well as other related laws and regulations, guidelines stipulated by the nation, and other rules.
The Company shall establish, steadily implement, maintain, and strive to continuously improve its Personal Information Protection Management System (the “PMS”).
The Company shall not divulge the content of consultation, request, etc. to anyone other than the person having made the consultation, request, etc.
In principle, the Company shall contact persons having made consultation, request, etc. only at the designated contact address.
The Company shall be responsible for the storage, management and destruction of books and records received from persons having made consultation, request, etc.

Revision of this Privacy Policy

To ensure proper protection of various information or to respond to amendments to or other changes in laws, regulations or other rules, the Company shall from time to time review the practice of handling various information and may revise this Privacy Policy without notice, as appropriate.
The Company shall notify a revision of this Policy to its clients by publishing the revised version on the Company’s corporate Website, and shall handle various information (including one acquired prior to the revision) in accordance with the revised Privacy Policy to the extent permissible under laws and regulations. Except as otherwise prescribed by the Company on its corporate Website, a revision of this Privacy Policy shall take effect at the time when the revised version is published on the corporate Website.

Inquiries about personal information

For inquiries about clients’ own personal information or about this Privacy Policy in general, please contact the Company at the Consultation Service Desk.

Consultation Service Desk
Personal Information Protection Manager
Tel: 03-6450-3600
Mail: pmark@simplex-q.com

Establishment: July 29, 2020
SIMPLEX QUANTUM, Inc.
Shibuya CH Building 3F,
29-12, Sakuragaoka-cho, Shibuya-ku, Tokyo 150-0031
Ryu Saito, Chief Executive Officer

Handling of Personal Information

Overview of the services offered

Development of wearable devices, development of related software, and development of algorithms;
Development and manufacture of devices, equipment and modules using next-generation circuit technology;
Development and manufacture of wearable terminals and smart technology devices;
Planning of a big data center, and establishment and operation of business models;
Planning, development and operation of mobile technologies; and
Planning, development and operation of services relating to artificial intelligence.

Personal information to be acquired, and method for acquiring personal information

Described below are the types of personal information to be acquired by the Company (in Section A below) and the method for acquiring such information (in Section B below).
Clients have the discretion to decide whether to provide their personal information to the Company; provided, however, that a client who decides not to provide personal information may not be able to enjoy the performance of operations and the provision of services as requested by the client.

Personal information to be acquired
1. Customer information (such as company name, department name, personal name, address, telephone number, e-mail address, age, gender, customer biometric data, and location information at the time of measurement);
2. Information on job applicants (such as name, age, address, telephone number, education history, and career history);
3. Information on employees (such as name, age, address, telephone number, career history, and family structure);
4. ID numbers of employees and others concerned; and
5. Images recorded by security cameras.
Method for acquisition
1. Acquire directly from the principal in writing / Acquire by means of Web forms / Acquire through use of services;
2. Acquire directly from the principal in writing;
3. Acquire directly from the principal in writing / Acquire by means of Web forms;
4. Acquire directly from the principal or his/her agent / Acquire by means of Web forms;
5. Acquire through security camera recordings.

Purposes of use of personal information

In accordance with Article 18 of the Act on the Protection of Personal Information and JIS Q 15001:201, the Company hereby discloses to the public that it uses personal information for the purposes of use listed below.
If it becomes necessary for the Company to use personal information of its clients or others concerned beyond the scope of the purposes of use clearly indicated or disclosed to the public in advance, the Company shall notify thereof to its clients or others concerned and obtain their consent before using their personal information.
The Company uses special care-required personal information in the course of the performance of its Doctor Support Service or other services that assume the use of special care-required personal information.

(Customer information (information on registrars with and users of the Company’s services using electrocardiac information))

Operation and provision of the Company’s services (the Company’s services using electrocardiac information):
1. To confirm whether the registrar has been truly registered as a member of the membership services;
2. To make it possible for users to view, change or delete their registration information, and view and update the status of their use;
3. To identify a person violating an agreement with the Company or the Terms of Use, and to suspend or discontinue use of services by any such person;
4. To charge use fees to users;
5. To provide medical doctors’ advice and support for users as part of the services offered by the Company; and
6. To aggregate, analyze or otherwise look into the attributes of personal information, and prepare statistical materials for the improvement of the quality and functions of marketing and services, and for the development and research of new services.
Response to inquiries and consultations about products, and manufacturing and delivery of products in the course of business operations
Contact to users in the course of business operations:
1. To send information on new features, updates, campaigns, etc. in relation to the services offered by the Company or services offered by a third party designated by the Company; and
2. To contact in relation to the services and products offered by the Company; and
3. To offer the Company’s services, advertisements or other offerings tailored to the users’ age, gender, occupation or other profiles.

(Resumes and career history information of job applicants)

Receipt of applications for employment screening;
Employment screening;
Contact or other clerical procedures in relation to employment screening; and
Unofficial employment notice, health checkups at the time of employment, and guidance on the steps to be taken when joining the Company.

(Employee information)

Personnel and labor management (such as personnel evaluation, staffing (including secondment and transfer), training, and recruitment);
Wage management (such as determination of salaries and lump-sum payments, and payment of retirement benefits);
Health management (such as medical checkups and health guidance);
Welfare services (such as asset building savings and offer of discounts on the Company’s products);
Security control (such as crime prevention, disaster prevention, and occupational health and safety); and
Management of business affairs (such as communications for business purposes, preparation of various reports, and posting on groupware).

(Employee ID numbers)

Use to acquire/confirm qualifications for pension, and to receive pensions;
Use to acquire/confirm qualifications for employment insurance or other benefits and to receive such benefits, and use at public employment security offices or for other clerical or other procedures;
Use by medical insurers for procedures such as the collection of medical or other insurance premiums, and use for the payment of welfare-related benefits, implementation of or other procedures for public assistance, and clerical or other procedures for low-income individuals;
Use to prepare tax returns, notifications, statements, or other documents to be submitted by citizens to tax authorities, and use for internal or other clerical procedures by authorities; and
Further to the above use, use for clerical procedures relating to social security, local taxes, disaster prevention and other similar matters that are stipulated by local governments in municipal ordinances.

(Images recorded by security cameras)

Security control (crime prevention, disaster prevention)

Efforts and measures for secure management

The Company takes the following measures for secure management of personal information:

(Establishment of basic policies)

To ensure that personal information is handled properly, the Company establishes its basic policies concerning “compliance with related laws, regulations and rules,” “contact for disclosure or other requests, complaints or consultations,” and other related issues.

(Establishment of rules concerning handling of personal information)

For each business handling personal information and for each lifecycle stage of personal information, analyze risks in each stage (acquisition, use, transfer/delivery, storage, retention, and deletion/disposal) and establish measures to manage potential risks;
Establish rules for the handling of and security measures for personal information with the view to properly handling and protecting personal information.

(Organizational security measures)

Define the roles and responsibilities in the handling of personal information and establish a system for the protection of personal information; and
Regularly conduct self-inspections and internal audits on the status of the handling of personal information.

(Human security measures)

Enter into a confidentiality agreement for non-disclosure of personal information at the time of the execution of an employment agreement, and enter into a confidentiality agreement at the time of the execution of a service agreement; and
Provide regular training and education for employees on the matters to be noted in, and their respective roles and responsibilities for, the handling of personal information.

(Physical security measures)

Define the physical security boundaries and security level within which personal information is handled, and conduct access control according to the security level; and
Store under lock, and restrict access to, media containing personal information to protect them from theft and loss.

(Technical security measures)

Provide access control to prevent unauthorized access to and alteration of networks, electronic systems, and personal information; and
Introduce a mechanism to protect electric systems from malicious software.

Provision of personal information to third parties

The Company does not disclose personal information of any client to third parties unless:

The client has agreed to the disclosure;
The disclosure is in accordance with laws or regulations;
The disclosure is necessary to protect human life, body or property, and it is difficult to obtain consent from the client;
The joint use and handling of personal information is outsourced to the extent necessary for achieving the purpose of use; or
The Company’s businesses are succeeded due to a merger, company split, business transfer or other similar reasons.

Outsourcing of operations involving personal information, and handling of personal information

To the extent necessary for achieving the purpose of use, the Company outsources the following items of the Company’s services (the Company’s services using electrocardiac information) to a third party:
In the case of outsourcing, the Company selects a service provider that has an adequate level of personal information protection, stipulates the level of protection in a contract or other documents, and guides and supervises the service provider to ensure the proper handling of personal information.

Analysis of electrocardiac data; and
Provision of medical doctors’ advice via chat.

Procedures for disclosure, revision, etc. of personal information

The Company accepts the following requests concerning personal information to be disclosed (within the scope of use for “Purposes of use of personal information”). For inquiries about any of these requests, please contact the Consultation Service Desk.

Request for notice of the purpose of use;
Request for disclosure;
Request for rectification of the content;
Request for addition or erasure;
Request for suspension of use or deletion;
Request for suspension of provision to third parties; and
Request for disclosure of records provided to third parties.

Request to:

Shibuya CH Building 3F,
29-12, Sakuragaoka-cho, Shibuya-ku, Tokyo 150-0031
SIMPLEX QUANTUM, Inc.
Consultation Service Desk
Personal Information Protection Manager
Tel: +81-3-6450-3600
Mail: pmark@simplex-q.com
Method for requesting disclosure, etc.

The Company does not prescribe any particular method for requesting disclosure, etc. Please state the information listed in i. to iv. below in a written document of any form, and send the document along with an identity verification document set forth in “(iii) Method for identity verification of the principal or his/her agent” below to the address set forth in “(i) Request to” above by Letter Pack (a package delivery service offered by Japan Post) or other trackable means. If a client causes his/her agent to make a request, please enclose a power of attorney of any form, as stated in “(iii) Method for identity verification of the principal or his/her agent” below. The Company charges fees only when it discloses personal information or notifies of the purpose of use. In such case, please also enclose a postal money order in accordance with “(iv) Method for collecting fees” below.
1. Information of a person making request
  - Date of entry
  - Name, pronunciation (in the case of a request by an agent, the agent’s name)
  - Relation with the principal (clarify whether the request is made by the principal or its agent)
  - Telephone number (telephone number that can be reached between 10:00 and 17:00 on weekdays
  - E-mail address (to be used when the Company cannot speak to the person during the above hours)
  - In the case of a request by an agent, the agent’s identity verification document to be enclosed (one of the items listed in (iii) below)
2. Matters concerning the principal (who is to be subject to the disclosure, etc.)
  - Name, pronunciation
  - Postal code, address
  - Telephone number
  - Title of the identity verification document to be enclosed (one of the items listed in (iii) below)
3. Nature and details of the request
  
  Please state the nature of the request (one of 1) to 7) above) and the following details of the request as appropriate:
  
  (In the case of a request for disclosure)
  The name of the service where the personal information subject to the disclosure request is registered or provided, items of the personal information (such as name, address, telephone number, and e-mail address), whether the information is disclosed to a third party, and records of such disclosure.
  
  (In the case of a request for rectification of the content)
  The name of the service where the personal information subject to the rectification request is registered or provided, items of the personal information, information before rectification, and information after rectification.
  
  (In the case of a request for addition or erasure)
  The name of the service where the personal information subject to the addition or erasure request is registered or provided, items of the personal information, and content of the personal information.
  
  (In the case of a request for suspension of use, deletion, and suspension of provision to third parties)
  The specific name of the service where the personal information subject to the request for suspension of use, deletion, and suspension of provision to third parties, details of the use, and other related information
4. Method for disclosing the requested content
  
  As to the method for disclosing the requested content, please choose and describe either of the following two options. If you fail to designate, the Company takes the method in a. below. If you choose the option in b. below and if the disclosure in such method requires considerable expense or is difficult, the Company takes the method in a. below.
  1. No designation (the method prescribed by the Company)
    
    The Company will respond by sending a written document to the address stated in the “identity verification document” of the person having made the request.
  2. Provision of electromagnetic records
    
    In light of the desire presented at the time of the request, the Company will respond in a manner agreed in advance with the person having made the request.
Method for identity verification of the principal or his/her agent

For the Company to confirm that the person having made the disclosure or other request is the principal or his/her agent, please submit any one of the following documents:
- Copy of the driver's license (including the reverse side if the address has changed);
- Copy of the health insurance card;
- Copy of the passport; or
- Copy of the certificate of alien registration.
The following persons shall be allowed to make a disclosure or other request, etc.:
1. A statutory agent of a minor or an adult ward
2. An agent assigned by the principal to make a disclosure or other request, etc.
In the case of a request by the person in b. above, please submit a power of attorney stating the following information, and a seal registration certificate of the principal (assigner).
- Date of the assignment, addressee (the Company’s name);
- Statement that the principal (assigner) designates the person stated in the power of attorney as his/her agent, and delegates the authorities over the disclosure or other request concerning the principal’s (assigner’s) personal information (specifying the nature of the request (one of 1) to 7) above);
- The agent’s name, address, telephone number, and relationship with the assigner; and
- The principal’s (assigner’s) name, address, telephone number, registered seal affixed next to the name (enclose a certificate of the registered seal (original issued within three (3) months)).
Method for collecting fees

If the Company collects fees for responding to a disclosure request or notifying the purpose of use upon a request, the Company designates the amount of and the method for collecting the fees to the extent that are considered to be reasonable in light of the actual cost for the disclosure or notification:
Fee: JPY 3,300 (including tax)
Method for collection: When mailing your request in writing to the Company, please enclose the fees by a postal money order. The Company responds to the request after confirming the receipt of the fees.
Purpose of use of personal information acquired in relation to a disclosure or other request

The Company handles any personal information acquired in relation to a disclosure or other request to the extent necessary to respond to the disclosure or other request. When the Company completes its response to a disclosure or other request, the Company shall properly manage or destroy such personal information.
Reasons for non-disclosure, etc.

In the following cases, the Company is unable to respond to a disclosure or other request. If the Company determines non-disclosure, etc., it notifies of the reason for such determination. The Company collects prescribed fees even in the case of non-disclosure or non-notification of the purpose of use.
- If the Company is unable to verify the identity;
- If the Company is unable to verify the right of representation in the case of a request by an agent;
- If any statement in the submitted documents is incomplete, or the Company is unable to identify the personal information held by it due to such incomplete statement;
- If the subject of the disclosure or other request does not constitute personal data that is held by the Company and can be disclosed;
- If it is likely to damage human life, body, property, or other rights or interests of the principal or any third party;
- If it is likely to significantly hinder the proper conduct of the Company’s business;
- If is to violate other laws or regulations.

Exemption

The Company shall be exempted from liability and assume no legal liability for any trouble caused by the acquisition of personal information by a third party in any of the following cases:

If a user discloses its personal information to another user by using any function or other means that are available as part of the services of the Company or a service provider of the Company;
If the identity of a user is verified based on the information input on the Company’s service Website by any user other than the user who is the principal;
If the identity of a user is verified due to the user having used any advertising Website accessible as part of the Company’s services; or
In the case of any other accident, such as leakage, that occurs even in the absence of negligence by the Company.