Personal Information Protection Policy
Enjin Inc. (“ENJIN”) has established this Policy and a personal information management system based on its Code of Ethics, through which ENJIN, as a company, is committed to realizing the responsible treatment of personal information.
- ENJIN will, to the extent possible, specify the purposes of use of the personal information, and will properly handle the personal information within the scope necessary to achieve such purposes. ENJIN will take measures to ensure the prevention of any use of the personal information other than for the intended purposes of use.
- ENJIN will obtain personal information only through legitimate and appropriate means.
- ENJIN will not provide any third party with the personal information of any individual without the consent of such individual.
- In managing personal information, ENJIN will make efforts to take all necessary and appropriate measures to ensure the prevention and correction of any leakage, loss or damage of the personal information, as well as the otherwise secure management of the personal information.
- In handling personal information, ENJIN will make efforts to ensure that the individual who has provided the information may properly be involved in the handling process, and make efforts to keep the personal information accurate and updated to the extent possible.
- ENJIN will comply with laws and regulations pertaining to the protection of personal information, and establish, continuously review and comply with its internal rules pertaining to the protection of personal information.
- ENJIN will have a section for responding to complaints and consultations concerning the protection of personal information and make efforts to properly respond to such complaints and consultations.
Regarding the handling of personal information
Personal information means information concerning a User as an individual, which can identify the User based on the name, address, telephone number, e-mail address, educational institution, or other descriptions, etc. constituting such information. In addition, any information which cannot identify the User solely by itself but can easily be cross-referenced with other information and, as a result thereof, can identify the User, is also included in the scope of personal information.
Purpose of use of personal information
ENJIN shall use personal information only for the following purposes, and shall not use any personal information beyond these purposes of use:
(The purposes of use of personal information that is directly obtained, other than by way of writing)
Performance of entrusted services such as call center services;
Communication based on publicized information such as those in publications or on the Internet, etc.;
(The purposes of use of personal information that is subject to disclosure)
Response to comments and inquiries received concerning services; and
Distribution of notices and announcements relating to recruitment and hiring.
Voluntary nature of provision of personal information
ENJIN requires Users to provide personal information that is necessary to accomplish the purpose of use. Although it is not necessary to answer all of the items, if a User fails to answer certain question(s), such User may not be able to use the Services.
Provision of personal information to third parties
ENJIN, as a general rule, does not provide any third party with any User’s personal information without the consent of such User. ENJIN provides third parties with personal information only if it has obtained the User’s consent thereto, specifying the party to whom the information is to be disclosed and the content of the information to be disclosed. However, ENJIN may provide personal information without the User’s consent within the scope not conflicting with related laws and regulations, where any of the following applies:
- ENJIN considers that the User will cause disadvantage to a third party;
- Providing such personal information is specifically necessary for the improvement of public health or the sound growth of children, and obtaining approval therefor from the User is difficult;
- It is necessary to cooperate with a governmental organization or a local government, or a person designated by the same in the performance of administrative work prescribed by laws or regulations, and obtaining the consent of the User thereto will likely hinder the performance of such administrative work;
- The disclosure of the personal information is required by a court, public prosecutor’s office, police or any other organization having similar authority;
- The User has expressly requested that his/her personal information be disclosed or provided to third parties;
- It is permitted by law or regulations to disclose or provide the personal information; or
- The personal information is provided in connection with a business succession due to merger or otherwise, to the extent that the personal information is handled within the scope of the purposes of use applicable prior to such succession.
Outsourcing of personal information processing
ENJIN may outsource personal information handling work in part or in whole. ENJIN shall be responsible for the handling of personal information by the party to which such work is outsourced.
Use of statistically-processed data
ENJIN may, based on personal information provided to it, create statistical data which shall be processed in a manner that cannot identify any individual. ENJIN may, without restriction, use such statistical data that cannot indentify individuals.
Modifications, etc. to personal information
As a general rule, only the User himself/herself can request notification regarding the “purposes of use of the personal information,” or any disclosure or correction of, addition to, or deletion or suspension of his/her registered personal information, or the provision thereof to third parties (“Modification, etc., of Personal Information”). For specific methods, please refer to the following contact person in charge of personal information management. However, ENJIN shall not agree to comply with a request for the Modification, etc., of Personal Information where any of the following applies:
- The Modification, etc., of Personal Information is likely to cause damage to the life, limb, property or other rights or interests of the User or any third party;
- The Modification, etc., of Personal Information is likely to considerably hinder the proper performance of the Services; or
- The Modification, etc., of Personal Information would constitute a violation of any other laws or regulations.
Furthermore, ENJIN shall not agree to comply with a request for the Modification, etc., of Personal Information if such Modification, etc., of Personal Information would require excessive cost, or if the performance of such Modification, etc., of Personal Information is otherwise difficult, and instead ENJIN ensures that necessary alternative measures shall be taken to protect the rights and interests of the User.
However, with respect to the original documentation, such as a postcard, that has been used for the acquisition of personal information, ENJIN disposes of such documentation after retaining the same for a certain period of time, and therefore, any request for the Modification, etc., of Personal Information with respect to the original documentation itself shall not be accommodated.
Restrictions on acquisition of sensitive personal information
ENJIN, as a general rule, shall not obtain any User’s personal information which contains any of the following information, unless the personal information has been provided by the User himself/herself:
- Information relating to personal philosophy, belief or religion;
- Information relating to race, ethnic background, family background, domicile (except for information on the prefecture where the User is located), physical or mental disability or criminal record or other matters that may cause social discrimination;
- Information relating to the right to organize, or any acts of collective bargaining or other collective actions as a worker;
- Information relating to participation in acts of mass demonstration, exercising of petition rights or other political rights; or
- Information relating to health and medical conditions or sex life.
In the event of a membership registration for each web service, or the use of the Services by a member, or ENJIN’s response to a User’s request for the disclosure, correction, deletion, or suspension of use of such User’s personal information, etc, ENJIN shall verify the relevant individual’s identity based on information that can identify such individual (i.e., name, address, telephone number, date of birth, e-mail address, member ID number, password, etc.). However, ENJIN shall not be responsible in the event of any third party obtaining and using information that can identify the relevant individual.
Person responsible for the management of personal information
Enjin Inc. Development department
Established and implemented on 3rd March, 2020