adish International (hereinafter the “Company”) may obtain and collect personal information (hereinafter “Personal Data”) for the purpose of conducting various marketing and sales activities directed toward customers and those people with whom we have had communication in our various businesses and services provided in the EU zone. We hereby declare that, when using Personal Data obtained or collected under such circumstances, we will comply with applicable GDPR regulations (hereinafter “Applicable Privacy Laws”) and will manage Personal Data in a strict manner with utmost care.

Personal Data to be Obtained, Collected, and Used

Target Individuals

Individuals who are subject to having their Personal Data being obtained, collected and used by the Company shall be the companies or the employees or directors of the companies (employees and directors of such corporate clients are hereinafter collectively called “you”) who have contacted us through the website forms of the Company, have made enquiries to the Company through mail, telephone or letter, or have exchanged name cards at the time of sales activities and exhibitions, etc.

Types of Target Personal Data

Types of Personal Data to be obtained, collected, and used by the Company shall be as follows:

• Name
• Name of company to which the individual belongs
• Mail address (mail address concerned is that of the company to which the individual belongs
• Phone number (phone number concerned is that of the employer)
• Address (address concerned is that of the company to which the individual belongs)
• Occupation
• Contents of consultations or inquiries
• IP address

Processing Purposes and Legal Basis of Personal Data

The Company may obtain, collect, and use your Personal Data for the following purposes:

Marketing and sales activities

The Company may obtain, collect and use your Personal Data for the purpose of communicating information regarding our various businesses and services provided (including new services to be provided in the future, hereinafter the same shall apply). For those who have contacted us using the website forms of the Company, we have obtained their agreement on a legal basis. However, the above-mentioned use of personal data may be terminated by either going through a deregistration procedure or by contacting us. However, if you have entered into a contract with us, it shall be done according to the contract.

For those who have exchanged business cards with us at exhibitions or sales activities, we may contact through newsletters, email, telephone, or letter, or you may go through a deregistration procedure or contact us to terminate the use of personal information.

Service provision

The Company may obtain, collect, and use your Personal Data for the purpose of providing services operated by our various businesses.

For those who use our services, it shall be done based on a contract.

Others

Although the Company may need to process your Personal Data for purposes other than those mentioned above, you may terminate such usage by going through a deregistration procedure or by contacting us.

Categories of Third-Party Recipients

The Company may provide third parties with your Personal Data when conducting marketing and sales activities related to various businesses of the Company, or for communication and provision of services in the following cases:

1. When using a third party’s ASP service as a means of contact
2. When the business of the Company is succeeded due to a merger or other reasons

Sharing of Personal Data

We will share your Personal Data within our group companies (including those new group companies established in the future).

Transfer of Data to a Third Country Outside the EU Zone

Based on applicable laws, we will not transfer your Personal Data to any third-party country (outside of the country or the region in which we obtained the data) without obtaining your explicit consent. An exception may occur when the same level of protection is secured in the third-party country as in the country or region from which the data was originally obtained.

Unless explicit consent is specifically obtained from you, or unless it is guaranteed that the country/region where your personal data will be transferred to will have the same level of protection as in the country/region where the data is obtained by the Company, in accordance with applicable laws, the Company will not transfer personal data outside of the country/region where it is obtained.

The Company may use servers provided by overseas companies when conducting marketing and sales activities of our various businesses, or for communication and provision of services.

Management of Information

We acknowledge your Personal Data is important information in need of protection, and we are committed to respecting your privacy. When we obtain and collect your Personal Data, we manage it in a strict manner. We are taking and will continue to take, sufficient preventive measures to protect Personal Data from unauthorized access, alterations, leaks, loss, and corruption.

In the unlikely event that such cases occur, we will address them swiftly in order to mitigate the problem and minimize disturbances to you.

Security

We take countermeasures against unauthorized access to our network.

In order to make it impossible to access the administrative servers from outside of our network

1. Access measures through IP address restriction
2. Permission of access granted only to administrators of our network, authorized staff, employees, and directors
3. Data encryption and access control on the accessibility of the database, etc.

Such measures against unauthorized access are being taken, every effort would be made to address new threats in the future.

When transferring specific Personal Data, the Company takes the following measures for prevention of information leakage in order to ensure the safety and maintain the accuracy of your Personal Data:

1. Sharing of information via storage can be accessed only from our internal network
2. Sharing of information with password protection when sending by email
3. Encryption of communication paths

Authority to access Personal Data will be given only to the employees, directors, agents or subcontractors of the Company who need to have access to the data. These parties are subject to confidentiality obligations based on employment contracts, subcontract agreements, or contracts on the processing of personal data.

In order to respond to infringements of Personal Data when they occur, we have established rules, including how to respond to such cases, in the “Personal Information Protection Regulations” inside the Company.

When it is found necessary, based on applicable laws, we will notify the relevant competent authorities and/or the owners of the Personal Data.

Retention Period of Personal Data

We retain and manage the Personal Data obtained and collected from you for the required period of time, in accordance with the purposes mentioned above. It is the policy of the Company to check the Personal Data against the above-mentioned purposes, when it is no longer unnecessary, delete it promptly.

Should you wish to delete your Personal Data that is retained and managed by us, you may request deletion by contacting us. However, we will first confirm your identity in order to prevent the leaking of information to third parties. We will delete the data promptly upon confirmation of your identity.

Cookies

A cookie is the function of enabling you to save the trouble of reentry of data, allowing the websites to display contents most suitable for you by storing your information in the browsers. The Company uses this technology on our website to keep track of the number of users, omit reentering, displaying the most suitable Internet advertisements, etc.

Cookies Used on the Website of the Company.

Strictly Necessary Cookies	Cookies are necessary for the correct operation and usage of the website of the Company. These cookies are used to recognize login information, etc.
Performance Cookies	These cookies collect information on the usage of our website. They do not collect information that identifies the users.
Functionality Cookies	These cookies record optional items (user name, language, area from which the website is accessed, etc.) on our website.
Targeting / Advertising Cookies	These cookies provide information on visits to our website to advertising companies to enable them to provide the most appropriate advertisements to those who are interested in our website.

We use access analysis services provided by third parties such as Google Analytics, which have settings that consider privacy. We use cookies to collect traffic data, which does not identify Personal Data.

You may choose whether or not to receive cookies by setting your browser to notify you when cookies are being sent. You may also set your browser to disable the functions of cookies. Please refer to the explanation website of each cookie for the method to disable the cookie function. Some functions provided by the website of the Company may be disrupted when you disable the use of cookies.

Rights on Personal Data

You have the following rights related to your Personal Data:

• Right to withdraw consent related to your Personal Data and to ask for the deletion of the data
• Right to confirm the contents (copies) of your Personal Data
• Right to ask for correction of the contents of your Personal Data
• Right to ask for restriction of the processing of your Personal Data
• Right to make an objection to the processing of your Personal Data when such processing is conducted out of necessity for public benefits, etc. or for legitimate interests sought by the Company or third parties.

When we process Personal Data for direct marketing, you may file a claim against us for the cessation of such processing.

When we process Personal Data for any other purposes, and such processing should be ceased in light of applicable laws, we will cease the processing of the Personal Data.

• Right to request the transfer of your Personal Data to yourself or to a third party, If the Company has obtained your Personal Data with your consent, we can provide such data to third parties designated by you upon your request, in a structured, generally available and machine-readable format.

In addition, you have the right to file a complaint or express discontent to competent authorities (particularly, competent authorities in your place of domicile, business, or EU countries where Applicable Privacy Laws have been breached) at any time.

Other Matters Requiring Your Attention

Our websites are as follows:

• https://www.adish.co.jp/
• https://socialappsupport.com/
• https://monitor.adish.co.jp/
• https://school-guardian.jp/
• https://frontsupport.jp/
• https://hitobo.io/

Please note that when we cannot obtain your Personal Data, we may not conduct marketing and sales activities related to our various businesses or may not communicate with you, or provide you with the services mentioned above.

We make no decisions based only on auto-processing (including profiling) following the processing of Personal Data obtained and collected by us.

Contact Information

Please use the following contact details should you have any inquiries regarding your Personal Data, or if you wish to exercise your rights over your Personal Data, or any other issues for which you have doubt:

adish International
12F Jaka Bldg., 6780 Ayala Avenue, Makati City, Philippines.
E-mail: connect@adish.co.jp