Spectee Privacy Policy
Last updated: Apr 17, 2023
ARTICLE 1. DEFINITIONS
In this Privacy Policy, the following definitions apply:
Applicable Legislation: Applicable privacy legislation, including the General Data Protection Regulation (“GDPR”) and the relevant national implementation acts.
Contract: The Contract between a customer and Spectee concerning products, services, etc.
Personal Data: Personal Data concerns any information concerning an identified or identifiable natural person that is Processed by Spectee as described in article 3 of this Privacy Policy.
Data Subject: Natural person who is identified or identifiable with Personal Data who can exercise legal rights concerning personal data protection.
Process/Processing: An operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
Website:
https://spectee.com/
Spectee (or “we”/”us”):
Spectee Inc.
3F Goban-cho YS Building, Goban-cho, Chiyoda-ku, Tokyo 102-0076, Japan
ARTICLE 2. SCOPE PRIVACY POLICY
2.1
This Privacy Policy applies to every use of the Website by you and governs the Processing of Personal Data via the Website. Spectee is the Controller for this Processing.
2.2
The Website may include references of third parties (for example hyperlinks or banners). We do not control these references and are not responsible for compliance with the Applicable Legislation by these third parties. We recommend you to carefully read the privacy policies of the third party websites you are visiting.
ARTICLE 3. PERSONAL DATA COLLECTED
3.1
We may collect the following Personal Data from you:
a. name and address details;
b. company and department name you are working for;
c. telephone number of your home and office, personal mobile phone number;
d. e-mail address;
e. username and password;
f. online identifier including IP address and cookie;
g. employment information, resume.
3.2
Via our Website we do not collect sensitive Personal Data such as political view, religious belief, genetic data, etc.
3.3
Personal Data is collected by us:
a. when you apply for our service;
b. when you inquire on the Website;
c. when you apply for a job via the Website; or
d. otherwise when you use the Website.
3.4
We will only Process the Personal Data in accordance with Applicable Legislation as described in this Privacy Policy.
ARTICLE 4. PURPOSES AND LEGAL GROUND FOR PROCESSING
4.1
We collect and Process your Personal Data solely for the purposes specified below:
a. Account registration and communication
Your Personal Data may be used for account registration and to communicate with you about our products and services and to inform you of matters that are important for your account and/or use of the Website and the handling of any complaints. If you create an account on the Website, we will keep the Personal Data so that you do not have to enter it every time. This Processing of Personal Data is necessary for the performance of a Contract and/or for purposes of a legitimate interest pursued by us, namely to conducts its normal business.
b. Marketing
To approach you via e-mail for marketing purposes, we always request your prior consent. You always have the right and option to unsubscribe from mailings. This Processing of Personal Data is necessary for purposes of a legitimate interest pursued by us, namely to keep in touch with you and to offer you our products and services based on prior consent.
c. Customer service
If you use customer service, your Personal Data may be used to provide you with customer service. This Processing of your Personal Data is necessary for the Performance of a Contract, or is necessary for purposes of a legitimate interest pursued by us, namely to conduct its normal business.
e. Job applications
If you apply for a job via our Website, your Personal Data may be used by us to handle your job application. This Processing of your Personal Data is necessary for purposes of a legitimate interest pursued by us, namely to hire people to work for Spectee.
4.2
If we intend to further Process the Personal Data for a purpose other than that the Personal Data have been collected, we will provide you with information about that other purpose and all relevant further information before that further Processing.
ARTICLE 5. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
We may share the Personal Data with third parties to achieve the purposes stated in 4.1. The third parties include our group companies, cloud service vendors, other service providers, etc. When we share the Personal Data, we supervise those third parties to take appropriate measures to protect the security of Personal Data to comply with Applicable Legislation.
ARTICLE 6. SECURITY
6.1
We take appropriate organizational and technical security measures to protect your Personal Data and to prevent misuse, loss or alteration thereof. In addition, we limit access to Personal Data to those employees, agents, contractors and other third parties who have a need to have access. Also the aforementioned persons involved are bound by a confidentiality obligation, either in their employment agreements or other contracts.
6.2
We have established information security guidelines internally, including a data infringement policy in which it is described how to deal with a suspected Personal Data infringement. We will notify the relevant supervisory authority and the Data Subjects involved if required under Applicable Legislation.
ARTICLE 7. RETENTION PERIODS
7.1
We do not store your Personal Data any longer than strictly necessary for the purposes for which we collect the Personal Data.
7.2
You may request us to delete the Personal Data at any stage. If the Personal Data are no longer required for the purposes for which we collected or otherwise Processed the Personal Data, we will delete the Personal Data.
ARTICLE 8. COOKIES
8.1
We use cookies to ensure that the Website functions properly.
8.2
Cookies are information that are stored by the browser on your computer. Spectee uses different types of cookies for different purposes.
a. Functional cookies
Cookies that are necessary for the Website to function properly, including cookies that are necessary to create an account;
b. Analytical cookies
Cookies that ensure that insight can be gained into how you use (parts of) the Website, so that we can improve the Website and that it fits as well as possible with what you find interesting and important. We only use the data obtained with these cookies to study how the Website is being used.
8.3
We only use third party cookies to improve the quality and effectiveness of the Website. For example, it uses Facebook Pixel and/or Google Analytics, which are set up in a privacy-friendly manner. Facebook Pixel and/or Google Analytics Process the IP addresses for Spectee.
8.4
Most browsers are set to accept cookies by default. You can set the browser to disable cookies or indicate when a cookie is being sent. However, it is possible that some functions and services of both Spectee and other websites do not function properly if cookies are disabled.
ARTICLE 9. YOUR RIGHTS
9.1
In so far as the Personal Data Processing is based on consent, you have the right to withdraw consent at any time.
9.2
You have the right to request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold.
9.3
You have the right to request correction of the Personal Data that we hold. This enables you to have any incomplete or inaccurate data we hold corrected.
9.4
You have the right to request deletion of your Personal Data. This enables you to ask us to delete Personal Data where there is no good reason for us continuing to Process it.
9.5
You have the right to object to Processing of your Personal Data where we are relying on a legitimate interest. Insofar as the Processing of your Personal Data takes place for direct marketing purposes, we will always honor your request. For Processing for other purposes, we will also cease and desist Processing, unless we have compelling legitimate grounds for the Processing which override your interests, rights and freedoms or that are related to the institution, exercise or substantiation of a legal claim.
9.6
You have the right to request restriction of Processing of your Personal Data.
9.7
You have the right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format.
9.8
The exercise of the abovementioned rights is free of charge. We will provide you with information about the follow-up to the request immediately and in any case within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months. We will notify you of such an extension within one month of receipt of the request.
9.9
If your requests are manifestly unfounded or excessive, in particular because of the repetitive character, we will either charge you a reasonable fee or refuse to comply with the request.
ARTICLE 10. CONTINUOUS IMPROVEMENT
In order to maintain appropriate personal data protection, Spectee will establish a personal data protection management system, conduct regular audits of its operating status, and strive for continuous improvement.
ARTICLE 11. CONTACT DETAILS
For any questions, complaints or in the event that you wish to make use of one of the rights mentioned in Article 9 of this Privacy Policy, you may contact us at the contact details below:
Spectee Inc., DPO (Data Protection Officer)
3F Goban-cho YS Building, Goban-cho, Chiyoda-ku, Tokyo 102-0076 Japan
Telephone Number: +81 (0)3-6261-3655
ARTICLE 12. MISCELLANEOUS
12.1
We reserve the right to change this Privacy Policy on a regular basis. It is your responsibility to regularly review the applicable conditions. This Privacy Policy is last amended and revised in Apr 2023.
12.2
If a provision from this Privacy Policy is in conflict with the law, it will be replaced by a provision of the same purport that reflects the original intention of the provision, all this to the extent legally permissible. In that case, the remaining provisions remain applicable unchanged.
