Privacy Policy

ACCEL LAB Ltd. Personal Information Protection Policy

ACCEL LAB Ltd. (the “Company”) recognizes that appropriately protecting personal information is an important social responsibility in conducting its business activities involving IoT devices for smart homes, application-related cloud services, and other related businesses.

The Company complies with the Act on the Protection of Personal Information and other applicable laws and regulations, guidelines established by the government, and other standards, and endeavors to appropriately handle and protect personal information in accordance with the following policy.

1. Compliance with Laws and Regulations

The Company complies with the Act on the Protection of Personal Information, JIS Q 15001, and other applicable laws, regulations, and guidelines, and appropriately handles personal information.

2. Appropriate Acquisition, Use, and Provision of Personal Information

The Company acquires personal information by lawful and fair means, specifies the purposes of use as clearly as possible, and uses personal information only to the extent necessary to achieve those purposes. Except where permitted by laws and regulations, the Company will not provide personal information to any third party or use it for any other purpose without the consent of the individual concerned.

The Company does not use the various types of personal information of customers and other individuals beyond the scope necessary to achieve the stated purposes of use and takes measures to prevent such use.

3. Security Control Measures

The Company takes security control measures to prevent unauthorized access to, leakage, loss, or damage of personal information and to otherwise ensure the secure management of personal information. If unauthorized access, leakage, loss, or damage occurs, the Company gives top priority to preventing the spread of harm, promptly takes corrective action, investigates the cause, and endeavors to prevent recurrence.

4. Supervision of Contractors

When outsourcing the handling of personal information, the Company selects an appropriate contractor and exercises necessary and appropriate supervision over that contractor.

5. Handling of Complaints and Consultations

The Company responds appropriately and promptly to complaints and consultations regarding the handling of personal information.

6. Continuous Improvement

The Company continuously reviews and improves its management framework and initiatives for personal information protection.

Inquiries Regarding the Personal Information Protection Policy

For inquiries regarding the contents of the Company’s Personal Information Protection Policy, please contact:

1. Appropriate Acquisition, Use, Provision, and Outsourcing of Personal Information

1.1 Acquisition of Personal Information

When acquiring personal information, the Company clearly indicates the purpose of use, lawfully and fairly acquires only the information necessary for that purpose, and notifies the individual concerned of, or publicly announces, the purpose of use.

1.2 Purposes of Use

The Company uses the various types of personal information of customers and other individuals within the scope of the purposes listed below and will not use such information for any other purpose unless the individual concerned has given consent or such use is permitted by laws and regulations.

Customer Information

• Identity verification and prevention of unauthorized use
• User registration and authentication
• Maintenance, provision, protection, and improvement of services and other offerings
• Communications as necessary, including important notices regarding services and other offerings
• Verification of service usage history with business partners
• Information about the Company’s products, services, events, campaigns, and other offerings
• Responses to inquiries, requests, and similar communications
• Communications regarding billing for services and other offerings
• Surveys and other activities to improve the quality of services and other offerings
• Delivery or display of advertisements of the Company or third parties
• Provision of customized services and other offerings to customers
• Response to violations of the Company’s terms and conditions
• Notification of changes to the Company’s terms and conditions and other rules
• Analysis of access and usage
• Analysis for the development of new products and services
• Creation of statistical data processed so that individuals cannot be identified

User and Member Information

• User registration, identity verification, and authentication
• Stable provision, protection, and improvement of services
• Communications, including important notices regarding services
• Verification of service usage history with business partners
• Information about the Company’s products, services, events, campaigns, and other offerings
• Responses to inquiries, requests, and similar communications
• Surveys and other activities to improve the quality of services and other offerings
• Delivery or display of advertisements of the Company or third parties
• Provision of customized services and other offerings to customers
• Response to violations of the Company’s terms and conditions
• Notification of changes to the Company’s terms and conditions and other rules
• Analysis of access and usage
• Analysis for the development of new products and services
• Creation of statistical data processed so that individuals cannot be identified

IoT Device Configuration and Log Information

• Device configuration, connection, control, maintenance, and troubleshooting
• Stable provision and quality improvement of services, and investigation of defects
• Responses to inquiries, requests, and similar communications
• Analysis of access and usage
• Analysis for the development of new products and services
• Creation of statistical data processed so that individuals cannot be identified

Business Partner Information

• Management of the Company’s business partners
• Communications, cooperation, negotiations, performance and enforcement of contracts, and sales activities relating to transactions

Seminar and Business Card Information

• Provision of information about the Company’s products, services, events, seminars, campaigns, surveys, and similar matters; responses to inquiries; improvement and new development of such offerings; and provision of information about products of the Company’s business alliance partners
• Sales and marketing activities, including communications from the Company and distribution of newsletters regarding the Company’s products and services
• Creation of statistical data

Information Entrusted to the Company in Connection with Outsourced Services

• Performance of the contract with the entrusting party to the extent necessary to carry out the entrusted services
• Maintenance, provision, protection, and improvement of services and other offerings
• Responses to inquiries, requests, and similar communications

Shareholder Information

• Exercise of rights and performance of obligations under applicable laws and regulations
• Provision of various benefits by the Company in connection with shareholder status
• Implementation of various measures to facilitate relations between shareholders and the Company
• Shareholder administration, including preparation of shareholder data in accordance with prescribed standards under applicable laws and regulations

Information Provided in Inquiries

• Responses to various inquiries

Job Applicant Information

• Recruitment activities, including communications and provision of information relating to the selection process
• Preparation of statistics, materials, and similar documents

Officer and Employee Information

• Personnel administration, payroll, and other labor management
• Employee benefits and occupational health and safety management
• Education and training
• Employee welfare
• Business communications and emergency communications
• Public relations activities
• Communications as necessary for social gatherings and similar purposes

Security Camera Footage

• Ensuring safety and security within the Company’s facilities and facilities managed by the Company

For the purposes of use of personal information not listed above, please contact the inquiry desk specified in Section 5, “Handling of Inquiries and Complaints.”

1.3 Provision or Disclosure to Third Parties

The Company will not provide or disclose acquired personal information to any third party except in the following cases:

1. When the individual concerned has given consent.
2. When required or permitted by laws and regulations.
3. When necessary to protect a person’s life, body, or property and it is difficult to obtain the consent of the individual concerned.
4. When particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the consent of the individual concerned.
5. When it is necessary to cooperate with a national government agency, local government, or a person entrusted by either in performing duties prescribed by laws and regulations, and obtaining the consent of the individual concerned is likely to impede the performance of those duties.
6. When it is difficult to obtain the consent of the individual concerned for the provision of information and, after following the procedures prescribed by laws and regulations, the Company has notified the individual in advance of, or made readily accessible to the individual, the following information:
   1. The Company’s name and address and the name of its representative.
   2. The fact that provision to third parties is a purpose of use.
   3. The categories of personal data to be provided to third parties.
   4. The means or method of provision to third parties.
   5. The fact that, at the request of the individual concerned, the Company will cease providing to third parties personal data by which that individual can be identified.
   6. The method by which the personal data was acquired.
   7. The method for accepting requests from the individual concerned.
   8. Other matters prescribed by rules of the Personal Information Protection Commission as necessary to protect the rights and interests of individuals.

1.4 Outsourcing

To facilitate its operations and provide better services to customers and other individuals, the Company may outsource the handling of their personal information to business partners. In such cases, the Company limits the personal information entrusted to the minimum necessary to perform the outsourced work, enters into agreements governing its handling with the contractor, and exercises appropriate supervision.

2. Management of Personal Information

The Company exercises the utmost care to prevent unauthorized access to, leakage, loss, or damage of personal information and takes necessary and appropriate security control measures, including establishing internal rules and providing thorough employee training. The Company also endeavors to keep the personal information of customers and other individuals accurate and up to date and to delete such information when it is no longer necessary to use it.

If unauthorized access, leakage, loss, or damage occurs, the Company gives top priority to preventing the spread of harm, promptly takes corrective action, investigates the cause, and endeavors to prevent recurrence. At the same time, the Company reports information regarding the incident to relevant persons and authorities to the extent necessary.

The Company takes the following measures to securely manage retained personal data:

(1) Formulation of a Basic Policy

The Company has established a Personal Information Protection Policy to appropriately manage personal data in accordance with the Act on the Protection of Personal Information and JIS Q 15001.

(2) Establishment of Rules for the Handling of Personal Data

The Company has established internal rules based on the Personal Information Protection Policy regarding the methods for handling personal data, the persons responsible, and their duties.

(3) Organizational Security Control Measures

Under its personal information protection management system, the Company clearly identifies the employees who handle personal data and the scope of personal data they handle, and has established a reporting and communication framework for cases in which a violation or indication of a violation of laws or handling rules is identified.

The Company also periodically verifies actual compliance with its rules through internal audits and other means and takes corrective measures when violations are identified.

(4) Personnel Security Control Measures

The Company provides employees and other personnel with training on personal information protection and ensures that they are fully informed of applicable laws and internal rules.

The Company also obtains confidentiality pledges concerning personal data from employees and other personnel.

(5) Physical Security Control Measures

The Company controls entry to and exit from its offices and implements measures to prevent access by unauthorized persons.

When transporting personal data, the Company also takes measures to prevent theft, loss, and similar incidents.

(6) Technical Security Control Measures

The Company restricts the personnel who may access personal information databases and similar systems and has implemented mechanisms to protect information systems against unauthorized external access, malware, and other threats.

3. Improvement Measures

The Company endeavors to respond appropriately to changes in the social environment surrounding the handling of personal information. The Company also strives to make improvements by changing, revising, or supplementing this Policy and its various rules as necessary.

4. Handling of Requests for Disclosure and Other Actions

4.1 Requests Covered

When the Company receives, in the prescribed manner, a request from an individual or the individual’s representative regarding retained personal data entrusted to the Company (the personal information marked with an asterisk in Section 1, “Appropriate Acquisition, Use, Provision, and Outsourcing of Personal Information”) for notification of the purpose of use; disclosure; correction, addition, or deletion of content; suspension of use; erasure; or suspension of provision to third parties, or a request for disclosure of records of provision to third parties, the Company will verify the identity of the individual or the authority of the representative and respond within a reasonable period and scope.

However, the Company may be unable to comply with all or part of a request if doing so could harm the life, health, property, or other rights or interests of the individual concerned or a third party; materially interfere with the Company’s operations; or violate any law or regulation.

4.2 Request Procedure

(1) Submission Desk

Requests for disclosure and other actions are accepted by post. Please send a written request stating the details of the request, together with the identity verification documents specified below, to the following address. Please use the Company’s Personal Information Disclosure Request Form.

(2) Identity Verification Documents

If the request is made by the individual concerned

One copy of any one of the following: driver’s license, passport, or Basic Resident Register card with photograph; and the original of a certificate of residence and the original of a certificate of registered seal.

If the request is made by a representative

(1) A power of attorney (or, in the case of a statutory representative, a document proving statutory representative status).

(2) Documents verifying the representative’s identity (the documents specified above under “If the request is made by the individual concerned”).

4.3 Fees

The Company may charge a fee of JPY 500 (including tax) per request for notification of the purpose of use or disclosure.

5. Handling of Inquiries and Complaints

For comments, complaints, or inquiries regarding the Company’s handling of personal information or the contents of the Personal Information Protection Policy, please contact:

6. External Transmission and Other Handling of User Information

6.1 External Transmission of User Information

The services provided by the Company may use cookies and similar technologies to transmit information about users from users’ devices to servers operated by persons other than the users for purposes such as understanding usage, improving convenience, analyzing statistical data, and delivering, displaying, and measuring the effectiveness of advertisements.

In providing its services, the Company uses services provided by external service providers (“External Services”) and, with due respect for privacy protection, transmits to the providers of those External Services the user information necessary to use them (“External Transmission”). Information transmitted externally is managed and used in accordance with the privacy policies and other rules of the respective recipients.

For the names of the recipients and services, the content of the user information transmitted externally, and the purposes for which the transmitted information is used, please see:

Disclosures Regarding External Transmission of User Information

6.2 Links to Other Websites

The Company’s website contains links to third-party websites for customers’ convenience. Please note that the Company is not responsible for privacy protection on those third-party websites.

6.3 Acquisition of Information from Third Parties

In relation to “SpaceCore,” NextDrive Co., Ltd. (“ND”) acquires log information concerning electricity usage obtained through HEMS devices. ND cannot identify such information as relating to a particular customer. The Company obtains this information from ND, links it to personal information concerning the relevant customer, and uses it to provide services to that customer.

7. Procedures for Changes to the Privacy Policy

The Company may amend this Policy as necessary. If an amendment requires the consent of customers or other individuals under applicable laws and regulations, the amended Policy will apply only to those customers or other individuals who have consented to the amendment in the manner prescribed by the Company.

When amending this Policy, the Company will announce the effective date and contents of the amended Policy by posting them on its website or by another appropriate means, or will notify customers and other individuals thereof.