Privacy Policy

Casley Deep Innovations, Inc. (the "Company") is, In carrying out planning, development and consulting services for information processing systems, and in providing our services (hereinafter referred to as "our services") to our customers (hereinafter referred to as "our services") to our customers, We recognize that it is our important social responsibility to protect the personal information of our customers and our employees and to operate our services appropriately.

To ensure the proper and safe handling of such personal information in the future, Protection, handling, etc. of such personal information, We have established the following privacy policy as a standard of conduct to be observed by all of our officers and employees, and contribute to the operation and improvement of the protection of personal information.

1. Personal Information

"Personal information" means as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act"). (hereinafter referred to as "Personal Information"), (iii) "Personal Information" means information concerning a living individual that can identify a specific individual by name, date of birth, or other description, etc., contained in such information, or information that contains a personal identification code.

2. Purpose of Use for Personal Information

We will acquire personal information appropriately to the extent necessary for the following purposes, We will use the acquired information for the following purposes. We will clarify in advance the purpose of use and whether or not the information will be provided, We will obtain the consent of the person in advance, use the information appropriately within the scope of the purpose, and take measures to ensure that the information is not used for purposes other than the stated purpose. In addition, we will take measures to ensure that the information is not used for purposes other than those described below,

(1) Personal information about customers who use our services
1. To provide our service
2. To improve and enhance our services or develop new services
3. To contact customers (important notices such as maintenance and revisions to the Terms of Service, information on new features and updates to our services, information on campaigns and other services provided by us, requests for cooperation in surveys, interviews, etc. related to our services, and requests to participate in various events), (including information on campaigns and other services provided by the Company, requests for cooperation in.)
4. To investigate and analyze the usage history of our services, and use the results for advertising distribution.
5. Providing personal information to participating companies, etc. of the Company -sponsored event based on your consent and application
6. To identify users who attempt to use our services for fraudulent or unfair purposes, and to refuse their use
7. In addition to the above, we will use it within the range of consent from customers.
(2) Personal information concerning client companies (including personal information obtained other than directly in writing)
1. To execute the consignment work
2. To contact us regarding transactions
3. For administrative procedures such as submission of contract, delivery, invoice, payment confirmation, etc.
4. In addition to the above, we will use it within the range of consent from client companies.
(3) Personal information about partners (including personal information obtained other than directly in writing)
1. For engagement and execution in system development projects
2. In addition to the above, we will use it within the range of consent from client companies.
(4) Personal information about customers who receive inquiries
1. To answer opinions, inquiries, etc. regarding our services
2. To use the information other than the above to the extent that we have obtained consent from the customer
(5) Personal information obtained through the use of ASCA/DEFENDER-X with SAFR managed by our company
1. For the prevention of criminal acts (including shoplifting, theft, and vandalism) and nuisance behaviors (including voyeurism)
2. To improve the accuracy of image analysis functions
3. To use it for marketing
(6) Personal information about our employees
1. For personnel labor management work, safety and health management work, and other business execution
(7) Personal information about employee recruitment applicants
1. For reception and contact for interviews, selection of applicants, and recruitment pass / fail judgment
(8) Personal information about our employees
1. For responding to inquiries from government offices and social insurance offices, etc
(9) Personal information about management administration
1. For the management of company establishment-related documents and board of directors-related documents

3. Basic Information

We have established a personal information protection management system that complies with the Japanese Industrial Standard "Personal Information Protection Management Systems - Requirements" (JIS Q 15001:2006) as a standard of conduct to be observed by all of our officers and employees, and we will properly maintain and operate this system. The Company has established a personal information protection management system in accordance with JIS Q 15001:2006, and will maintain and operate this system appropriately.
With respect to the handling of personal information handled in all of our businesses and the personal information of our directors, officers, employees, etc., we will comply with laws, regulations, national guidelines, and other norms related to the protection of personal information.
We will take reasonable security and corrective measures against risks such as unauthorized access to personal information, loss, destruction, damage, falsification, and leakage of personal information.
In response to changes in social and economic conditions, we will continuously review and improve our personal information protection management system to ensure the appropriate use and protection of personal information.

4. Ensuring the Accuracy of Data Content

We strive to keep personal data accurately and up to date within the scope necessary to achieve the purpose of use.

5. Management and Protection of Personal Information

"The management of personal information will be strictly carried out, and we will not disclose or provide data to third parties unless the customer consent is made, except in the following cases. In addition, in consideration of safety, we will take measures to prevent unauthorized access to personal information, to prevent risks such as loss, destruction, tampering, and leakage."

When it is necessary for the protection of a person's life, body, or property and it is difficult to obtain the customer's consent
When it is especially necessary to improve public health or to promote the sound growth of children and it is difficult to obtain the customer's consent
When it is necessary for the national institution, local governments, or those who have been commissioned, need to cooperate in carrying out the clerk specified by law, When the consent of the customer may hinder the execution of the office work
When outsourcing all or part of the handling of personal information within the scope necessary for achieving the purpose of use in order to carry out the work smoothly
In cases where personal information is provided in connection with the succession of business due to mergers or other reasons
When using personal information in collaboration with a specific person, the item of the personal information used in collaboration, the scope of those who use it in collaboration, When the name or name of the person who is responsible for the use of the user and the management of the personal information are notified in advance, or in a state where customers can easily know it.
Other cases of laws and regulations

6. Matters to Disclose and Provide to Third Parties

In the following cases, we may disclose and provide the personal information provided to third parties. When providing personal information to third parties, we will select a person who has met the sufficient protection level and take appropriate measures through contracts.

Type of business	Purpose of provision	Personal information item	Made or method	Types and attributes of the organization to be provided
Salary / bonus transfer business	For salary and bonus payments	Name, account information	Web registration	Bank
System development work	To participate in system development projects	Gender, date of birth, name, address, educational background, technical career	Directly handed, fax, email	Our business partner company Contract on handling of personal information: No contract is individually contracted.
Consignment work	To prevent criminal acts, etc.	Video data taken with security cameras, etc.	Cloud server	Government offices, our business partners

7. Consignment of Handling of Personal Information

We may outsource all or part of the handling of personal information within the range necessary to achieve the purpose of use. In this case, the Company will fully examine the qualifications as a consignment, and will determine matters related to confidentiality in the contract, and perform necessary and appropriate supervision for the contractor.

8. Joint Use of Personal Information

The Company may share your personal information for the following scope and purpose as long as you need to achieve the purpose of use.

<Purpose of shared use>
For security and inconvenience
<Scope of personal information to be used>

As an analysis of camera images and images, crime acts and abuses suspected of bothering
<Scope of personal information to be used>
CASLEY DEEP INNOVATIONS Co., Ltd. and its affiliates
<Those who are responsible for managing personal information>
CASLEY DEEP INNOVATIONS Co., Ltd. (Representative Kazumasa Sunagawa)

9. Disclosure of Personal Information

We will disclose personal information to our customers (limited to the person himself/herself. When we are requested to disclose personal information by a customer (limited to this article, the same hereinafter), we will disclose such information to the customer without delay. However, if disclosure would result in any of the following cases, we may not disclose all or part of the information, and if we decide not to disclose the information, we will notify the customer to that effect without delay.

If there is a possibility that the life, body, property, and other rights of the third party may be harmful
If there is a risk of significant hindrance to the proper implementation of our business
Other cases where it violates laws and regulations

10. Correction and Deletion of Personal Information

If the personal information in our possession is incorrect, we will, at the request of the customer, correct or delete the personal information in accordance with the procedures we have established. If we receive a request from the customer and determine that it is necessary to comply with the request, we will correct or delete the relevant personal information without delay and notify the customer of such correction or deletion.

11. Suspension of Use of Personal Information, etc.

If we receive a request from a customer to cease use of or erase personal information (hereinafter referred to as "cease of use, etc.") because it falls under any of the following items, we will conduct the necessary investigation without delay. In the event that the Company receives a request from a customer to cease use of or erase personal information (hereinafter referred to as "Cessation of Use, etc."), the Company will conduct the necessary investigation without delay, and based on the results of such investigation, the Company will cease use of personal information in accordance with the law and notify the user thereof. However, in cases where the suspension of use, etc. of personal information involves a large amount of cost, or where it is otherwise difficult to suspend the use, etc. of personal information, and However, in cases where it is difficult to suspend the use of personal information due to the large amount of costs involved or other reasons, and alternative measures can be taken to protect the rights and interests of the user, we will take such alternative measures.

If it is handled beyond the scope of the purpose of use
When the personal information acquired by fraudulent means
When it is used in a method that promotes or unjust act or may be triggered
If we no longer need to use your personal information
When there is a risk of leak, loss or loss of personal information containing personal information (hereinafter referred to as "leakage, etc.").
When there is a risk of leakage of personal information that may have been performed for the purpose of fraud, or may occur.
If there is a risk of leakage or more or more of the number of individuals on personal information, or may occur.
If the handling of the personal information may be damaged by the right or legitimate interest of the user

12. Safety Management Measures

Personal information entrusted to us by our customers will be stored in a highly dispersed manner in Japan and abroad in a highly dispersed manner to ensure its safety. In addition, by taking organizational, physical, human, and technical measures such as recording access logs of personal information files and implementing security measures to prevent unauthorized access from outside, We will prevent unauthorized access to personal information, as well as the loss, destruction, falsification, or leakage of personal information. In the unlikely event of an accident such as the leakage of users' personal information, In accordance with the Personal Information Protection Law and related guidelines, we will promptly report the incident to the regulatory authorities and take necessary measures to prevent similar incidents from occurring or recurring, in accordance with their instructions.

13. Audit

We will regularly conduct audits to confirm the status of safety management measures. In the audit, if the safety management measures are not sufficiently taken, we will promptly formulate improvement measures and take measures to prevent recurrence.

14. Change of Personal Information Protection Policy

We will review the contents of this personal information protection policy as appropriate and strive to improve it. The contents of this personal information protection policy except for laws and regulations and other specified matters in this personal information protection policy. It can be changed. The changed privacy policy shall be effective from the company prescribed by the Company, or from the time it is posted on our website.

15. Response to Complaints and Consultations

We will accept complaints and consultations regarding the handling of personal information at our inquiry desk and respond to them appropriately and promptly. In addition, requests for disclosure, correction, addition, deletion, or refusal to use or provide such personal information (hereinafter referred to as "disclosure, etc.") (hereinafter referred to as "Disclosure, etc."), We will respond appropriately and promptly to the extent reasonable after following the procedures prescribed below.

If you wish to request disclosure, etc., please download and fill out the application form below, or contact us at the contact address below and we will mail the form to you. After filling out the form, please be sure to bring or mail it to the contact address below, along with the documents for identification.
Application for personal information, disclosure, etc.
In order to confirm that the claimant such as disclosure is the person, we will confirm the identity by name, address, telephone number, date of birth, etc. In addition, the details of the claim method by the agent are described in the above application form.
We do not collect commissions for "notifications for use" or "disclosure" of disclosure target personal information.

16. About the Voluntary Nature of Providing Personal Information and the Results that Occur

It is optional to provide personal information. However, if we do not provide the personal information we seek, Please note that you cannot receive the services listed in "2 Purpose of use of personal information".

17. Acquisition of Personal Information in a Way that the Person Cannot Easily Recognize

We do not acquire personal information on our own management site in a way that cannot be easily recognized by the person using technologies such as cookies and web beacons.

18. Our Address, Representative, Name, and Personal Information Protection Manager

The name of our address, representative and personal information protection manager is as follows.

Address: Ebisu 4-20-4, Shibuya-ku, Tokyo, Ebisu Garden Place Tower B1F
Representative: Kazumasa Sunakawa
Personal Information Protection Manager: Kazutaka Egawa

19. Inquiry Contact

For inquiries regarding the handling of personal information by our company, please contact the following.

Casley Deep Innovations Corporation Security Management Office
Ebisu 4-20-4, Shibuya-ku, Tokyo, Ebisu Garden Place Tower B1F
Mail: info@casleydi.co.jp
Inquiry time: Weekdays (Monday to Friday) 10:00 to 19:00

20. Certified Personal Information Protection Organization's Name and Destination for Resolution of Complaints

The Company is the target business of the Japan Information Economic and Social Promotion Association, a general incorporated association, which is a certified personal information protection organization. Regarding complaints about the handling of our personal information, we can apply for a solution to the Personal Information Protection Conservation Council provided within the association.

Name of certified personal information protection organization	Japan Information Economic and Social Promotion Association
Application for solving complaints	Personal information protection complaint counseling room
Address	1-9-9 Roppongi, Minato-ku, Tokyo 106-0032 Roppongi First Building 12F
Phone number	03-5860-7565 / 0120-700-779

21. Others

The references are as follows. In addition, the Personal Information Protection Policy has been confirmed by the JEAS Nippon Shoiku Prevention System Association.

JEAS Personal Information Protection Guidelines 3rd Edition
https://www.ppc.go.jp/files/pdf/48_jeas_shishin.pdf
Report of experts about the use of camera imaging to prevent crime and ensure safety (draft)
https://www.ppc.go.jp/files/pdf/20230314_shiryou-2.pdf

Issue Date: June 1, 2023
Issuer: Casley Deep Innovations Co., Ltd.
Postal Code: 150-6090
Ebisu 4-20-4, Shibuya-ku, Tokyo
Ebisu Garden Place Tower B1F

Notes on the introduction and use of ASCA/DEFENDER-X with SAFR

For the purpose of daily safety and protection of our customers and to prevent illegal activities, we have developed ASCA/DEFENDER-X with the purpose of preventing criminal acts such as shoplifting and theft (including destruction of property) and nuisance acts (including voyeurism) and improving the accuracy of image analysis functions, ASCA/DEFENDER-X with SAFR, which detects behavior such as shoplifting from camera images and helps prevent crime, has been installed in the face recognition cameras ¹ installed at the entrance/exit of stores at our customers' facilities.

※1. Face recognition cameras refer to security cameras equipped with facial identification features.

1. Purpose of Use of Face Authentication Camera System

We use it to prevent criminal acts such as shoplifting and theft (including property damage), to deter nuisance behaviors (including voyeurism), and for marketing purposes.

2. Installation Outline

The face authentication camera will be installed at the entrance of the installed facility, and it will be taken for security and inconvenience. The face authentication camera is indicating that the face authentication camera is being operating at an easy -to -read position near the entrance of the installation facility.

3. Standards for Disclosure and Provision to Third Parties

We will not disclose or provide acquired image data to third parties without the consent of the individual. However, we may disclose or provide information if requested to do so under the following circumstances.

When required by laws and regulations
If a request for a criminal investigation is received from an investigative agency
In cases deemed urgent and necessary to protect human life, body, or property

※When information is provided to a third party, the date and time of the provision, the recipient, the information provided, and the purpose and reason for the provision will be noted on a separate sheet of paper and stored. In addition, when providing information to a third party, we will fully consider the necessity of providing the information.

4. About Personal Information and Privacy Protection

The Act on the Protection of Personal Information defines information that can identify a specific individual as personal information. Image data acquired by a face recognition camera may also fall under the category of personal information as defined by the Act. In addition, depending on how the image data captured by a face recognition camera is handled, there is a risk of infringement of privacy. When handling image data, in addition to the provisions set forth in this Privacy Policy, the Company shall comply with the Act on the Protection of Personal Information and other related laws and regulations, The data will be handled appropriately in consideration of the protection of personal information and privacy.

5. Establishment of Information Management Managers

Two managers will be installed at the facial authentication camera system introduction office.

6. Operation of Registration Information

The registered information obtained will be set up by each administrative person, giving the management responsible person only to operate, and does not operate others.

7. Information Leakage Prevention Measures for Retirees

We change login information regularly so that retirees do not acquire personal information after retirement.

8. Inquiries about Registration Information

For inquiries about the information obtained by each store, each manager will respond.