Privacy Policy

MK DT INFORMATION TECHNOLOGY L.L.C (the “Company”) and its affiliates, including its Japanese and Indonesian entities (collectively, the “MKDT Group”), recognize that respecting and properly protecting the privacy of our customers is an important responsibility. The Company and the MKDT Group have established this Privacy Policy, ensure that all officers and employees understand it, and will continue our efforts to protect not only personal information but all information assets.

• We comply with established rules on the collection, use and provision of personal information, and handle it safely under strict control.
• We strive to prevent unauthorized access to, and loss, destruction or alteration of, personal information.
• We comply with laws, regulations and other norms concerning the handling of personal information.
• We review our compliance program for the protection of personal information as appropriate and improve it continuously.

Specifying and Publishing the Purpose of Use

We specify, as far as possible, the purposes for which we use the personal information we obtain from customers, and publish them in advance.

When we obtain personal information directly from a customer in a contract or other written document, we state the purpose of use to the customer in advance.

Use Within the Scope of the Purpose of Use

We handle customers' personal information only to the extent necessary to achieve the purpose of use. However, we may handle it beyond that scope in any of the following cases:

1. When required by law
2. With the consent of the individual
3. When necessary to protect a person's life, body or property and it is difficult to obtain the individual's consent
4. When especially necessary to improve public health or promote the sound upbringing of children and it is difficult to obtain the individual's consent
5. When it is necessary to cooperate with a national agency, a local government, or a party entrusted by either in carrying out duties prescribed by law, and obtaining the individual's consent may interfere with those duties

Retention Period

We set a retention period for customers' personal information within the scope necessary for the purpose of use, and delete it without delay once the retention period has passed or the purpose has been achieved, except in any of the following cases:

1. When required by law
2. With the consent of the individual
3. When we retain personal information to the extent necessary to carry out our business and there is a reasonable ground for not deleting it
4. In addition to the three cases above, when there is a special reason for not deleting the personal information

Supervision of Contractors

We may entrust all or part of the handling of customers' personal information to third parties within the scope of the purpose of use. In selecting contractors, we confirm that they handle personal information properly, and require them to do so, for example by specifying the proper handling of personal information in the contract.

We also exercise necessary and appropriate supervision over contractors, for example by including provisions on audits of personal information handling in the contract.

Provision to Third Parties

We do not provide customers' personal information to third parties except in any of the following cases:

1. When required by law
2. With the consent of the individual
3. When necessary to protect a person's life, body or property and it is difficult to obtain the individual's consent
4. When especially necessary to improve public health or promote the sound upbringing of children and it is difficult to obtain the individual's consent
5. When it is necessary to cooperate with a national agency, a local government, or a party entrusted by either in carrying out duties prescribed by law, and obtaining the individual's consent may interfere with those duties
6. When we entrust the handling of personal information to the extent necessary to achieve the purposes of collection and use
7. When personal information is provided as part of a business succession due to a merger or other reasons
8. When it is jointly used among group companies as set out in the following section

Handling of Personal Information Outside Japan

To the extent necessary to achieve the purpose of use, we may entrust all or part of the handling of customers' personal information to businesses outside Japan (including cloud service providers), use it jointly with our overseas group companies, or store it on servers located outside Japan (main storage and transfer destinations: the United Arab Emirates, Indonesia, etc.).

In such cases, we take necessary and appropriate measures for the secure management of personal information, based on an understanding of the personal information protection systems of the countries concerned. When we provide personal information to a third party in a foreign country as required by law, we do so only after obtaining the customer's consent in advance or confirming that the third party has an appropriate protection system in line with Japanese law.

Joint Use of Personal Information

If you wish to request notification of the purpose of use, or disclosure, correction, addition or deletion of your personal information, or suspension of its use or of its provision to third parties, please follow the procedure separately specified by the Company.

After confirming that the requester is the individual concerned, we will respond promptly and appropriately within a reasonable period and scope.

Requests for Disclosure, etc.

If you wish to request notification of the purpose of use, or disclosure, correction, addition or deletion of your personal information, or suspension of its use or of its provision to third parties, please follow the procedure separately specified by the Company.

After confirming that the requester is the individual concerned, we will respond promptly and appropriately within a reasonable period and scope.

Handling of Complaints

We respond promptly and appropriately to complaints and other inquiries from customers regarding the handling of personal information.

Response to Data Breaches

In the event of a leak or other incident involving customers' personal information, we will respond promptly and appropriately, including notifying the customers concerned of the facts without delay.