Spiral Ventures Pte. Ltd. (hereinafter referred to as the “Company”) has established the following Privacy Policy (hereinafter referred to as the “Policy”) regarding the handling of personal information of customers (including representatives of business partners), and will appropriately handle such personal information in accordance with this Policy.
1. Purpose of Use of Personal Information
The Company shall acquire and use customers’ personal information only to the extent necessary to achieve the following purposes of use (hereinafter referred to as the “Purposes of Use”):
- To use as a means of confirming administrative communications and other correspondence with customers
- To exercise rights and fulfill obligations under contracts, laws, and regulations with customers
- To verify the identity of the individual based on the laws or regulations of relevant countries
2. Provision of Personal Information to Third Parties
Except as required by laws and regulations, the Company will not provide customers’ personal information to any third party without obtaining the customer’s prior consent.
3. Requests for Disclosure, etc.
Customers may request the Company, in accordance with the procedures set forth in (4) below and within the scope permitted by laws and regulations, to notify them of the purpose of use or to disclose their personal information or records of provision to third parties. However, the Company may not disclose such information if there are grounds prescribed by laws and regulations or if the Company is unable to confirm that the request is made by the customer.
Customers may request the Company, in accordance with the procedures set forth in (4) below, to correct, add to, or delete their personal information. In such cases, the Company will promptly conduct an investigation within the scope necessary to achieve the purpose of use and, based on the results, will correct, add to, or delete the relevant personal information to the extent permitted by laws and regulations.
Customers may request the Company, in accordance with the procedures set forth in (4) below, to suspend the use of their personal information or to stop providing it to third parties. In such cases, the Company will respond appropriately in accordance with laws and regulations.
When making any of the requests described in the preceding three paragraphs, customers are requested to complete the Company’s prescribed request form (please contact us as described in “5. Inquiries”) and send it to the email address listed in “5. Inquiries.”
4. Security Management Measures
The Company will implement necessary and appropriate security management measures to prevent leakage, loss, or damage of customers’ personal information it handles, and to otherwise ensure the safe management of personal information. The security management measures implemented by the Company are as follows:
- The Company establishes and complies with a basic policy regarding methods for handling personal information to ensure its proper handling.
- The Company appoints a person responsible for handling personal information and establishes a reporting and communication system to report to such person in the event that a violation of the Personal Information Protection Act or internal personal information handling regulations, or signs thereof, is identified.
- The Company imposes confidentiality obligations on its officers and employees and thoroughly informs them of security management measures. It also appropriately manages areas where personal information is handled and implements measures to prevent theft and similar incidents.
- The Company introduces mechanisms to protect against unauthorized external access and malicious software, and sets access privileges as necessary.
- When handling personal information in foreign countries, the Company will understand the systems related to the protection of personal information in the relevant country or region and implement necessary security management measures.
5. Inquiries
For opinions, requests, or complaints regarding the handling of personal information, as well as other inquiries related to the handling of personal information, please contact the following:
[Contact Information]
Spiral Ventures Pte. Ltd.
Email address: [email protected]