Last Updated: April 20, 2010
Small Bridge Inc. (hereinafter We, Us, Our Company) recognizes the safeguarding of personal information to be a critical social commitment of the firm, and require all of our employees including officers to comply with the policy herein for any personal information obtained through Cafetalk (http://cafetalk.com).
1. Definition and Usage of Personal Information
Personal information is defined as information pertaining to an individual, including standard information that can be used to identify a specific individual (Act on the Protection of Personal Information, Article 2). However, we are not responsible for personal information accessed through websites that we do not directly manage, even if our users are directed to those websites through links posted onto the site that we operate (hereinafter Our Site).
2. Laws and Ordinances Pertaining to Personal Information, Nationally Established Guidelines, and Compliance to Other Criteria
As a site operation business that deals with customers’ important personal information, we abide by the personal information protection laws based on guidelines created by the Japanese governmental authorities, starting with JISQ15001 (Personal information protection management systems) and other models that relate to protecting personal information (hereinafter Relevant Laws).
3. Reasonable Acquisition of Personal Information
1) We handle personal information acquired through legal and impartial means.
2) In the case that we must acquire personal information directly from the user, we will specify the necessary item and intended usage of this information to the user and acquire the information after gaining permission. In the case that we obtain the personal information through a third party, we will confirm that the third party obtained this information from the user through reasonable means, and make a notice on our website of the necessary item and intended use of this personal information.
3) We do not acquire the specific and delicate personal information listed below. However, in the case that we are required to adjust our policy based on relevant laws, this information may not be limited to what appears on this list.
① Information pertaining to ideology, faith, or religion
② race, nationality, lineage, permanent residence (excluding information about Japanese prefectures), body, mental disorders, criminal record, and other information that may be a cause of social discrimination.
③ Information regarding the workers’ right to organize, collective bargaining, and other acts of group behavior.
④ Information regarding participation in group demonstrations, exercising the right to petition, and exercising other governmental rights.
⑤ Information regarding health and medical treatment or one’s sex life
4) We receive information based on the students’ and teachers’ cookies (a standard technology, in which a web server discerns information from a user’s browser). This information is less than or equal to the following: user information, visited pages, and user environment. After automatically receiving this information from the user’s browser, we analyze it in order to make improvements to the quality of our site. This information does not indicate specific information that could discern an individual so it is not applicable as personal information, however, if you do not wish for us to obtain this information, please disable cookies on your browser.
4. Prohibition of Usage Outside of the Stated Usage of Personal Information
1) We manage collected personal information in an appropriate manner and never provide nor disclose it to any third parties without your consent.
2) The personal information we collect is mainly used for the following purposes:
① To operate the service smoothly
② To implement lesson requests for lessons that instructors wish to offer and that students wish to take.
③ To pay instructors fees that are equivalent to the lessons that they offer through their public profiles on this site.
④ To check users’ identities
⑤ As a reference guide in order to draft or improve this service or other services provided by our company
⑥ To distribute the site’s newsletter
⑦ To provide information that is considered beneficial to users about our service and any other service information.
5. Appropriate Disclosure of Personal Information to Third Parties
We manage personal information in an appropriate manner and will not disclose it to third parties without consent, except for in the following situations:
1) If required by law.
2) Cases in which the provision of personal data is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person
3) Cases in which the provision of personal data is specially necessary for improving public health or promoting the sound growth of children who are still developing both mentally and physically and when it is difficult to obtain the consent of the person
4) Cases in which the handling of personal information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned
6. About Third-Party Cookies
1) Sometimes we will display advertisements via third-party companies who may collect and store information about your visits on your browser in the form of cookies.
3) You can disable this feature by opting out on the respective third-party websites.
4) Cookies are usage and data entry logs transceived between browsers and servers that are saved as files on your computer. Next time you access the same page, the page administrator can change what you see based on the information from the cookies. If you have cookies enabled on your browser, websites can obtain cookies from your browser. In order to protect your privacy, your browser will only send cookies to a website’s server if it has received cookies from that server.
5) You can choose between settings such as “enable all cookies,” “disable all cookies,” or “notify me when I have received cookies.” These settings differ by browser. Please check how to change your settings by referring to your browser’s help menu.
6) Please note that if you disable all cookies, you may face some restrictions on which internet services you will be able to utilize, including services that require authentication.
7. Analyzing your Communications
We may review, scan, or analyze your communications on the Cafetalk Platform for reasons outlined in this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.
8. Third-Party Partners & Integrations
Parts of Cafetalk may link to third-party services, not owned or controlled by Cafetalk, such as Zoom, Vimeo and Google Calendar. Use of these services is subject to the privacy policies of those providers. Cafetalk does not own or control these third parties and when you interact with them you are providing your information to them.
9. Data Erasure
In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the erasure of your personal information:
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Cafetalk and Cafetalk Payments may keep information for tax, legal reporting and auditing obligations.Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Cafetalk, even after your Cafetalk Account is cancelled. However, attribution of such information to you will be removed.
Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
10. Unsubscribing from Information Regarding Our Service
We occasionally send emails to customers with information that are considered to be beneficial to them about our service and any other service information. Customers may cancel or restart the service by requesting in a method set by us.
11. Ensuring Accuracy of Personal Information
In order to reach our goals within the range of our purpose of use, we strive to keep the content the information as accurate and up to date as possible.
12. Prevention of Leaks, Losses, or Breaches of Personal Information
We take the following rational safety measures, corrective and preventive actions against any risk of personal information leak, loss or breach to secured personal information. Additionally, in the event that a deficiency is found within the security system, we will take swift corrective actions.
1) As we take countermeasures against unauthorized access to personal information stored within the system, we keep an access log and keep surveillance.
2) Safekeeping of paper or digital media containing personal information
3) Physical security measures to counteract unauthorized access into the office and server room.
4) When disposal and safekeeping of personal information is entrusted to a contractor, necessary supervision is provided in order to enforce protection of personal information.
We do not manage user ID’s or passwords. If by any chance a user inadvertently lets a third party use his ID or password, that user’s personal information may be accessed by the third party. Users are responsible for the protection of their own ID’s and passwords, and are warned that their mistakes while using the site may be taken advantage of by third parties.
14. Supervision of Workers and Trustees
1) In order to manage personal information in a reasonable manner, we provide necessary training to those who work with personal information and supervise them properly.
2) In the event that we entrust the management of personal information to an external body, we will ensure proper management and supervision of the trustees by executing a contract that includes the duty of confidentiality.
15. Continuous Improvement of the Personal Information Management System
We use personal information in an appropriate manner and in order to provide complete protection of that information, we regularly inspect our management system and are constantly making improvements to it. This includes making adjustments according to changes in business environments or social state of affairs, advances in information security technology, and the establishment or revision of laws and ordinances.
16. Inquiries Concerning Personal Information
1) If you have any questions or complaints about our management of personal information, please use the information listed below to contact us and we will get back to you as quickly as possible.
2) If you request a report on our purpose of utilization regarding personal information, legal disclosures, corrections, additions, deletions, suspensions of use, discontinuation of third party offers, or erasures, we will go through with the procedures after checking your identity.
3) If you have any questions or complaints regarding this or any of the preceding passages, please direct them to Cafetalk through the contact information below.
17. Revisions to this Policy
In order to provide complete protection of your personal information now and in the future, we will revise the policy in accordance to changes in business trends. Please note that in the case of a revision, we will indicate every change made on this page.
18. Governing Law
These policies are governed by laws of Japan.
Any disputes regarding this policy will be under the court jurisdiction of the Tokyo Summary Court or the Tokyo District Court.
Established and effective as of April 20, 2010
Small Bridge, Inc.
Representative Director: Kotaro Hashizume