PRIVACY POLICY
1. Introduction
Mori Building Co., Ltd. (“Mori Building”) and Mori Building Palo Alto Co., Ltd. (“MBPA”) (collectively, “we,“ “us,” or “our”) comply with the Japanese Act on the Protection of Personal Information (the “APPI”) , the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) and any other applicable laws and regulations and properly handle your personal information pursuant to this Japan Innovation Campus Privacy Policy (this “Policy”).
This Policy applies to our handling of personal information of the users of the Services (as defined below) (“you” or “user”) which we collect regarding our co-working space which MBPA operates under the name of Japan Innovation Campus (the “Facility”) and any relevant services which we provide in relation to the Facility such as management of online communities (together with the Facility, the “Services”). We operate the Services as part of the business consigned by the Japanese Ministry of Economy, Trade and Industry (“METI”).
2. Personal Information We Collect
We collect the following categories of personal information of the users.
(1) Personal Information we collect from you
We collect your personal information such as that listed below directly from you or your company or organization:
• Profile and contact information, such as name, the name of your company or organization, title, phone number, Email address, address, facial images, date of birth, nationality;
• Information regarding visa status;
• Information regarding your SNS account;
• Usage status of the Services;
• Event participation status;
• Content of inquiries you make and content of your responses to our questionnaire surveys;
and
• Other information you or your company or organization voluntarily provide to us.
(2) Personal information automatically collected from your device
At the time when you are using this website or other online services, we collect your personal information such as that listed below from the device that you are using:
• Technical information such as types and versions of OS or language settings;
• Internet Protocol address and approximate geolocation information based thereon;
• Online identifiers such as cookie ID; and
• Log information including access times, and pages and content viewed.
<Personal Information of Minors>
We do not knowingly collect personal information from minors under thirteen years of age in relation to the Services. If we discover that we have collected personal information from minors under thirteen years of age, we will take steps to delete such information as soon as possible. If you become aware that a minor under thirteen years of age has provided us with personal information, please contact us immediately at the contact information set forth in “10. Contact Information” below.
3. Purposes of the Collection and Processing of Personal Information
We will collect and process your personal information for the following purposes:
(1) To operate and provide the Services, such as:
• managing the Facility and relevant facilities, including ensuring the security thereof;
• managing the user community and enhancing communication or collaboration between users or between users and local communities;
• user registration, authentication and confirmation;
• planning and organizing events;
• providing you with information about theFacility, event information and other useful information; and
• answering your inquiries.
(2) To improve or develop the Services, such as:
• carrying out questionnaire surveys; and
• investigating and analyzing the usage status of the Services.
In principle, we will collect and process your personal information within the scope of the purposes set forth above, and when we use your personal information outside the scope of those purposes, we will obtain your prior consent unless otherwise permitted by applicable law.
4. Provision of Personal Information to Third Parties
Except for the following cases, we will not provide personal information to third parties without obtaining your prior consent unless it is permitted under the applicable laws and regulations.
(1) Provision to METI
We will provide your personal information to the Japanese Ministry of Economy, Trade and Industry (METI). By agreeing to this Policy, you consent to such provision of your personal information.
(2) Provision to Subcontractor
We may provide the personal information to our subcontractors for the purpose of operating the Services. We will enter into a contract with the subcontractors obligating them to implement appropriate security measures to protect your personal information and continually monitor their processing thereof.
(3) Sharing between Mori Building and MBPA
We will share your personal information between Mori Building and MBPA for the purposes specified in “3. Purposes of the Collection and Processing of Personal Information” The categories of personal information shared is the same as described in “2. Personal Information We Collect”. MBPA is the administrator of the sharing of the information and your primary contact point.
Administrator of the sharing
Mori Building Palo Alto Co., Ltd.
Address: 212-214 Homer Ave, Palo Alto, CA 94301, USA
CEO: Yoshiaki Mori
5. Security Measures of Personal Information
We implement reasonable security procedures and practices appropriate to the nature of the personal information in order to protect the personal information from unauthorized or illegal access, destruction, use, modification or disclosure. In the case that we delegate all or part of the handling of personal information to a subcontractor, we will ensure that the subcontractor is subject to contractual obligation to implement appropriate security procedures and practices and appropriately supervise the subcontractor. If you have any question about our security procedures and practices, please contact us at the contact information set forth in “10. Contact Information” below.
6. International Transfer of Personal Information
In principle, your personal information is stored within the U.S. or Japan. Please note, however, that, to the extent necessary for the purposes specified in “3. Purposes of the Collection and Processing of Personal Information” above, your personal information may be transferred to and stored in countries/regions outside the U.S. and Japan, and that such country/region may not have the same level of data protection as that provided within the U.S. and Japan. In the course of the international transfer of your personal information, we will take adequate measures to protect your personal information and ensure that related collection and processing of your personal information are in accordance with applicable laws.
7. Data Retention
We may retain your personal information one year after we cease providing the entire Services.
8. Your Rights
You may have certain rights regarding your personal information under the APPI and other applicable data protection laws, such as the right to know your personal information or the right to delete or correct your personal information. These rights should be exercised in accordance with such applicable data protection laws.
If you wish to exercise the above rights, please make a request to us using the contact information set forth in “10. Contact Information” below. We will promptly handle your request after verifying your identity.
As to the rights of California residents, please see “11. California Privacy Rights” below.
9. Modification to Privacy Policy
We will review this Policy as necessary and make continuous improvements from time to time in order to reflect your feedback or operational changes or to comply with changes in our legal obligations. When we make important changes to this Policy, we will notify you of such changes, if required under applicable law,
we will obtain your prior consent before implementing such changes.
10. Contact Information
If you have any questions, comments or requests regarding this Policy, please contact us at:
General Manager, Mori Building Palo Alto Co., Ltd.
Address： 214 Homer Ave, Palo Alto, CA 94301, USA
TEL：(650) 800-6528
E-mail：contact@jp-innovation-campus.org
11. California Privacy Rights
In addition to the provisions set forth above, the following provisions apply to the processing of personal information of residents residing in the state of California in the United States.
◼ Disclosure and Sale/Sharing of Your Personal Information
We may and have disclosed your personal information to the Japanese Ministry of Economy, Trade and Industry (METI) for the purpose as set in “3. Purposes of the Collection and Processing of Personal Information” above. The categories of personal information we disclose is as described in “Notice at Collection” below. We do not sell your personal information as the term “sell” is traditionally understood.
However, “sell” under the California Consumer Privacy Act (CCPA) is broadly defined, and it includes the sharing of personal information with third parties in exchange for something of value. Accordingly, we treat the disclosure to METI as a “sale” under the CCPA. We do not knowingly sell or share personal information of data subjects under 16 years of age as the Services are provided only for users who are 16 years or older.
In addition, we may and have disclosed your personal information to our service providers or our contractor who process your personal information on our behalf for the purposes described in “3. Purposes of the Collection and Processing of Personal Information” above.
We have not sold, or shared for cross-context behavioral advertising (i.e., behavioral advertising based on personal information collected across multiple websites, applications, etc.), your personal information to the third parties and have no plans to do so in the future.
◼ Notice at Collection
Under the CCPA, you are entitled to certain notice of our practices regarding your personal information. The following is intended to provide you with such notice.
We may collect your personal information and use it for specific purposes. The categories of personal information we collect are identifiers, personal information categories listed in the California Customer Records statute, commercial information, biometric information, and internet or other electronic network activity information. We may and have sold your personal information to METI for valuable consideration.
For the details of personal information that we collect and the purposes for which we use such personal information, please see “2. Personal Information We Collect” and “3. Purposes of the Collection and Processing of Personal Information” above.
For the retention period of your personal information, please see “7. Data Retention”.
◼ Right to Know, Correct and Delete
You will have the following rights, with certain exceptions, under the CCPA:
(1) The right to know what personal information we have collected about you, including:
• The categories of personal information;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting, selling, and sharing personal information;
• The categories of third parties to whom we disclose personal information; and
• The specific pieces of your personal information
(2) The right to delete personal information that we have collected from you
(3) The right to the correction of inaccurate personal information that we maintain about you
(4) The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA
If you wish to exercise any of the rights set forth above, please contact us using the contact information set forth in “10. Contact Information” above.
As required under applicable law, we will take needed steps to verify your identity before responding to your request. We may require you to provide information, depending on the sensitivity of the information you are requesting and the type of request you are making. If you use an agent to submit a request, we will require the agent to provide us with proof that you gave the agent signed permission to submit the request.
◼ Right to Opt-Out of Sale/Sharing
We may sell your personal information for valuable consideration, as shown in “11. California Privacy Rights Disclosure and Sale/Sharing of Your Personal Information”.
Under the CCPA, you have the right to opt-out of our sale and sharing of your personal information. If you are a California resident and you would like us to stop selling and sharing your personal information, you can submit your opt-out request by contacting us at:
General Manager, Mori Building Palo Alto Co., Ltd.
Address： 214 Homer Ave, Palo Alto, CA 94301, USA
TEL：(650) 800-6528
E-mail：contact@jp-innovation-campus.org
◼ Do Not Track signals
Some online services have a “Do Not Track” feature that allows you to send a signal to the online service you use indicating that you do not wish to be tracked. Please note that our Services do not currently support “Do Not Track” signals.
◼ Collection of Personally Identifiable Information by Third Parties
Third parties may not collect “personally identifiable information” about your online activities over time and across different websites when you use this website. Some service providers, however, may collect your personal information on our behalf when you use this website.