Privacy Policy

1. Overall Policy

XCom Global, Inc. (hereinafter referred to as "Our company") believes that it is our social responsibility to protect the personal information of our customers and employees, and in accordance with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act") and other laws and regulations, our company has established and operates a personal information protection management system, and has made a company-wide effort to continuously improve this system. Our company declare that our company will establish and operate a personal information protection management system in accordance with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act") and other laws and regulations, and will make public the following matter.

1. 1. Our company will acquire, use, and provide personal information only to the extent necessary and appropriate. Our company will not use personal information beyond the scope necessary to achieve the specified purposes of use (use for purposes other than those specified), and we will take measures to ensure that this is the case.
2. 2. Our company will comply with the Personal Information Protection Law and other laws and ordinances, government guidelines, and other norms regarding the handling of personal information.
3. 3. Our company will strive to prevent and correct unauthorized access to personal information, as well as leakage, loss, or damage of personal information.
4. 4. Our company will respond appropriately and promptly to complaints and consultations regarding personal information.
5. 5. Our company will continuously improve our personal information protection management system.

2. Use of Personal Information

In regard to our customers' personal information, our company shall make use of it within the range required in order to provide our users with our services (data communication device rental, cell phone rental, clinic business, website and application operation, credit checks for credit card payment and post-payment at convenience stores, confirmation of application to the applying travel agency, information on products and services, implementation of questionnaire surveys, etc.), except when otherwise stipulated by law, etc.
Furthermore, if personal information is being used to send direct mail or for direct marketing, such as telephone marketing, the use of personal information for such activities will cease immediately upon request from the customer.
In addition, our company will handle personal information obtained in accordance with our "Privacy Policy" as below.

1. 1. Purpose of use of personal information in cases where personal information is acquired directly or indirectly other than in writing, etc. (Article 18, Paragraph 1 of the Personal Information Protection Law)

Personal information that our company acquire other than directly in writing, etc., or indirectly, will be acquired for the purpose of business operations that fall into one of the following categories, and will be handled appropriately within the scope of the purpose of use.

Types of Personal Information	Purpose of Use
Customer information acquired by the call center	To provide services and respond to inquiries
Security camera recording information	To protect personal information
Personal information obtained from publicly available and published books, websites, etc.	To provide information on our products, services, and events in the data communication equipment rental, cell phone rental, and clinic businesses
Personal information entrusted by our business partners	To carry out work as instructed by the consignor and to provide information on products, services, and events
Personal information acquired in connection with our research studies or other contracts for the purchase or use of our services	Performance of its contractual rights and obligations and information on the Company's products, services and events
Personal information other than the above	To guide our products, services, and various recruitment activities, and for planning and development

2. 2.Purpose of Use of Personal Information Subject to Disclosure
1. (1) Customers' personal information: In addition to the provisions of the main text of Article 2, for sending products, making payment, sending direct mail, sending e-mail magazines, conducting campaigns, etc., conducting questionnaire surveys, and confirming applications to the applying travel agency.
2. (2) Personal information of our employees: for personnel management, payroll, benefits, labor management, education and training, etc.
3. (3) Personal information of applicants for employment: To contact applicants regarding employment selection, interviews, etc.
4. (4) Personal information of visitors: To protect personal information
3. 3. Voluntary nature of giving personal information, etc.

The provision of personal information is voluntary, but if you do not provide it, the purposes of use described in the preceding paragraph may not be achieved.

3. Appropriate Collection of Personal Information

Our company shall collect customers' personal information required in order to complete the purposes as specified in 2. using appropriate and suitable methods.

4. Provision of Personal Information to Third Parties

1. 1. In addition to the circumstances already agreed upon in 2., our company may provide personal information to a third party under the following circumstances.
1. (1) In the case of receiving from a court an order or a judgement based in law to provide the information, or when receiving an official request to present the information based in legal investigation authority from a public body (including overseas bodies), such as the police.
2. (2) In the case that the customer has, in the use of the services of our company or those of a business partner, contravened applicable laws, terms of service or guidelines, and presentation of the information is required in order to preserve the rights, assets, services, etc. of a third party or the company, and acquiring consent from the customer would be difficult.
3. (3) In the case of an emergency in which a danger is presented to human life, health or assets, etc., and acquiring consent from the customer would be difficult.
4. (4) In the case where the information is provided to a subcontractor with whom our company has concluded a nondisclosure agreement in order to achieve the purpose of use.
5. (5) Any other cases as permitted under law pertaining to personal information.
2. 2. Notwithstanding the preceding paragraph, the following cases shall not fall under the category of third parties
1. (1) Cases in which our company outsources all or part of the handling of personal information within the scope necessary to achieve the purpose of use
2. (2) When personal information is provided as a result of the succession of business due to merger or other reasons
3. (3) Cases in which personal information is used jointly with a specific person, and in which this fact, the items of personal information jointly used, the scope of joint use, the purpose of use by the person using the information, and the name of the person responsible for managing the personal information are notified to the person in advance, or are made readily accessible to the person. or the name of the person responsible for the management of said personal information is made readily accessible to the individual.

5. Acquisition and Provision of Personally Relevant Information*.

1. 1. Our company may acquire the following personally identifiable information from third parties and use it as personal data for the purpose of measuring the effectiveness of advertising conducted in cooperation with third parties and for other purposes specified in the Privacy Policy.
1. (1) Information when you click on an advertisement (date and time of click, source URL, information on using devices and operating systems, etc.)
2. 2. Our company will use the following personally identifiable information about customers provided by affiliate sites in conjunction with the customer information on the Company's site for the purpose of paying commissions to the affiliate sites. Our Company may also provide a portion of customer application information to the relevant affiliate site.
1. (1) Information to identify the affiliate site a customers has visited
2. (2) Information regarding when customers click on the site
3. (3) Information that enables the site to identify customers
4. (4) The amount of money spent by the customer on the site

*Personnally Relevant Informartion
Information about a living individual that does not fall under any of the following categories: personal information, pseudonymized information, and anonymized processed information.

6. Measures for Safe Management

Our company shall create a department specifically for the management of customer's personal information, in order to prevent its loss, unauthorized modification, leakage, etc., and implement all suitable safety and management measures. All members of staff who handle personal information will be trained in the importance of its protection and shall suitably supervise any other parties to whom customer's personal information is entrusted.

7. Disclosure Request Procedures

Our company shall respond suitably and swiftly in regard to all disclosure requests and other procedures as determined by law.

Procedures for Disclosure of Personal Information

1. (1) Please fill out the "Application for Disclosure, etc. of Personal Information" and apply for disclosure, etc.
2. (2) Our company confirms the identity of the applicant based on the personal information in our possession.
3. (3) In principle, the application must be made by the person himself/herself. In the case of an inquiry from a representative, our company will confirm the representative's identity with a letter of attorney and proof of seal impression, but our company may refuse to disclose the information.
4. (4) Inquiries are accepted by mailing the "Application for Disclosure of Personal Information, etc." form to the following address for sending the form.
5. (5) If customers want to request notification or disclosure of the purpose of use of their personal information, please pay a handling fee of 1,100 yen per request in the form of postage stamps. Please enclose the fee when sending the documents to be submitted.
6. (6) Personal information received on the "Application for Disclosure of Personal Information" form will be used to contact the customer who made the inquiry. It will not be used for any other purpose.

Please download the "Application for Disclosure of Personal Information" from the link below.
＞ Application for Disclosure of Personal Information(PDF 55KB)

(Contact for sending application forms)
XCom Global, Inc.
Customer Inquiries Regarding Personal Information
Shibuya Scramble Square 26F 2-24-12 Shibuya Shibuya-ku,Tokyo JAPAN 150-6126

8. Changes to the Privacy Policy

1. 1. The contents of this Privacy Policy may be changed without notice to users.
2. 2. Unless otherwise specified by our company, the revised Privacy Policy shall become effective from the time it is posted on this website.

9. Inquiries

Our company shall respond suitably and swiftly in regard to all opinions and requests relating to the handling of personal information.
If customers have any opinions, requests, inquires or complaints regarding our handling of personal information or our safety and management measures, please contact the address as shown below.