OGIS-RI's Privacy policy based on CCPA

LAST UPDATE:2023.4.3

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA"), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months:

(1) We collected the following categories of Personal Information:

  1. Identifiers, such as name, contact information, online identifiers, and government-issued ID numbers;
  2. Personal information, as defined in the California customer records law, such as name, contact information, government-issued ID numbers, signature, payment card number, financial information, medical information, insurance information, education information, and employment information;
  3. Protected classifications under California or federal law, such as sex, age, marital status and race;
  4. Commercial information, such as transaction information, purchase history, financial details and payment information;
  5. Biometric information, such as fingerprints and voiceprints;
  6. Internet or network activity information, such as browsing history, online behavior, internet data and interactions with our and other websites;
  7. Geolocation data, such as device location and IP location;
  8. Audio, electronic, visual, thermal, olfactory, and similar information, such as images and audio, call and video recordings created in connection with our and our clients' business activities.
  9. Professional or employment-related information, such as work history and prior employer;
  10. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records; and
  11. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual's preferences and characteristics.

We collect this Personal Information from you, our subsidiaries, our clients and our service providers.

We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; in our surveys, to confirm the appropriateness of the subjects of such surveys, to conduct analytics, analyze, and process the data obtained, and to prepare the results of such surveys; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

When we collect or use sensitive Personal Information, we will notify you separately.

We disclose this Personal Information to our clients, our service providers and authorized third parties.

(2) We retain the Personal Information for as long as is necessary to operate, manage, and maintain our business, to provide our products and services, and to achieve our business purposes. We determine the retention period based on these considerations, as well as the length of time the information must be retained to comply with legal obligations and to exercise your right to delete personal information.

(3) We disclosed the following Personal Information to the above third parties for our operational business purposes:

  1. Identifiers, such as name, contact information, online identifiers, and government-issued ID numbers;
  2. Personal information, as defined in the California customer records law, such as name, contact information, government-issued ID numbers, signature, payment card number, financial information, medical information, insurance information, education information, and employment information;
  3. Protected classifications under California or federal law, such as sex, age, marital status and race;
  4. Commercial information, such as transaction information, purchase history, financial details and payment information;
  5. Biometric information, such as fingerprints and voiceprints;
  6. Internet or network activity information, such as browsing history, online behavior, internet data and interactions with our and other websites;
  7. Geolocation data, such as device location and IP location;
  8. Audio, electronic, visual, thermal, olfactory, and similar information, such as images and audio, call and video recordings created in connection with our and our clients' business activities;
  9. Professional or employment-related information, such as work history and prior employer;
  10. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records; and
  11. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual's preferences and characteristics.

(4) We have not "sold" or "shared" Personal Information:

For purposes of this Privacy Policy, "sold" or "sale" means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

"Shared" or "share" means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

(5) If you are a California resident, you may request that we:

  1. Disclose to you the following information covering the 12 months preceding your request:
    • ・The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
    • ・The specific pieces of Personal Information we collected about you;
    • ・The business or commercial purpose for collecting Personal Information about you;
    • ・The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
  2. Correct inaccurate Personal Information that we maintain about you.
  3. Delete Personal Information about you which we collected from you.
  4. Limit the use of your sensitive Personal Information.
  5. Refrain from unlawful discrimination against you for exercising your rights under the CCPA.

In some instances, we may decline to honor your request where the law does not apply or where an exception applies. We will respond to your request consistent with applicable law. Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under CCPA.

How to Make Requests

If you are a California resident, you may make a request about your rights described above by contacting us at:

(1) toll free number: 1-833-456-5298; or

(2) https://www.ogis-ri.co.jp/forms/inqform_kre.html.

Changes to this notice

We may change or update this notice from time to time. When we do, we will provide you will the revised notice.

Revision history

2023.4.3  : The CCPA, as amended by the California Privacy Rights Act of 2020, and our  processing of personal information about California residents that we have collected or disclosed within the past 12 months have been reflected in this Privacy Policy.

2022.2.10 : The call number has changed (How to Make Requests).

2021.11.1 : The details of the procedure requesting regarding personal information has changed (How to Make Requests).

2020.7.10 : First Edition has released.