1. Definition of Personal Data
Personal Data means information, whether true or not, about an individual who can be identified from the data, or from that data and other information to which the organization has or is likely to have access to (“Personal Data”).
2. Collection and Use of Personal Data
(1) Collection of Personal Data
Forit shall inform you of the purposes for the collection, use or disclosure of the Personal Data on or before collection and will make reasonable security arrangements to manage your Personal Data to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. The Personal Data that we shall collect is limited to the extent necessary for our purposes of use specified in (2) and (3) below.
(2) Behavioral Targeting Advertising
(3) Use of Personal Data
Forit shall use the Personal Data for the following purposes with respect to the provision of Webridge services. Webridge is an overseas affiliate program operated by Forit, through which (among other things) it connects the platforms operated by advertisers and publishers, allowing users of the publishers’ platform to be redirected to the advertisers’ platform and/or contact the advertisers. The Personal Data owned by Forit will not be used outside the scope of the purposes below unless permitted by applicable laws and regulations.
- Performing obligations in the course of or in connection with our provision of Webridge services;
- Verifying your identity;
- Communicating changes or suspension to Webridge services;
- Processing of payment and credit transactions for the provision of Webridge services, and Transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
- Sending you information on the Webridge services to be provided.
- Research and development of new products and services;
- Development, operation and maintenance of Webridge operating facilities and accompanying facilities;
- Marketing research and other research;
- Proving updates on new products and promotions, including but not limited to rewards and campaigns schemes;
- Response to requests for disclosure under applicable laws and regulations;
- Replying to your inquiries, requests, applications, complaints and feedback from you; or
- Any other incidental business purposes related to or in connection with the above.
3. Secure Management of Personal Data
(1) Forit shall take necessary and appropriate security measures to prevent any unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks to your Personal Data.
(2) Forit shall establish an internal system to prevent any unauthorized access to Personal Data, establish rules on information security, and provide employees with the necessary and appropriate training to ensure that they are thoroughly familiar with the handling of Personal Data.
4. Provision of Personal Data to Third Parties outside of Your Country
(1) Forit shall take appropriate steps to ensure that the overseas recipient is bound by legally enforceable obligations so as to provide to your transferred Personal Data a standard of protection that is at least comparable to that under applicable laws.
(2) Forit shall not provide or disclose your Personal Data to third parties outside of your country without your consent, except for the permitted situations below:
- you are expressly informed of the intended transfer of your Personal Data to the recipient, and you consent to such transfer;
- the transfer of the Personal Data to the recipient is necessary for the performance of a contract between you and us, or to do anything at your request with a view to you entering into a contract with us;
- the transfer of the Personal Data to the recipient is necessary for the conclusion or performance of a contract between us and a third party which is entered into at your request;
- the transfer of the Personal Data to the recipient is necessary for the conclusion or performance of a contract between us and a third party if a reasonable person would consider the contract to be in your interest;
- the transfer of Personal Data to the recipient is permitted under applicable laws, and we have taken reasonable steps to ensure that the Personal Data so transferred will not be used or disclosed by the recipient for any other purpose;
- the Personal Data is data in transit; or
- the Personal Data is publicly available.
5. Compliance with relevant laws
Forit shall comply with all applicable laws and regulations on Personal Data.
6. Disclosure, Correction and Cease of use of Personal Data
(1) Subject to applicable laws, Forit shall provide information on your Personal Data in its possession and the ways in which your Personal Data has been or may have been used or disclosed by Forit within a year since the date of your request, within a reasonable time upon the receipt of your written request to our Personal Data Protection Officer.
(2) Subject to applicable laws, Forit shall make corrections to your Personal Data if deemed appropriate to, and send the corrected Personal Data to all organisations to which the previous Personal Data was disclosed to within the past year, within a reasonable time upon the receipt of your written request to our Personal Data Protection Officer.
(3) Subject to applicable laws, Forit shall cease collecting, using or disclosing your Personal Data within a reasonable time upon the receipt of your written request to our Personal Data Protection Officer and upon receipt of further confirmation of your request despite being informed by our Personal Data Protection Officer of the likely consequences of withdrawing your consent for the collection, using or disclosing of your Personal Data.
7. Accuracy of Personal Data
Forit shall rely on personal data provided by you. Please update us on changes to your Personal Data by submitting a written notice to our Data Protection Officer so that we may ensure that your Personal Data is up to date.
8. Retention of Personal Data
Subject to applicable laws, Forit shall only retain your Personal Data for as long as necessary to fulfil the purpose for which it was collected.
9. Contact information of Personal Data Protection Officer
Name: [HIROKI FUJIMURA]
Postal Address: 9th floor E-Space Tower, 3-6, Maruyamacho, Shibuya-ku, Tokyo 150-0044 Japan
For it Inc.
9th floor E-Space Tower, 3-6, Maruyamacho, Shibuya-ku, Tokyo 150-0044 Japan
Tel: +81 3-5728-5865
Monday to Friday
Regular holidays: Saturday and Sunday/National holidays (under holiday laws)/Year-End and New Year holidays
Effective date: [December 1] 2019