Japan Privacy Notice
Japan Privacy Policy
ComPsych Corporation with its principal place of business located at 455 N. Cityfront Plaza Dr., NBC Tower, 13th FL., Chicago, IL, U.S.A. and whose CEO Paul Posey along with its Global Partner in Japan, Work Way, Inc. located at 1-7-8 Sendagaya, Shinjukuku, Tokyo, 151-0051 Japan and whose CEO is Shinya Hanada (the “Company”, “we”, “our” or “us”) complies with laws and regulations regarding the protection of personal information, and the handling of your personal information appropriately. This Policy addresses our policy on how we handle your personal information in connection with the use of our EAP (Employee Assistance Program) as service users (“Users”). The definitions of terms in this policy are the same as those in the Act on the Protection of Personal Information (APPI) unless there is a specific definition in this policy.
Article 1: Acquisition and use of personal information
We may acquire and collect your personal information including sensitive personal information, (e.g., health/medical conditions), if you voluntarily provide it while receiving EAP services. When using ComPsych’s website, you acquire services directly from ComPsych, who offers them from the United States. By interacting with our website you choose to share your information, including sensitive personal information, to be stored or otherwise processed in servers and databases located in the United States.
When using services provided Work Way, in Japan, your personal information, including sensitive personal information, will be stored or otherwise processed in servers and databases located in Japan.
We will acquire and collect your personal information by proper means, and use your personal information legitimately. In addition, we will not use personal information for purposes other than the purposes specified in this privacy policy unless the applicable law (including the APPI) permits. We will provide or disclose it to a third party subject to requirements to the extent the applicable law (including the APPI) applies.
Article 2: Compliance with laws and norms regarding personal information protection
We will comply with applicable laws and regulations regarding the personal information we hold, guidelines set by the government, and other norms.
Article 3: Management and protection of personal information
We will take reasonable safety measures against risks such as unauthorized access, loss, destruction, falsification, and leakage of personal information, and regularly review and correct them.
Article 4: Disclosure of your personal data
We may share your personal data with the third parties entrusted by us to provide our EAP service with your consent
Article 5: Response to complaints and consultations
To request notification, disclosure, correction, addition, deletion, use or suspension of personal information, to claim a complaint or to have a consultation, it is necessary to follow the procedures prescribed by the Company.
Article 6: Continuous improvement of personal information protection management system
We will identify the person in charge of protecting personal information, carry out in-house education and continuously review and improve the management system.
Contact for inquiries regarding personal information protection policy and complaints / consultation regarding personal information
If you have further queries relating to our Privacy Policy, or you have a problem or complaint related to use of ComPsych’s website please contact our Privacy Official at [email protected]
If you have further queries relating to our Privacy Policy, or you have a problem or complaint related to services provided in Japan contact WorkWay’s Privacy Official at [email protected].
Purpose of use of personal information
We will handle personal information of the Users for the following purposes:
- To provide Users with EAP services;
- To personalize the Users’ experiences to use our EAP service;
- To provide information on user support including making referrals to User;
- For communication with the Users including response to inquiries from you;
- For data security management including the Users’ personal information;
- To improve our products and services, conduct internal business analyses, assess product use and completion rates, and
- To comply with applicable law.
Query on your Personal Data
- Where to make complaints regarding the handling of retained personal data
If you have further queries relating to our Privacy Policy, or you have a problem or complaint related to use of ComPsych’s website please contact:
ComPsych Corporation
Attn: Privacy Official
455 N. Cityfront Plaza Dr., NBC Tower, 13th Fl.
Chicago, IL, U.S.A. 60611
(312) 660-1076
If you have further queries relating to our Privacy Policy, or you have a problem or complaint related to services provided in Japan contact:
WorkWay, Inc.
Attn: Privacy Official
1-7-8 Sendagaya, Shibuya-ku,
Tokyo 151-0051 Japan
- Procedures Regarding your Personal Data
Regarding our retained personal data, you can request notification of purpose of use, disclosure, correction, addition or deletion of content, suspension of use, erasure, and suspension of provision to third parties (disclosure, etc.). Please send an email to the appropriate contact listed below:
For requests related to use of ComPsych’s website please contact:
ComPsych Corporation
Attn: Privacy Official
455 N. Cityfront Plaza Dr., NBC Tower, 13th Fl.
Chicago, IL, U.S.A. 60611
(312) 660-1076
For requests related to services provided in Japan contact:
WorkWay, Inc.
Attn: Privacy Official
1-7-8 Sendagaya, Shibuya-ku,
Tokyo 151-0051 Japan
The requestor will be required to confirm their identity, and if a third party is requesting the information, they will be required to also confirm their authority to receive your information. If you are the requestor identifying documents will be required (e.g., driver’s license, passport, etc.). If your agent is the requestor, documents certifying the relationship between you and the agent and proof of the agent’s authorization to make the request will be required (e.g., power of attorney stating that “the authority to receive the results of disclosure, etc. is delegated” to the agent).