- Personal Information Protection Policy
- Policy on Protection and Handling of Personal Information
- Personal Data Breach Hotline
Policy on Protection and Handling of Personal Information
Global Mobility Service Inc. (“GMS” or “we”) believes that, in order that you, our customers, will feel safe and secure when using our products and services, proper protection of your personal information constitutes an important social duty that GMS owes. Therefore, GMS will make sure that your personal information is protected and handled as set out below in accordance with GMS’s Personal Information Protection Policy:
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1Purpose of Using Personal Information GMS Has Obtained
GMS will use your personal information GMS has obtained within the scope of the purposes listed below:
(1)To plan, research, develop, and provide products and services that GMS are currently providing or will provide in the future using the history of your application information, location information and other information and your payment status, including machine operations to locate vehicles and start and control the engine, and other relevant machine operations;
(2)To send you newsletters or direct mail related to the products and services described in item (1) above;
(3)To research, check, analyze the usage status and other related conditions of the products and services described in item (1) above, and to improve and enhance the quality and provision system of those products and services and other related matters;
(4)For consumer trends surveys, customer satisfaction surveys and other marketing activities;
(5)To communicate with you when necessary, including responding to your inquiries and making important announcement;
(6)To conduct analysis for securing assets GMS’s business partners have, such as vehicles for which GMS has given them a loan;
(7)To make credit decisions and to control vehicles in question after credit decisions has been made for those vehicles, including machine operations to locate those vehicles and stop the engine, and other relevant machine operations;
(8)To conduct analysis for improvement and development of the social environment related to vehicles;
(9)To calculate the credit scoring logic by analyzing action history and related information and to apply and process the scoring logic; and
(10)To provide the personal information to financial institutions, leasing companies, security companies and other companies that conduct fintech business in partnership with GMS.
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2Provision of Information to Contractors
GMS may engage a GMS Group company or third-party contractor to handle various kinds of personal information to the extent necessary to accomplish the purposes listed above in “1. Purpose of Using Personal Information GMS Has Obtained.” In that case, GMS will take appropriate security control action by way of this Policy on Protection and Handling of Personal Information (this “Policy”) or a relevant contract or agreement.
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3Sharing Information among Group Companies
In order that GMS Group offers more attractive products and services to our customers, information obtained by and in the possession of a GMS group company is shared and used among GMS Group companies. Therefore, GMS may share with other GMS Group companies various kinds of information that GMS has obtained with respect to the products and services provided by GMS. If GMS shares information with other Group companies, GMS will take appropriate security control action by way of this Policy.
(1)Purpose of sharing information: As listed above in “1. Purpose of Using Personal Information GMS Has Obtained”
(2)Scope of sharing information: To the extent that information is shared with GMS Auto GK
(3)Person in charge of managing information shared: Global Mobility Service Inc.
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4Provision of Information to Third Parties
GMS will never provide your personal information to third parties without your prior consent unless permitted by law or stipulated in this Policy.
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5Pseudonymized Information
GMS may create pseudonymized information regarding an individual by processing that individual’s personal information GMS has obtained so as not to identify that individual unless matched against other information while taking measures for pseudonymization prescribed by law, and may use such pseudonymized information. If GMS creates pseudonymized information, GMS will:
1.process the original information appropriately in accordance the standard prescribed by law;
i.For personal information that falls under item (i), paragraph 1, Article 2 of the Act on the Protection of Personal Information (information regarding an individual that contains his/her name, date of birth, or other descriptions by which he/she can be identified, including information that can be readily matched against other information thereby enabling him/her to become identifiable): delete part of those descriptions contained in the personal information in question (or replace part of those descriptions with other descriptions using a method that does not have any regularity that enables that part of descriptions to be restored); and
ii.For personal information that falls under item (ii), paragraph 1, Article 2 of the Act on the Protection of Personal Information (information containing individual identification codes, such as vehicle number): delete all the individual identification codes contained in the personal information in question (or replace those individual identification codes with other descriptions using a method that does not have any regularity that enables those individual identification codes to be restored);
2.take action for security control of deletion information and other related information in accordance with the standard prescribed by the Rules of the Personal Information Protection Commission as the standard necessary for preventing leakage of such deletion information and other related information;
3.never handle pseudonymized information, which is limited to personal information only, unless required by law or beyond the scope necessary for accomplishing the defined purpose of use;
4.make public what items are included in pseudonymized information GMS has created;
5.strive to delete pseudonymized personal data, deletion information and other related information without delay if GMS no longer needs to use those data and information;
6.never provide third parties with pseudonymized personal data unless required by law;
7.never match the original personal information of any individual against other information in order to identify that individual; and
8.never use contact information contained in pseudonymized information for the purpose of making contact.
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6Anonymously Processed Information
GMS may create anonymously processed information (information regarding an individual that is produced by processing that individual’s personal information while taking action prescribed by law so as neither to be able to identify that individual nor to be able to restore that personal information) by deleting all or part of individual identification codes, such as vehicle number, and travel history from personal information that GMS has obtained, and may use such anonymously processed information. If GMS creates anonymously processed information, GMS will:
1.process the original information appropriately in accordance the standard prescribed by law;
2.take security control action to prevent leakage of deleted information and information about the processing method in accordance the standard prescribed by law;
3.make public what items are included in anonymously processed information GMS has created; and
4.never match the original personal information of any individual against other information in order to identify that individual.
If GMS provides anonymously processed information to a third party, GMS will make public what individual-related items are included in that anonymously processed information and how GMS provides that information, and explicitly tell the third party that the information GMS is going to provide to the third party is anonymously processed information.
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7Handling of Individual-Related Information Collected from Equipment Installed on Vehicles with GPS
7.1GMS will collect Individual-Related Information (as defined in the Act on the Protection of Personal Information) from the equipment installed on a vehicle with the GPS system, including the location of that vehicle. GMS will use Individual-Related Information so collected to the extent GMS accomplishes the purpose defined in Section 1 above.
7.2If GMS no longer needs to use your Individual-Related Information, GMS will strive to delete your Individual-Related Information, deletion information and other related information without delay.
7.3If GMS provides your Individual-Related Information to a third party, GMS will confirm that that third party has obtained your consent for obtaining your Individual-Related Information from an Individual-Related Information Handling Business Operator (as defined in the Act on the Protection of Personal Information) as personal data by which you are identifiable. In addition, GMS will keep a record of such provision to a third party.
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8Handling of Personal Related Information on GMS Website
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8.1Use of Log Information
If you access GMS website, GMS records your access log, which contains the IP address sent from your browser to GMS, the name of your browser, your language, the length of time for which you access GMS website, the address of the website you visited from and other information. GMS also may obtain information on the pages you visited on GMS website and what else you did on GMS website. Further, by using website technologies, GMS may obtain information as to whether you opened our email or clicked a link in our email. Using these techniques, GMS will obtain statistics on how GMS website is used and how effective GMS website is, thereby tailoring the content on GMS website to your possible preference, narrowing down the content of email GMS will send you so that any content that seems unnecessary or irrelevant to you is removed, and making GMS website easier-to-use.
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8.2Obtaining and Using Unidentifiable Attribute Information and Activity History
GMS uses cookies as reference information that tells us how you are using our services provided through GMS website, thereby improving the quality of our services and offering you services more relevant to your preference and needs.
Further, GMS website uses Google Analytics, a service provided by Google which enables GMS to learn how GMS website is used. Google Analytics analyzes how you use GMS website, by using the cookies generated by GMS website. GMS receives from Google the results of such analytics, including user attributes and interests categories, through which GMS learns how you use GMS website.
Google manages your information collected, recorded and analyzed by Google Analytics, in accordance with Google privacy policy. For details about Google Analytics terms of service, visit Google Analytics website. For details about Google privacy policy, visit Google website:
- Google Analytics Terms of Service
- How Google uses information from sites or apps that use our services
- Google Privacy Policy
If you want to disable Google Analytics, go to Google Analytics Opt-out Browser Add-on page and download and install the add-on for your web browser. If you have disabled Google Analytics, Google Analytics is still disabled on any websites you visit, in addition to GMS website. You may enable the add-on again by change the add-on setting for your web browser.
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9Revision of this Policy
This Policy is subject to change depending on any change in the purpose of using personal information, security improvement, revision of applicable laws, ordinances or regulations or for any other reason. You are requested to regularly review this Policy on GMS website or similar documents.
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10Contact Information
Please refer to this page for confirmation, disclosure, correction, suspension of use, and deletion of your personal information and other similar requests.
Established on January 20, 2021
Revised on March 16, 2022
Tokushi Nakashima, President/CEO
Global Mobility Service Inc.