Last Updated and Effective: September 24, 2024
Updated: September 4, 2023
Updated: April 6, 2023
Updated: January 12, 2023
Updated: April 1, 2022
Updated: November 1, 2021
Updated: July 16, 2020
Updated: January 14, 2020
Updated: October 31, 2018
Updated: May 25, 2018
First Published: March 4, 2016
Introduction. The purpose of this privacy policy (“Privacy Policy”) is to describe how VisasQ Inc. and its affiliated companies, including Coleman Research Group, Inc. (“Company” or “we” or “us”) collects, uses, and shares information about you generally, including through Company’s online interfaces (e.g., websites and online portals) owned and controlled by us, including https://visasq.co.jp and https://service.visasq.com; https://www.colemanrg.com (collectively referred to herein as the “Site”; all such data “Personal Data”), and our services (“Services”).
We may modify this Privacy Policy and if any material changes are made to it, we will provide notice through our Services or by other means to provide you the opportunity to review the changes before they become effective.
You acknowledge that your continued use of the Site after we publish or send a notice about our changes to this Privacy Policy means that the collection, use, and sharing of your Personal Data is subject to the updated Privacy Policy.
Terms that are used but not defined in this Privacy Policy shall have the same meaning ascribed in the Integrated Terms and Conditions: https://service.visasq.com/term_en .
Data this Privacy Policy Covers. This Privacy Policy covers Personal Data, including through our Site. Some of our Site’s functionality can be used without revealing any Personal Data, though for some features, Personal Data is required. In order to access certain features on our Site, you may need to submit or we may collect Personal Data. Personal Data does not include information that is anonymized.
Personal Data We Collect Provided Directly by You or by Third Parties. We may collect Personal Data about you from the following sources:
How We Use Your Personal Data. We may use your Personal Data for various purposes, subject to applicable law, including to:
From time to time, we may use your e-mail address and/or phone number to send you information and keep you informed of products and services in which you might be interested. You may at any time elect to stop receiving such communication. Your contact information may also be used to reach you regarding issues concerning your use of the Site, including changes to this Privacy Policy.
How We May Share Personal Data. We may, for legitimate business purposes, by contractual necessity, and/or with your prior, express consent, or in compliance with applicable law, disclose your Personal Data to other parties, including:
If we engage a third party to process your Personal Data, that party will (i) only process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.
Categories of Personal Data we may Process. We may process the following categories of Personal Data about you:
Categories of Sensitive Personal Data we may Process: We may process the following categories of Sensitive Personal Data about Experts:
Subject to individual consent, the Company may collect the above-listed categories of sensitive personal data and disclose the sensitive personal data to its third-party identity verification vendor in order to provide the Services. Sensitive personal data may be collected and disclosed as part of the registration, identity verification, and fraud prevention processes and, if collected or disclosed, will be used exclusively for the purposes of facilitating those processes or as otherwise required by applicable law. For more information on how our third-party partner processes sensitive personal data, visit https://withpersona.com/legal/privacy-policy. The Company prohibits any further disclosure or re-disclosure of biometric data unless the individual consents to the disclosure or as otherwise required by law. The Company does not sell sensitive personal data.
This Privacy Notice for EEA and UK Residents supplements and should be read in conjunction with the information contained in the Company’s Privacy Policy and applies solely to Site visitors, users of or participants in our Services, and others who reside in the EEA or UK. The Company is the data controller with respect to your Personal Data (“Controller”). The Controller is the entity that determines how and why Personal Data are processed. The Company retains your Personal Data until either it is no longer necessary for the purpose for which it was collected, you withdraw consent to process your data, or no other legal basis for processing exists. The Company’s head office address is Sumitomo Fudosan Aobadai Hills 9F, 7-7, Aobadai 4-chome, Meguro-ku, Tokyo, 153-0042 Japan, and you can contact the Company via e-mail at [email protected].
Legal Basis for Data Processing. As explained above, we use your Personal Data in various ways depending on your use of the Site and/or participation in the Services. We may process your Personal Data in reliance upon one or more of the following legal bases, depending on the circumstances: (1) with your consent; (2) as necessary to perform our agreement to provide the Services; (3) where required by applicable law; (4) where necessary to protect the vital interests of any individuals; or (5) where we have a legitimate interest.
Transfers of Personal Data. Personal Data we collect may be transferred to, and stored and processed in, Japan, the United States or any other country in which we, our affiliates, or third parties with whom we engage in order to provide our Services maintain facilities. We will ensure that transfers of Personal Data to a third country or an international organization are subject to appropriate safeguard as described in Article 46 of the General Data Protection Regulation.
Right to Access and Correct Personal Data. You can access your Personal Data and confirm that it remains correct and current by logging into the Site or sending an e-mail to us. You have the right to request access to your Personal Data and to receive a copy of your Personal Data, as well as certain information about our processing activities with respect to your Personal Data. You have the right to request correction or completion of your Personal Data if it is inaccurate or incomplete. You have the right to restrict our processing if you contest the accuracy of the data we hold about you, for as long as it takes to verify its accuracy. If you are a current Company Client or a current Member of our expert network and would like a copy of your Personal Data, please log in to the Site and click on the ‘Personal Data’ link at the bottom of the page and follow the instructions; or, if the “Personal Data” link is not available in the Site you are using, send an email to: [email protected]. If you are not a current Company Client or a current Member of the Company’s expert network and would like a copy of your Personal Data, please also send an e-mail to the same email address.
Right to Personal Data Portability. Where technically feasible, you can request that your Personal Data be transmitted directly from the Company to another data controller in a structured, commonly used, and machine-readable format. If you would like to request your Personal Data to be ported, please log in to the Site and click on the ‘Personal Data’ link at the bottom of the page and follow the instructions. If the “Personal Data” link is not available in the Site you are using or you are not a current Company Client or a current Member of the Company’s expert network and would like a copy of your Personal Data, please send an e-mail to: [email protected].
Right to Request Data Erasure. You have the right to have your data erased from our Site if (i) the data is no longer necessary for the purpose for which it was collected, (ii) you withdraw consent and no other legal basis for processing exists, or (iii) you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing. Your Personal Data will generally be erased from the Site without undue delay and will be anonymized in order to be able, if necessary, to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Integrated Terms and Conditions or agreements, or fulfill your request to “unsubscribe” or “opt out” from further messages from us. If you would like to request the erasure of your Personal Data from our Site, please log in to the Site and click on the ‘Personal Data’ link at the bottom of the page and follow the instructions or, if the “Personal Data” link is not available in the Site you are using, send an e-mail to: [email protected].
Right to Withdraw Consent. Where we process your Personal Data on the basis of your consent, you have the right to withdraw consent. If you would like to withdraw your consent to the processing of your Personal Data, please send an e-mail to: [email protected].
Right to Lodge Complaint. You have the right to lodge a complaint with the appropriate relevant data protection supervisory authority in your EEA country of residence, found here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
This Privacy Notice for California Residents supplements the information contained in the Company’s Privacy Policy and applies solely to Site visitors, users of or participants in our services, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) (collectively referred to in this policy as “CCPA”). Any terms defined in the CCPA will have the same meaning when used in this notice.
Information We Collect. The Company collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("Personal Information"). The Company collects information from the following Personal Information categories listed in the California Customer Records statute described below (Cal. Civ. Code § 1798.80(e)). The Company’s Site has collected the following categories of Personal Information from its consumers within the last twelve (12) months:
| Category | Examples |
|---|---|
| Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, or other similar identifiers. |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, and bank account number. Some personal information included in this category may overlap with other categories. |
| Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| Biometric Information | Imagery of the iris, retina, face, or similar, from which an identifier template, such as a faceprint can be extracted. |
| Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
| Professional or employment-related information | Current or past job history. |
| Education Information | Educational information that is not publicly available. |
| Geolocation | Precise geolocation derived from the device an individual is using. |
Right to Limit Use and Disclosure of Sensitive Personal Information
You have a right to limit the Company’s use of your Sensitive Personal Information for any purposes other than for the provision of the Services or as otherwise permitted by law. The Company does not use Sensitive Personal Information for any other purposes.
The Company obtains the categories of Personal Information listed above from the following categories of sources:
Personal Information does not include:
Use of Personal Information. In addition to the stated uses set forth above, we may use, or disclose the Personal Information we collect for any purpose described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
Sharing of Personal Information. The Company may disclose your Personal Information to third parties for purposes consistent with the business purpose for which it was collected. In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:
Retention and Opt-Out Procedures. By participating in the Company’s services, you will be prompted to agree to the Company’s Privacy Policy and the terms of sharing of your Personal Information. To exercise your right to opt out, simply notify us of your request(see Exercising Access, Data Portability, Correction, and Deletion Rights). The Company will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account with the Company is active, or as needed to provide our services to you. If you no longer want the Company to use your information to provide our Services to you, you may notify us and close your account. In the event that you no longer want the Company to use or share your information for the purposes of providing our Services to you, and you provide us notice of such request (see Exercising Access, Data Portability, Correction, and Deletion Rights), the Company will retain and use your information only to the extent necessary to comply with our legal obligations. In addition, third parties who were given access to your information as necessary for the provision of our Services may retain and use your information to comply with their own legal obligations.
Sale of Personal Information. In the preceding rolling twelve (12) months, the Company has not sold Personal Information.
Your Rights and Choices Related to Personal Information. The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights. You have the right to request that the Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Correction, and Deletion Rights), we will disclose to you:
Correction of Inaccurate Personal Information. You have the right to ask us to correct inaccurate or incomplete Personal Information about you. Upon our receipt of your verifiable consumer request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the inaccurate Personal Information as directed by you.
Deletion Request Rights for Personal Information. You have the right to request that Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Correction, and Deletion Rights), we will delete your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, Correction, and Deletion Rights. To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Request Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
This Privacy Notice for Japan Residents, including the Cookie Policy, supplements the information contained in the Company’s Privacy Policy and applies solely to Site visitors, users of or participants in the Services, and others who reside in Japan ("consumers" or "you"). We adopt this notice to comply with the Act on the Protection of Personal Information, Act No. 57 of 2003, Japan (the "Personal Information Protection Act") and any terms defined in the Personal Information Protection Act will have the same meaning when used in this notice.
We may collect the following Personal Information (as defined in our Integrated Terms and Conditions). Channels for collecting Personal Information described in 1.i., 1.ii., and 1.iii. below includes your provision to us and our acquisition of information which was made public by yourself on sources as the internet.
We identify purposes of the collected Personal Information as follows.
We are not contracted for the purpose of processing Personal Data for other individuals or entities.
We may engage third party service providers to process Personal Data to the extent necessary to achieve any of the purposes above on our behalf and in accordance with our instructions and supervision in order to ensure Personal Data is safely and properly processed and managed.
With respect to the handling of Personal Data, we may use external services, such as cloud services, provided by a third party (including a third party in a foreign country). In this case, if we can confirm (i) that it is stipulated in the agreement with such external services provider or other rules of such provider including terms of use that such provider will not handle Personal Data and (ii) that such provider implements proper access control, then we will handle Personal Data deeming that such case does not fall under third-party disclosure or entrustment. Even in such case, we will implement the actions provided in “7. Security management of Personal Data.”
We will not provide Personal Data to any third party in Japan without obtaining the prior consent of its owner except as set forth below. Further, we will not provide Personal Data to any third party in any foreign country without obtaining the prior consent of its owner except as set forth in 5.i. through 5.vii., 5.ix and 5.x. below.
In addition, we may disclose information in a form where it is impossible to identify individuals such as statistical data.
In case of providing Personal Data to a third party in a foreign country, please check https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku to confirm the information of the regulations regarding the protection of Personal Data in the countries or regions in which a third-party who receives Personal Data is located. Such Foreign countries include the following:
We jointly use Personal Data as follows:
We will keep Personal Data accurate and up-to-date to the extent necessary to achieve any of the purposes above, and will strive to delete Personal Data without delay which we no longer need to use.
In addition, in order to prevent unauthorized access to Personal Data, from loss, damage, falsification, and leakage, we will implement necessary measures such as maintenance of security systems, development of management systems, and thorough employee education, and safety measures to strictly control Personal Data.
Details of safety management measures are as follows.
In order to ensure the proper handling of Personal Data, “Handling of personal information” was established as a basic policy for "compliance with relevant laws and guidelines" and "consultation and complaint inquiries regarding personal information."
Establishment of Personal Information Handling Regulations and Safety Management Regulations that stipulate handling methods, persons in charge, and their duties at each stage of acquisition, use, storage, provision, deletion, disposal, etc. of Personal Data.
In the case that the country to which the Personal Data is transferred is a country that does not have a personal information protection system that is equivalent to that required in Japan, we will grasp the personal information protection system in such country and implement necessary security management measures.
The purposes of Personal Data in our possession are the same as described in “2. Purposes” above.
We will respond to request by you or your agent, with respect to Personal Data in our possession, of notification, disclosure or change etc. (correction of contents, addition or deletion) of the purposes, stop of usage etc. (stop of usage or deletion,) and stop of provision to a third party in accordance with laws. Please email us at: [email protected]. When you request the procedure above, please provide us with the followings to verify your or your agent’s identity:
We will charge you JPY 1,000 for notification of purposes or disclosure request per request. Please pay to the bank account designated by us. Bank transfer fee for such payment shall be paid by you. In the case of requests which require a lot of our work, we may charge you extra fee subject to our prior fee quotation.
We may use Cookies for the purpose of identifying users. For details of information of your use of the Site, which we obtain through the use of Cookies (“Cookie Information”), the purpose of using Cookie Information (including third party Cookies), and other details, please refer to our Cookie Policy. Cookie Information may be tied to the above-mentioned Personal Information. The purpose of using Cookie Information when tied to Personal Information is handled in accordance with the above-mentioned purpose in addition to the use described in Cookie Policy.
This Privacy Policy applies to the handling of Personal Information in the Services. This Privacy Policy does not apply to handling of Personal Information on third party websites and services which are linked from the Services. We are not responsible or liable for handling of Personal Information on third party websites and services.
VisasQ Inc.
Please refer to this page for the representative and address: https://corp.visasq.co.jp/en/company/base
Legal and Compliance; Personal Data Protection Administrator.
Please contact Personal Information Complaint Consultation Desk below for any opinions, questions, objections, complaints, or other inquiries regarding Personal Information.
Personal Information Complaint Consultation Desk
Sumitomo Fudosan Aobadai Hills 9F,
4-7-7 Aobadai, Meguro-ku, Tokyo 153-0042, Japan
Personal Data Protection Administrator, VisasQ Inc.
E-mail: [email protected]
Hours: Weekdays 10:00-17:00 (JST)
The governing law of this Privacy Notice for Japan Residents is the laws of Japan. The Tokyo District Court shall be the court of exclusive jurisdiction in the first instance. With respect to Personal Information about residents outside of Japan, in addition to the Personal Information Protection Act, we will comply with such applicable laws and regulations on protection of Personal Information as equivalent to the Personal Information Protection Act.
We are a certified user of “PrivacyMark”. PrivacyMark is certification system which allows a certain entity to use PrivacyMark, subject to evaluation and certification by third party certification organization as an entity which takes appropriate measures to protect Personal Information.
Certification Organization: JIPDEC
Consultation Desk: Consumer Consultation Desk TEL：0120-116-213／0120-700-779
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We issue and use cookies for the following purposes:
To refuse the use of these cookies, you will need to change your browser settings. Please note that by rejecting the use of cookies, some parts of the Site may not function properly.
We use cookies issued by third parties outside of the Site in order to improve and enhance your experience with the Site. These third parties will handle your cookie information.
| Name of Service | Provider | Purpose of Use | To opt-out |
|---|---|---|---|
| GoogleAnalytics | Google LLC | This is a web page access analysis service. We measure the usage of the Site based on the status of visits and inflow routes to the Site and other factors. | opt out |
| FullStory | FullStory, Inc. | This is a web page access analysis service. We measure the usage of the Site based on behavior patterns and other factors. | opt out |
| Mixpanel | Mixpanel, Inc. | This is a web page access analysis service. We measure the usage of the Site based on the route of inflow to the Site and information on the browsers and devices being used and other factors. | opt out |
| MIERUCA | Faber Company Ltd. | This is a web page access analysis service. It measures the usage of the Site based on behavior patterns and other factors. | N/A |
| Intercom | Intercom, Inc. | This is a customer support service. It provides notifications based on the status of your visit to the Site and other factors, as well as a chat function. | N/A |
| Zendesk | Zendesk, Inc. | This is a customer support service. It provides an inquiry function. | N/A |
| Stripe | Stripe, Inc. | This is a payment agency service through the Internet. It provides credit card settlement services for the Services. | N/A |
| Marketo | Marketo, Inc. | This is a marketing automation service. It centrally manage inquiries to the Services, email notifications, seminar participation, visits to the Site, and other matters. | opt out |
| Google Ads | Google LLC | This is an advertisement distribution service. It distributes advertisements for the Services. We use information obtained from cookies to improve the relevance of the advertisements we deliver based on your visit history to the Site and other factors. | opt out |
| Yahoo! Ads | LY Corporation | This is an advertisement distribution service. It distributes advertisements for the Services. We use information obtained from cookies to improve the relevance of the advertisements we deliver based on your visit history to the Site and other factors. | opt out |
| Facebook Ads | Meta Platforms. Inc. | This is an advertisement distribution service. It distributes advertisements for the Services. We use information obtained from cookies to improve the relevance of the advertisements we deliver based on your visit history to the Site and other factors. | opt out |
| X Ads | X Corp. | This is an advertisement distribution service. It distributes advertisements for the Services. We use information obtained from cookies to improve the relevance of the advertisements we deliver based on your visit history to the Site and other factors. | opt out |
| Linkedin Ads | Linkedin. Inc,. | This is an advertisement distribution service. It distributes advertisements for the Services. We use information obtained from cookies to improve the relevance of the advertisements we deliver based on your visit history to the Site and other factors. | opt out |
| A8.net | Fun Communications Inc. | This is an affiliate advertising service. It distributes advertisements for the Services. We use the information obtained by cookies to record the affiliate results you set and for other purposes. | N/A |
| intimate merger | Intimate Merger, Inc. | This is a data management platform. In order to deliver advertisements for the Services, we use this platform to improve the relevance of the advertisements we deliver based on the history of visits to the Site and other information. | opt out |
| CookieYes | CookieYes Limited | This is a Cookie Plug-in. Cookies allow us to provide better services on the Site, such as making it easier for users to share content on social media, understand what content users are interested in, and deliver content, job postings, and advertisements tailored to the interests and location of individual users from us. We use this information to improve the user experience. | opt out |
| SiTest | GLAD CUBE Inc. | This is an access analysis tool. It uses information collected through cookies to analyze website usage and improve its performance. | opt out |
To disable (opt-out) the use of these cookies, you will need to change your browser settings. You can also disable (opt-out) some cookies by accessing the opt-out page for the service provided. Please note that some parts of our website may not function properly if you refuse the use of cookies.
Among cookies issued by third parties, information such as a user's browsing history obtained from cookies for the services listed below may be linked to information obtained by the Company that can identify a specific individual. In such cases, we treat the information including cookie information as a unit of personal information. Please refer to our Privacy Policy for the purposes for which we use such information.