1. Our views about the protection of personal information
SKYGO mobile Inc (hereinafter referred to as the “Company”) hereby promises the following matters regarding the handling personal information（hereinafter including the “Specific Personal Information”） based on the understanding that the personal information of customers and all the persons involved in the business activities of the Company (including the shareholders and employees, and hereinafter collectively referred to as the “Principals”) shall be handled properly and prudently under the Act on the Protection of Personal Information and with the philosophy of respect of personality (protection of privacy), and this has a close relationship with not only compliance with the laws and regulations, but also people's personal rights and interests.
1. We will observe any and all laws regarding the protection of personal information, any and all guidelines about such laws in economic and industrial fields, and any other applicable laws and regulations, and we will also comply with any and all applicable practices for handling personal information that are generally accepted as fair and proper; In addition, we will make an effort to appropriately improve our handling of personal information;
2. If the EU General Data Protection Regulation (the GDPR) might apply to the Company’s acquisition of personal information, the Company will manage such personal information appropriately in accordance with the GDPR. With respect to the Company’s handling of personal information and the rights of the Person in cases where the GDPR applies to the Company’s handling of personal information, please refer to VIII below since the provisions of VIII below will take precedence over I to VII.
3. When we obtain any personal information, we will identify and notify the Person of the purpose of use of said obtained personal information, and handle it according to that purpose;
4. When we handle personal information, we will define a storage period as needed for the general purpose of its use, and we will delete any personal information without delay after the lapse of such a storage period, unless any laws or regulations otherwise allow us to keep the information;
5. We will take any necessary countermeasures to protect any personal information from being leaked, lost or falsified, and we will manage such personal information thereby; and
6. As for any personal information held by us, if we receive a request from the Person at a designated information counter to disclose, correct, delete or stop using any personal information, we will handle such personal information in good faith as per the request.
7. The Person may ask the Company to access his/her own personal data held by the Company, revise or delete any incorrect personal information, or restrict data processing whilst the accuracy of the personal information is being examined.
8. Personal information acquired by the Company will be stored on a server in Japan used by the Company.
9. The Person may raise an objection with the supervisory authorities of the EEA (European Economic Area) member states if the GDPR applies to the Company’s handling of personal information and if the Person has doubts over the Company’s handling of personal information.
2. Regarding the Appropriate Handling of Personal Information with Consideration of the Details and Scale of Business
We will obtain any personal information necessary for each business run by us, and we will use said personal information for the following purposes. In addition, to conduct our business smoothly, we will contract out parts of our business and sometimes provide personal information to our contractors within a necessary range for business. In this case, we will provide for proper supervision, including the signing of an agreement regarding the handling of personal information between the Company and any such contractors.
(1) Purpose of Use
1. Handling of personal information when providing goods and services (*);
2. Providing post-sale services in connection with the previous line;
3. Billing and collecting each type of fee for our business and others, and protecting our account receivables (including any cases where we contract out the handling of personal information to bill and collect each type of fee);
4. Studying and developing new goods and new services for our business;
5. Announcing goods and services as set forth in the previous line;
6. Training in sales and solicitation methods for our business and improvement training for our employees;
7. Conducting market research and other studies and research for our business;
8. Granting prizes and conducting campaigns;
9. Developing statistical data for business analysis and using the results of such analysis;
10. Responding to any request for disclosure based on the Private Information Protection Law, and monitoring and inspecting the handling of personal information;
11. Conducting activities for CSR (Corporate Social Responsibility);
12. Managing customers, contractors, suppliers or vendors, and contract-related matters;
13. Managing shareholders; Exercising any rights or implementing obligations based on the Commercial Code; Providing every type of convenience to the shareholders for positions with the Company; Taking every type of measure to smooth the relationship between the shareholders and the Company, from the perspectives of the members of an incorporated entity and the incorporated entity itself; Developing shareholder data based on predetermined standards according to various laws and regulations;
14. Employing employees (including recruiting and hiring), and conducting human resources management;
15. Offering benefit packages to employees (including the announcement and management of said benefit packages);
16. Managing facilities and equipment;
17. Joint use as prescribed in the following paragraph (2);
18. Providing personal information to any third parties for the purposes as prescribed in the following paragraph (3);
19. Introducing goods or services provided by certain companies with which the Company has a business partnership (but with which we do not have any capital ties); and
20. Carrying out other operations, within a range necessary to conduct our business, in connection with each of the above lines.
*Details of Our Business Line
1. Renting out portable communication devices and their peripheral equipment;
2. Planning, developing and maintaining our website on the internet; and
(2) Joint Use
1. We will share and jointly use what we acquire over the telephone, including our customers’ names, company names and contact information, with our parent company, subsidiaries and affiliates. Incidentally, in the event that we use such information with our parent company, subsidiaries and affiliates, the purposes of such use include the office automated equipment business for selling business equipment such as copiers, multi-function machines, telephones and personal computers, the selling and brokering of cell phones, the SHOP business for brokering various credit cards, the insurance business and online advertisement business, and the Internet business for managing rental servers, portable content and portal sites; and
2. The Company will share and jointly use personal information for employment and management, including employees’ names, dates of birth, genders, ID photos, families, belongings, education and training, skills, qualifications, evaluations, work experience, academic backgrounds, career plans and communication within our group, in order to improve employment, human resources and morale. Accordingly, the Company itself assumes full responsibility for managing such personal information.
(3) Provision to Third Parties
1. In the event that there are debtors who have not paid fees related to our business regardless of being overdue, and there are outstanding amounts of payment and default disputes, we may provide the following to other companies involved in our business to prevent recurrence of non-payment of any fees related to our business: the debtors’ names, dates of birth and any other information regarding any dispute. Accordingly, the Company itself assumes full responsibility for managing the personal information that we use;
2. In the event that there are debtors who have not paid fees related to our business regardless of being overdue, we may transfer accounts receivable for defaults, and so that the transferee may collect the defaults, we may provide the transferee with the debtors’ names, addresses, dates of birth and outstanding amounts; and
3. The Company may provide an entity who conducts due diligence (investigating corporate information) with personal information for any relevant due diligence of the restructuring of business organization, absorption, reorganization or transfer of operations.
3. Disclosure & Provision to Third Parties
The Company may revise these terms from time to time without obtaining any consent from the Signers. In this event, the Company will provide any and all Signers with a notice of the revised terms by any of the methods prescribed in Article 6 (Methods of Notification), and the revised terms will become effective immediately thereafter.
1. If there is the consent of the Person;
2. If the information is disclosed or provided as statistic data in such a way that it is impossible to identify the Person;
3. If the Company is requested to disclose and provide personal information based on laws and regulations;
4. If it is a matter of protecting human lives, persons or assets, and it is difficult to obtain the consent of the Person; or
5. If the Company is required to cooperate with national or local public service institutions for their public business transactions, and obtaining the consent of the Person may impair the implementation of such business.
4. Procedure for Disclosure
For personal data held by the Company, if the Person requests to disclose his/her personal information, we will generally provide a response in writing within a reasonable period of time after the requester has been identified as the Person. Incidentally, according to laws and regulations, we may not accept all such requests.
5. Correction & Deletion
For personal data held by the Company, if the Person requests to correct, add or delete his/her information, we will correct, add or delete such personal information within a reasonable period of time after the requester has been identified as the Person, if it is found that the recorded content is not factual.
6. Termination of Use & Deletion
For personal data held by the Company, if the Person requests to terminate the use of or delete his/her personal information, we will generally terminate the use of or delete his/her personal information within a reasonable period of time after the requester has been identified as the Person.However, if we stop using or delete a portion or the entirety of the Person’s personal information, we cannot provide the desired services against our will. We would like to ask for understanding and cooperation on this point.
In addition, we cannot satisfy your request to terminate the use of or delete any information as is held based on laws and regulations such as the Labor Standards Acts, in the event that
2. The Company obtains personal information in an illegal or unlawful manner; or
3. The Company wrongly discloses personal information to any third parties.
7. Disclosure Requests & Information
Regarding personal data held by the Company, please use the following contact information for any of the requests as set forth in the above paragraphs 4, 5 and 6, and for any other questions about personal information. Incidentally, we may not accept any request for disclosure through any other contact method:
Address: 370 Crenshaw Blvd E207 Torrance Ca 90503 Tel: 1833GOSKYGO
The reception time for all counters is from 10 AM to 5 PM on weekdays*.
*Excludes Saturdays, Sundays, and national holidays.
8. Additional Clauses
If you have your habitual residence in the European Economic Area, this Chapter VIII shall prevail against Chapters I to VII above with respect to our processing of personal data and data subject rights.
Summary of PRIVACY NOTICE
This summary Privacy Notice ("Summary Notice") will provide you with a summary of the accompanied, detailed Privacy Notice (hereafter "Full Notice", together "Summary and Full Notice") on the data processing activities of SKYGO mobile Inc, located at 370 Crenshaw Blvd E207 Torrance Ca 90503 ("SKYGO", „our“, "we" or "us") with respect to individually identifiable information ("Personal Data") about users of our site (https://www.skygowifi.com/)("Website").
Scope of applicability
This Summary and Full Notice applies to you if you are a user of our Website.
Processing of your Personal Data (categories of Personal Data)
We process the following of your Personal Data collected during your visit of our Website: your full name, your date of birth, your gender, your country, your postal address including your street and number, city, zip code, phone number, e-mail address, your IP-address, host name, user agent, browser identification, referrer, the date/time of your access to the Website, and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you. For more details see 1. of the Full Notice or click here.
We process your Personal Data for the following purposes: providing WiFi router rental services, billing and collecting fees for our services, granting prizes and conducting campaigns, introducing goods or services of us or our business partners, managing and administrating your account, get in contact with you concerning your queries, security and fraud prevention, conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and service. For more details see 2. of the Full Notice or click here.
Legal justifications for the processing of your Personal Data
One of the key privacy law requirements is that any processing of Personal Data has to have a legal justification. We generally use the following legal justifications: (1) You have given your consent to the processing (Art. 6(1)(a) GDPR; "Consent Justification"), (2) the processing is necessary for (a) the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR; "Contract Performance Justification") (b) compliance with a legal obligation (Art. 6(1)(c) GDPR; "Legal Obligation Justification") and (c) realizing a legitimate interest (Art. 6(1)(f) GDPR; "Legitimate Interest Justification"). For more details and the matching of purposes and corresponding legal justifications see 3. of the Full Notice or click here.
Data transfers and recipients and legal justification for such transfers
We transfer your Personal Data to our service providers, and, in accordance with applicable law, other governmental authorities, courts, external advisors, and similar third parties, some of the aforementioned recipients located in jurisdictions outside the EU. For more details see 4. of the Full Notice or click here.
Retention periods for and deletion of your Personal Data
Your Personal Data will be deleted once they are not any longer needed for the purposes motivating their original collection or as required by applicable law. For more details see 5. of the Full Notice or click here.
Your statutory rights
You have a number of rights with regard to the processing of your Personal Data, each as per the conditions defined in applicable law, such as the right to have access to your Personal Data, to have them corrected, erased or handed over. Please refer any of your questions to firstname.lastname@example.org. For more details see 6. of the Full Notice.
Changes of this Summary and Full Notice as well as further notices
This Summary and Full Notice are subject to change. You will be notified adequately of any such changes. Further, you will be notified adequately through further relevant privacy notices (e.g. for specific purposes) in case such is not covered by this Summary and the Full Notice.
How to contact us
If you wish to exercise your data subject rights or if you have any other questions concerning this Summary and Full Notice, please address your request to us, who can be contacted at:
Address: 370 Crenshaw Blvd E207 Torrance Ca 90503 Tel: 1833GOSKYGO
Address: 370 Crenshaw Blvd E207 Torrance Ca 90503 Tel: 1833GOSKYGO
The reception time for all counters is from 10 AM to 5 PM on weekdays*.
The reception time for all counters is from 9 AM to 5 PM on weekdays except for national holidays in Japan.
We are delighted about your interest in our Website. Your privacy is important to us. Hereafter, we provide you with detailed information on dealing with your personal data on this Website.
This Full Notice is applicable for the Website only. Other Skygo websites may be governed by other privacy policies. Please also note that parts of the Website may contain links to such other Skygo websites or third party websites which may be governed by other privacy policies.
1. Categories of Personal Data
We process the following Personal Data about you (hereinafter jointly "Your Data"):
1. your full name, your date of birth, your gender, your country, your postal address including your street and number, city, zip code, phone number, e-mail address (hereinafter jointly "Contact Data");
2. your IP-address, host name, user agent, browser identification, referrer, and the date/time of your access to the Website (hereinafter jointly "Technical Data"); and
3. any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you (hereinafter jointly "Form Data").
2. Processing purposes
We process Your Data to the extent permitted or required under applicable law, for the following purposes:
1. to perform a contractual obligation under contracts between you and Skygo or to take steps at your request prior to entering into a contract with us (hereinafter "Contract Purposes");
2. to provide the Website in an optimized way for you and to currently enhance the user experience of the Website (hereinafter "Quality Purposes");
3. to send you marketing materials, such as newsletters to provide you with the latest information about our products and services which might be of interest to you (hereinafter jointly "Marketing Purposes").
3. Legal justification for the processing of Your Data
Generally, the provision of Your Data is voluntary. However, if you do not provide Your Data, the use of the Website may be different. Particularly, if you do not provide Contact Data, we do not provide our Wi-Fi router rental services to you.
Furthermore, We rely on the following legal justifications for the processing of Your Data:
Categories of Your Data involved
Contract Performance Justification
Legitimate Interest Justification
4. Data transfers and recipients and legal justification for such transfers
1. Third parties: We may transfer Your Data to governmental agencies and regulators, courts, and government authorities, all in accordance with applicable law based on Legal Obligation Justification and to external advisors acting as controllers (e.g., lawyers, accountants, auditors etc.) based on Legitimate Interest Justification.
2. Service providers: We contract with third party service providers as part of our normal business operations to provide the Website and related services to you (i.e., cloud service providers, call center service providers, and logistic companies).
2. Cross-Border Data Transfers
1. We may transfer Your Data outside of the country you are located. Some recipients of Your Data are also located in another country for which the European Commission has not issued a decision that this country ensures an adequate level of data protection as of the date of this Privacy Notice, namely: Japan.
2. By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Art. 46(5) GDPR, we have established that all recipients located outside the EEA will provide an adequate level of data protection for Your Data and that appropriate technical and organizational security measures are in place to protect Your Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law. Such agreements are accessible upon request from [email@example.com].
5. Retention periods for and deletion of Your Data
1. Your Data processed for the purposes hereunder will be stored only to the extent necessary. If a judicial or disciplinary action is initiated, Your Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
2. In principle, we will retain Your Data as long as required or permitted by applicable law. Afterwards, we will remove Your Data from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.
6. Your statutory rights
Under the conditions set out under applicable law (i.e., the GDPR), you have the following rights:
1. Right of access: You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. The access information includes – inter alia – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed. You have the right to obtain a copy of the Personal Data undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.
2. Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
3. Right to erasure (right to be forgotten): You have the right to ask us to erase your Personal Data.
4. Right to restriction of processing: You have the right to request the restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
5. Right to data portability: You have the right to receive the Personal Data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another entity without hindrance from us.
6. Right to object:
You have the
right to object, on grounds relating to your particular situation, at
any time to the processing of your Personal Data by Us and We can be
required to no longer process your Personal Data. In general, you
have the right to object to our processing of your personal data for
direct marketing purposes. If you have a right to object and you
exercise this right, your Personal Data will no longer be processed
for such purposes by Us. Exercising this right will not incur any
Such a right to object may not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Please note that the aforementioned rights might be limited under the applicable national data protection law. We remain the universal point of contact for your execution of these rights.
Please refer any of your questions to firstname.lastname@example.org.
In case of complaints you also have the right to lodge a complaint with the competent supervisory authority, in particular in the member state of your habitual residence or alleged infringement of the GDPR.
IX Additional Clauses