Privacy Policy

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April 8, 2021

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November 18, 2021

April 12, 2021

Privacy Notice

FRONTEO USA Inc. and its subsidiaries and affiliates recognize the importance of your personal information and data. This privacy notice explains how we collect and use personal information, and describes the rights you have with respect to your personal information and data.

In this notice, “FRONTEO,” “our,” “we,” or “us” refers to FRONTEO USA, Inc., and its subsidiaries and affiliates. For the purposes of this Policy, the terms “personal information” and “personal data” mean the same thing.

FRONTEO handles personal data responsibly and fairly. We appoint a person in charge of management of personal data and acquire personal data by lawful means and only with consent and to the extend necessary to achieve lawful purposes. For information on protecting your personal data through opt-out procedures, please refer to the section below entitled “Provision of Personal Information to Third Parties through Opt-Out Procedures” below.

FRONTEO collects personal data in a variety of ways and for a variety of purposes. We may collect personal data from you directly, for example, if you engage us to perform work, if you visit our web sites, if you submit your contact details to receive marketing communications from us, if you submit event related data to attend FRONTEO events, or submit a job application. We may collect personal information about you from third parties, for example from employment consultants or job lists. We may obtain personal data from you directly through employment submissions, resumes or through your use or our web sites. And we may obtain personal data via publicly available resources, such as through social media sites like LinkedIn.

FRONTEO generally processes personal data in the context of providing contracted for services, to enable outside contractors to complete work within the scope and specific terms included in our services contracts, or to enable trusted management personnel to adequately support and manage service projects.

For some purposes, personal data may be subject to authorized disclosure, for example to provide, bill and pay for product and services ordered by FRONTEO, to provide product support to clients, to send and collect questionnaires, to provide third-party services that we deem beneficial to customers, to identify and communicate with FRONTEO event or seminar participants, to follow up with event or seminar participants, to provide information about sponsored events (such as through an e-mail newsletter), to identify registered members of our content website, to provide information using website content, to send gifts, to verify of persons making inquiries or complaint and responding to those inquiries or complaints, to communicate with and exercise the rights of shareholders, to contact prospective employees, and for other personnel and labor management purposes. This privacy notice is intended to cover all of the above-mentioned scenarios.

FRONTEO’s use or disclose personal data without prior authorization may occur in the following instances ( i.~iv below).

When required by law.
When necessary to protect the life, body, or property of the person or a third party, and it is difficult to obtain the consent of the person.
When there is a risk of significant hindrance to the proper implementation of FRONTEO's business.
When it is particularly necessary for the improvement of public health or the promotion of the sound development of children, and it is difficult to obtain the consent of the person.

FRONTEO will use and/or disclose personal data within the scope of use stipulated by applicable laws and regulations and by third-party organizations designated by such applicable laws and regulations, after obtaining information by lawful and fair means. However, this may not apply in the following cases ( v.~vi below).

In order for financial institutions to make payments in the event of a severe disaster, etc.
When it is necessary to use the Individual Number to protect the life, body, or property of a person.

Additional promises and conditions apply, such as:

In the event that the purpose of use of personal information is changed, FRONTEO will notify the person of the changed purpose of use or make a public announcement. (Except in the case of i.~iv. above).
FRONTEO will not disclose or provide personal information to any third party other than FRONTEO without the consent of the individual. (Except in the case of i.~iv. above)
FRONTEO will not share personal information with third parties other than our company without the consent of the individual.
To provide better services to our customers, FRONTEO may outsource part of our business and entrust personal information and individual numbers to subcontractors. In this case, FRONTEO will select a contractor that satisfies the security standards, conclude a consignment agreement regarding the protection of information, and thoroughly manage and supervise the contractor. In addition, in the unlikely event that business is re-outsourced, the same measures will be taken.
FRONTEO may use the services of the following contractors to manage personal information. Depending on the terms of service of the contractor, personal information may be used for the purpose of improving or developing the outsourced service/system, re-disclosure to the outsourced group company, or other purposes specified in the terms of use. If you do not wish to use the following consignment services, please refer to the following section and take steps to suspend the provision of personal information to a third party. If you follow the procedure, FRONTEO will stop providing the target personal information to the contractor and promptly take appropriate measures such as deletion.

Adobe (Please refer to the following URL for terms of service)
https://www.adobe.com/legal/terms.html

Salesforce (Please refer to the following URL for terms of service)
https://www.salesforce.com/company/legal/sfdc-website-terms-of-service/

Azure (Please refer to the following URL for terms of service)
https://azure.microsoft.com/en-us/support/legal/

Microsoft (Microsoft 365 service)
https://www.microsoft.com/en-us/servicesagreement

FRONTEO reserves the disclosure, correction, addition, deletion, suspension of use, elimination, and suspension of provision to third parties (hereinafter referred to as "disclosure, etc.") of retained personal data from the person or his/her agent. FRONTEO will respond to your request. When requesting disclosure, etc., please specify the matters to be disclosed, etc., and contact the requester using the following request method.

Available methods for requesting your personal data:

Those who can request disclosure, etc.	Principal, legal representative, and voluntary representative
Reception method	Please prepare the necessary documents and mail them to the billing address.
Required Documents	Request form for disclosure, etc. (free format. Request, name, address, and telephone number are mandatory.) Identification documents (a copy of one of the following documents: driver's license, certificate of residence, passport, or other document issued by a public institution) In the case of a request by a voluntary or legal representative, please attach the following additional documents: Documents confirming the right of representation ＜In the case of a legal representative＞a copy of a document that can confirm the right of legal representation, such as a copy of the family register ＜In the case of a voluntary agent＞ power of attorney (with the registered seal of the principal) and a certificate of seal registration of the principal (issued within 3 months) The identity verification document of the agent (a copy of one of the documents issued by a public institution, such as a driver's license, certificate of residence, passport, etc.) ）
Commission	Free of charge (however, the cost of mailing the documents for the request for disclosure, etc. will be borne by the person making the request.)
Request to	FRONTEO USA, Inc. Attn: Legal Team 1411 West 190th Street, Suite 270, Gardena CA, 90248 Email: usinfo@fronteo.com
Other precautions	＜Regarding identity verification documents and power of attorney verification documents＞ If there is any information on your permanent domicile, medical records, etc., please delete the relevant part before mailing it. ＜Cases in which FRONTEO are unable to respond to disclosure, etc＞ Please note that FRONTEO not be able to respond to requests for disclosure, etc. in the following cases. In that case, FRONTEO will notify you that FRONTEO cannot respond to the request for disclosure, etc. with a clear indication of the reason. When it cannot be confirmed that the person requesting disclosure, etc. is the person or agent of the retained personal data When the subject of the request for disclosure, etc. does not fall under the category of retained personal data When there is a risk of harming the life, body, property, or other rights and interests of the person or a third party When there is a risk of significant hindrance to the proper implementation of FRONTEO's business When it violates other laws and regulations, etc. ＜Purpose of use of personal information obtained in connection with a request for disclosure, etc.＞ Personal information obtained in connection with a request for disclosure, etc. shall be handled only to the extent necessary for disclosure, etc. Submitted documents will not be returned. After FRONTEO have completed our response to the request for disclosure, etc., FRONTEO will manage and dispose of it appropriately.

In order to ensure the accuracy of the content of personal data, FRONTEO will endeavor to manage personal information and individual numbers in an accurate and up-to-date state within the scope of the purpose of use.
In compliance with laws and regulations applicable to personal information and individual numbers held by FRONTEO, FRONTEO will review and improve its efforts in the handling of personal information as appropriate, such as strengthening internal safety management measures.
If you have any complaints or inquiries regarding the handling of personal information and individual numbers, please contact the following.

FRONTEO USA, Inc.
Attn: Legal Team
1411 West 190th Street, Suite 270,
Gardena CA, 90248
Email: usinfo@fronteo.com

FRONTEO takes appropriate precautions to properly manage, process, and protect personal data as well as important data and information provided by our clients and customers. In order to manage, process, and protect such important information, FRONTEO has implemented the following initiatives.

Regarding the establishment and operation of our dedicated data analysis laboratory, FRONTEO limits the number of people who have the authority to enter and exit the laboratory.
FRONTEO has installed a system that requires vein authentication when entering and exiting our data analysis laboratory, and FRONTEO maintains a log for each registrant’s fingerprint when entering and leaving the room.
A low-light surveillance camera is installed in our dedicated data analysis laboratory, and FRONTEO records and stores entry and exit from our dedicated data analysis laboratory and monitors access to the analysis PC booth and server 24 hours a day.
FRONTEO uses our forensic hardware for all of our PCs to acquire and maintain data on HDDs on a regular basis.

Provision of personal information to third parties through opt-out procedures

FRONTEO will provide personal information to third parties through opt-out procedures only within the scope of the following purposes of use.

Purpose of use of provision to third parties
FRONTEO will provide information on the relationship between the target researcher and the organization to which the researcher belongs, and other researchers and organizations to which the researcher belongs, for the purpose of risk compliance surveys such as risk analysis in the supply chain, surveys related to academic research, surveys related to public policy, and surveys related to product development and research. In addition, when providing article information, FRONTEO will provide author information accompanying the paper.
Where does FRONTEO provide information?
Government agencies, educational institutions, private companies (companies involved in the procurement and distribution of goods, pharmaceuticals, companies that possess or use R&D functions), and other corporations and individuals who wish to conduct analysis and investigation.
Where does the information come from?
Websites for searching and publishing articles on the Internet (limited to websites that post author information and papers with the consent of the author of the paper).
How does FRONTEO process information?
In order to maintain the information held and managed in the database, FRONTEO collates and compares the information FRONTEO already has with the newly acquired information, and updates processes such as correcting the changed data and adding new data. At this time, for example, if there are different notations for a person’s name or an organization’s name, it includes a name matching process that unifies the predetermined notation.
Appropriate Acquisition of Information
In accordance with the guidelines of U.S. and relevant foreign laws, FRONTEO acquires personal information in an appropriate manner.
Items of personal data to be provided to third parties
Title of paper, author's name, organization, country/region to which the organization belongs, email address
Method of Provision to Third Parties
1. Provision by e-mail
2. Provision in the form of optical discs, paper, and other media
3. Provided through services on the Internet that can only be viewed by contracted users
Procedures for Suspension of Provision to Third Parties
FRONTEO will stop providing your personal information to third parties at your request by mail or e-mail.

FRONTEO USA, Inc.
Attn: Legal Team
1411 West 190th Street, Suite 270,
Gardena CA, 90248
Email: usinfo@fronteo.com

Handling of personal information of persons located in the European Economic Area (EEA)

With regard to the handling of personal information of persons located in the European Economic Area (EEA), to which the European General Data Protection Regulation (GDPR) applies, this "Handling of Personal Information of Persons in the European Economic Area (EEA)" (hereinafter referred to as the "Privacy Policy") applies in addition to FRONTEO's "Handling of Personal Information". In the event of a conflict between the contents stipulated in the former and the contents stipulated in the latter, the provisions of the latter shall take precedence.

Term Definition
The definitions of terms in this "Handling Policy" are as follows.
- Applicable Privacy Laws
  Applicable privacy laws, including the General Data Protection Regulations (GDPR) and related national implementing laws
- EEA
  Member States of the European Union and countries under the Agreement on the European Economic Area (EEA)
- FRONTEO
  FRONTEO USA Inc. 1411 West 190th Street, Suite 270, Gardena CA, 90248
- Personal data
  Information that can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier or by reference to a plurality of elements relating to an identified or identifiable natural person (hereinafter referred to as the "Site User").
- Processor
  Natural or legal persons, public authorities, departments or other organizations that process personal data on behalf of the controller.
- Administrator
  Natural, legal persons, governmental authorities and other persons who, alone or jointly with others, determine the purposes and means of the processing of personal data.
- Third party
  Natural or legal persons, public authorities, departments or other organizations other than site users, administrators, processors, and persons authorized to process personal data under the direct approval of the controller or processor.
- Restriction of processing
  Marking the personal data stored in the record in order to limit its processing in the future.
- Processing
  Perform any business or group of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, compilation, structure, record keeping, modification or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise made available, alignment or combination, restriction, erasure or destruction.
- Profiling
  Any form of automated processing of personal data consisting of the use of personal data in order to assess certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to the natural person's ability to perform his or her duties, economic status, health, personal preferences, interests, reliability, behavior, location and movement.
- Consent of the person
  Freely given, identified, previously explained, and non-ambiguous expression of the intention of the site user, whereby the site user expresses his consent to the processing of personal data concerning him/herself, either by his statement or by a clear affirmative act.
- FRONTEO web site
  https://legal.fronteousa.com/
  https://www.fronteo.com/
Scope of application of this policy
1. Applies to individual use of our site by users and the processing of personal data through our site, to which applicable privacy laws and regulations apply. FRONTEO is the controller of such processing.
2. Our Site may contain information from third parties (e.g., hyperlinks, banners, etc.). FRONTEO does not control the information of these third parties, and FRONTEO is not responsible for their compliance with applicable privacy laws. FRONTEO asks that users of our website carefully read the privacy policies of the third-party websites they visit.
The purpose of use of personal data acquired and held by FRONTEO and the basis for lawful processing based on the EU General Data Protection Regulation (GDPR) are as follows.
1. Business partners: For transactions with FRONTEO and related communications. Based on the consent of the individual (Article 6(1)(a) of the GDPR) or legitimate interest (Article 6(1)(f) of the GDPR)
2. To respond to inquiries from the person in question. Based on the consent of the individual (Article 6(1)(a) of the GDPR) or legitimate interest (Article 6(1)(f) of the GDPR)
What personal data does FRONTEO collect?

FRONTEO may obtain the following personal data from users of FRONTEO's website.
1. Name and address
2. E-mail address
3. Username and password
4. IP address
5. Cookie
6. Employment information, resume
FRONTEO does not collect sensitive personal data, such as passport information or health data, through our site, except as required by applicable privacy laws.
Purpose of data processing

FRONTEO collects personal data when the following actions are performed by users of our site. FRONTEO will only process personal data in accordance with applicable privacy laws and regulations as described in this Privacy Policy.
1. When registering on FRONTEO's website
2. When you apply for employment through our site
3. When using FRONTEO's website for other purposes
FRONTEO collects and processes personal data only for the purposes described below.
1. Customers and business partners: To perform contracts or respond to requests from users of our website before concluding a contract
2. Customer service: To respond to inquiries about products and services, important information, and complaints.
3. Marketing: To provide information about our products, services, and events, to conduct questionnaires, and to send gifts such as campaigns.
4. Shareholders: To ensure the exercise of rights as a shareholder, to respond to communications and inquiries, and to send IR materials
5. Applicants for employment: To contact those who wish to provide information on employment and to select employment
Third-country relocation

When FRONTEO provides personal data to FRONTEO’s subcontractors and partner companies, it may involve transfers outside the EEA. FRONTEO limits the transfer of personal data to third parties located outside the EEA to cases where at least one of the following applies:
1. Transfer to a country that has been deemed by the European Commission to have an adequate level of protection for personal data (Article 45 of the GDPR)
2. Transfer to a contractual partner with whom FRONTEO has entered into a data transfer agreement that includes standard contractual clauses designated by the European Commission (Art. 46(2) of the GDPR)
3. Transfers that fall under the exceptional grounds stipulated in Article 49(1) of the GDPR
Retention Period

FRONTEO will keep personal data for an appropriate period of time as stipulated in accordance with relevant laws and regulations. Personal data that is no longer necessary to be handled after the retention period has elapsed will be appropriately deleted in accordance with internal regulations.
Changing Registration Information

If FRONTEO receive a request for disclosure, correction, addition, deletion, suspension of use, or deletion of personal data, FRONTEO will respond in an appropriate manner after confirming that the person making the request is the person in question or a person who has been delegated by the person. (Regarding the handling of personal information< described in > Method of Requesting Disclosure of Personal Information, etc.) The above requests and other inquiries regarding personal data will be accepted at each contact point. If you do not know who to contact, please contact us at the following address.

FRONTEO USA, Inc.
Attn: Legal Team
1411 West 190th Street, Suite 270,
Gardena CA, 90248
Email: usinfo@fronteo.com
Filing a complaint with a supervisory authority

If you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority (which can be found at the URL below) regarding the processing of your personal data.
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Contact details of the Data Protection Officer

Billing to

FRONTEO USA, Inc.
Attn: Legal Team
1411 West 190th Street, Suite 270,
Gardena CA, 90248
Email: usinfo@fronteo.com

California Privacy Statement

This addendum to the FRONTEO Privacy Policy explains the categories of personal data that we collect from you and how we collect and use personal data that is subject to the California Consumer Privacy Act of 2018 (the “CCPA”). It further describes the rights that California residents have with respect to their personal data. This addendum should be read together with the FRONTEO Privacy Policy and in case of any conflict the terms of this addendum will prevail as to personal data of California residents that is subject to the CCPA. For purposes of this addendum, the term “personal data” includes all personal information” as defined in the CCPA.

Your legal rights

Under certain circumstances, California residents have the following rights in relation to their personal data:

Right of access and data portability. You may have the right to request that we disclose to you information about our collection and use of your personal data in the preceding 12 months, including: (a) the categories and specific pieces of personal data we collect; (b) the categories of sources from which we collect or sell personal data; (c) the business or commercial purpose for which we collect personal data; (d) the categories of third parties with whom we share personal data; and (e) the categories of personal data disclosed for a business purpose or sold to third parties and the categories of third parties to whom such personal data was sold or disclosed.
Right to deletion. You may request that we delete certain personal data that we have collected about you. The foregoing is subject to our right to maintain your personal data for specific purposes permitted under CCPA. If we are unable to comply with any such request, we will notify you.
Right to opt-out. You may have the right to request that your personal data not be sold to third parties.
Right to non-discrimination. You have the right to exercise any of the rights listed above (and any other rights under CCPA) without discrimination by us.

Do Not Track

If we detect that you have enabled the Do Not Track setting in your browser, we will automatically disable Advertising/Targeting cookies.

Sources of, purposes for collecting, and categories of personal data collected and disclosed

We collect and process personal data for a variety of business or commercial purposes. The FRONTEO Privacy Policy describes in greater detail the specific pieces of personal data that we collect, the categories of sources from which we collect or sell personal data, and the categories of third parties with whom we share or may share personal data.

In the preceding twelve (12) months, we have collected the following categories of personal data from California residents. Please note that the following list represents categories of personal data across all California residents whose personal data we may have collected or received and does not necessarily represent information we have collected specifically about you. Please also note that the definition of “personal information” under CCPA is subject to certain exceptions as set forth therein and does not include information that is publicly available or has been aggregated or deidentified in accordance with CCPA.

Identifiers. This includes information such as name, postal address, email address, internet protocol address, driver’s license number and other similar identifiers.
Personal information as defined by Cal. Civ. Code § 1798.80(e): The types of personal data in this category include several of the identifiers described above but also includes, among other things, information such as employment history, bank account number, credit card number, or debit card number.
Certain protected classifications. Information under this category may include race, color, national origin, marital status, religion or creed or other similar information that is generally protected under California or federal law.
Commercial information. Commercial information is information such as records of personal property, products or services purchased or other consumer history or tendencies.
Biometric information. Information under this category includes measurements or technical analysis of human body characteristics, such as fingerprints or a retina image, which are used to authenticate an individual so that they can access a FRONTEO site or managed database.
Internet or network activity. The types of information in this category includes information that relates to browsing or search history, or information regarding visitors’ interaction with an internet website.
Geolocation data. In general, geolocation data relates to information regarding the physical location of an internet connected device.
Sensory information. Information under this category can include audio, electronic, visual, thermal, olfactory, or other similar sensory information.
Professional or employment-related information. This includes information such as job history.
Education Information. Information under this category is non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99).

We may have collected and processed personal data for various business purposes in the preceding 12 months, including:
Auditing related to interactions with consumers in accordance with the professional services FRONTEO provides.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and taking appropriate action as a result of any such detected activity.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient uses where the personal data is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the relevant interaction.
Performing professional services for our clients.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

In the preceding 12 months, we may have disclosed to third parties for a business purpose the categories of personal data listed above. In addition, we may have shared your personal data with the following categories of third parties: FRONTEO USA, Inc. affiliates and subsidiaries; vendors and suppliers that provide services on our behalf; professional services organizations such as law firms, tax advisors, and auditors; and other third parties such as advisors, insurers, joint marketing partners, business partners, ad networks, internet service providers, data analytics providers, operating systems and platforms, providers of identity and credit verification services, regulatory and other professional bodies, and government authorities.

Sales of personal data

We do not sell your personal data for monetary consideration. We may allow certain third parties (such as online advertising services) to collect your browsing activity and certain other personal data via automated technologies on FRONTEO websites in exchange for non-monetary consideration. We may share the categories of personal data listed below in order to improve the performance of FRONTEO websites, to enhance your browsing experience, to provide you a more personalized browsing experience, and to improve our advertising efforts. You can view a full listing of those third-party cookies and opt out of their use via the FRONTEO website settings pages. Please note that to the extent you are accessing FRONTEO websites across multiple devices or platforms or if you clear your browser settings, you may have to opt out again.

In the preceding 12 months we may have sold the following categories of personal data in connection with such third-party cookies:

Identifiers. This includes FRONTEO’s website visitors’ internet protocol (“IP”) addresses.
Internet or network activity. This includes information about visitors’ interaction with FRONTEO websites, including information about the visitor’s web browser, page location, referrer, and person using the website; cookie-specific data such as cookie ID and the cookie; and button and field data, such as any buttons clicked by site visitors, the labels of those buttons, any pages visited as a result of the button clicks, and the names of any website fields filled in by visitors.

Exercising your rights in relation to personal data

If you would like to exercise any of the rights you may have with respect to personal data under the CCPA as listed above, please contact us by either:
Submitting a request through sending inquiry to usinfo@fronteo.com.
Contacting us via our toll-free number at 1-866-80FRONT.

As part of processing your request, we require you to provide certain personal data about you in order to verify your identity in accordance with the CCPA requirements. This information includes your first and last name, email address, physical address, telephone number, and description of your relationship to FRONTEO, but may also include additional information based on the nature of your request and your relationship with us.

Additionally, in accordance with your rights under the CCPA, you may designate an authorized agent to make a request on your behalf. In order to comply with your request, we will require the personal data referenced above to be used for identity verification purposes, as well as the name, email address, and telephone number of your authorized agent.

After we verify your identity and the validity of your request, we will take the following action free of charge:
in the case of an access request, provide you any required personal data covering the twelve 12-month period preceding your request; and
in the case of a deletion request, delete personal data that we have collected about you, subject to our right to maintain your personal data for specific purposes permitted under CCPA.

We will endeavor to comply with your verified request within forty-five (45) days, but may extend that period when reasonably necessary, in which case we will notify you. Please note that you may only make an access request to us for your personal data up to two (2) times in any twelve (12) month period.

Contact for more information

If you have any questions regarding the processing of your personal data, please contact the FRONTEO Legal Team