English translation is provided for convenience purposes only. The Japanese version of this document shall be regarded as the official version.
1. COLLECTED DATA AND METHOD
1) Information we ask Customers to provide
a. Corporate information (company name, location number, etc.)
b. Anonymized information about employees, the insured, and dependents (anonymized ID, department, email, relationship, birth date, gender, etc.)
c. Anonymized information about HR (anonymized ID, announcement, attendance, etc.)
d. Anonymized information about health insurance (anonymized ID, application, medical cost, health check, etc.)
e. Lifelog data Users synchronize with their mobile phone
f. Other information we ask Users to provide on entry forms
2) Information we collect about Users while using our service
We may collect the following information about access to the Service and uses.
a. Device information
b. Operational logs
c. Cookies and similar technologies
2. PURPOSE OF USE
We shall use user information for the following purposes:
The Company shall use Customers’ personal information for the following purposes:
1) Intervention in Users using checkup results and regulated health information by contractors including companies or health insurance unions
2) Intervention in Users using lifelog data (ex. the number of steps) and unregulated health information by contractors including companies or health insurance unions
3) System management necessary for the provision of the Service such as personal authentication (ex. login) and display switch.
4) Display of user information on administration page
5) Provision of functions to promote service use
6) Generation and use of anonymized statistics data provided on the Service
7) Provision of information necessary for Users to operate the Service such as maintenance, policy change, and the other important notification
8) Provision of notification we consider useful for Users
9) Answer for the Users’ opinion or inquiry on the Service
10) Development of the new service by us or alliance partners
11) Provision of anonymized information to our alliance partners
12) Information management, notification, inspection, guidance or measures by contractors including companies or health insurance unions to maintain and improve Users’ health
13) Promotion, sale and guidance about financial products of us, associates or alliance partners as well as introduction of associates, providing that these actions meet Users’ needs with their consent.
14) For any other purposes related to the above purposes
3. CHANGE OF PURPOSE OF USE
We may change the purpose of use of personal information to the extent that the purpose of use after the change is deemed duly related to the original purpose of use. When the purpose of use has been changed, we shall notify the Users of the change or publicly announce the change on our page.
4. DISCLOSURES TO THIRD PARTIES
In user information, we do not provide personal information to any third-parties except for:
1) The case where prior consent of Users is obtained
2) The case where we entrust all or part of the handling of personal information within the range necessary to achieve the purpose of use
3) The case where personal information is provided following business succession due to merger or other reasons
4) The case where disclosure is necessary for protecting human life or asset and where it is difficult to obtain consent of principal
5) The case where disclosure is necessary for improving public health or promoting the healthy development of children and where it is difficult to obtain consent of principal
6) The case where it is necessary for national/local governments or their subcontractors to perform regulated affairs and where the consent of the Users may affect the affairs
7) The other cases where disclosure is accepted based on the Personal Information Protection Law and other regulations
5. DISCLAIMER OF THIRD-PARTY PROVISION
We do not hold responsibility regarding third-party provision of Users’ data in the following cases:
1) Users themselves providing their personal information through our services
2) Third-parties accessing Users’ identification data such as email address, password, or etc. in some way
6. DISCONTINUING USING OR ERASING OF PERSONAL INFORMATION
In cases where we are requested by a User to discontinue using or erase the personal information (the “discontinue using, etc.”) under the Personal Information Protection Law based on the reason that their personal information is handled beyond the prespecified scope of the purpose of use or obtained by deception or other illegal means and where the request has reasonable grounds, we shall, after confirming that the request is made by the principal, discontinue using, etc. within a reasonable period and notify the User. Some items of user information assume the collection or use for the Service and therefore we discontinue collecting or using the items only when the User withdraws from the Service by our specified method, except in cases where we are not obliged to discontinue using, etc. under the Personal Information Protection Law or other regulations.
7. CORRECTING, ADDING, AND DELETING OF PERSONAL INFORMATION
In cases where we are requested by a User to correct, add or delete the content (the “correct, etc.”) under the Personal Information Protection Law based on the reason that their personal information is not true, we shall, after confirming that the request is made by the principal, conduct a necessary investigation within a reasonable period within a range necessary to achieve the purpose of use, and based on the result, we correct, etc. the content of personal information and notify the User (we notify the User when we decide not to correct, etc.), except in cases where we are not obliged to correct, etc. under the Personal Information Protection Law or other regulations.
8. DISCLOSURE OF PERSONAL INFORMATION
In cases where we are requested by a User to disclose their personal information based on the Personal Information Protection Law, we shall, after confirming that the request is made by the principal, disclose the information within a reasonable period and notify the User (we notify the User when the related personal information is absent), except in cases where we are not obliged to disclose under the Personal Information Protection Law or other regulations.
9. GOOGLE API SERVICES USER DATA POLICY
To sync users’ lifelog data from Google Fit, we may request users’ information to sign in to users’ Google account. The credentials data are only temporarily stored on the users’ devices, and we never obtain the credentials.
To sync lifelog data with users’ accounts, users’ activity data are accessed and transferred automatically via Google API. For example, we request users’ data such as step counts, distance (no information about the location of the user is requested or collected.), calories, weight, body fat, sleep, and body temperature. Users’ aggregated data are anonymized and used only for the purpose shown above.
10. USE OF ACCESS ANALYTICS TOOLS
This website uses a web analytics service and behavioral targeting provided by the following company to analyze user access. Please refer to each page about the service policy and guideline of each service.
12. INFORMATION MANAGEMENT SUPERVISOR
The following person is in charge of personal information management.
Takuya Kusumoto, Information management supervisor, WellGo, Inc.