PRIVACY POLICY

We recognize that protecting personal information is an important social mission of a company, and we declare that all employees, including executives, will comply with legal regulations regarding personal information protection. In order to embody our basic policy outlined below, we have established a personal information protection management system that complies with JISQ15001, and that we will work as a company to continually improve our personal information protection management system while always keeping a close eye on changes in societal demands.

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1. We strongly recognize the importance of protecting personal information, and as a company that handles important personal information of customers through our telemarketing business, we strive to acquire, use, and provide personal information appropriately.
   This includes not handling personal information beyond the scope necessary to achieve the specified purpose of use (unintended use) and taking measures to ensure this.

2. We will take reasonable safety measures and preventive and corrective measures against the risk of personal information being leaked, lost, or damaged, so that you can provide us with your personal information with peace of mind.

3. As a company that holds important personal information, we will comply with laws, regulations, national guidelines and other standards regarding the handling of personal information.To that end, we have established a personal information protection management system that complies with the Japanese Industrial Standard "Personal Information Protection Management System - Requirements" (JIS Q 15001) and will operate it appropriately.

4. We will use personal information appropriately and continually review and improve our personal information protection management system to thoroughly protect it.

5. We will not provide personal information to third parties unless we have received the individual's consent or are required by law.

6. When outsourcing all or part of the handling of personal information, we will provide necessary and appropriate supervision to the outsourced party to ensure the safe management of the outsourced personal information.

7. If you have any complaints or inquiries regarding our handling of personal information, we will respond promptly and appropriately at the personal information complaints and inquiries desk listed below.

 

[Contact information for complaints and inquiries regarding personal information protection policy and personal information]

Upsell Technologies Inc.
Personal information complaints and inquiries desk
Telephone: 03-5986-0777 FAX: 03-5986-0778

 

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Established on January 22, 2007
Last revised on June 17, 2025
Upsell Technologies, Inc.
Chairman and CEO Ryota Takahashi

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How We Handle Personal Information:

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　We (Upsell Technologies Inc., CEO: Ryota Takahashi, Head Office: 6F Rikuo Nishiikebukuro Building, 5-26-19 Nishiikebukuro, Toshima-ku, Tokyo 171-0021) will take great care in managing personal information acquired by us, as well as personal information acquired through commissioned work from clients, and will handle such information as set out below.

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1. About the Personal Information Protection Manager
   We have appointed the following person as the Personal Information Protection Manager to properly and safely manage your personal information and to take measures to prevent and correct unauthorized access from outside, loss, destruction, falsification, leakage, etc.
   
   Name of the company and Personal Information Protection Manager
   Upsell Technologies Inc.
   Director, CCO, Executive Vice President
   03-5986-0777

2. Purposes of use of personal information held by our company:
   We will use personal information that we lawfully obtain from the individual or a business partner in writing, audio, electromagnetic means (website, email, fax), recording, or other means for the following purposes.
   
   <Purpose of use of retained personal data>
   (1) Information on customers who make inquiries about or use UPSELL CLOUD (our service)
   ・To respond to inquiries, etc. and to provide information on each service
   ・To smoothly provide, operate, and manage
   each service ・To bill for fees, etc. for
   each service ・To conduct research for the purpose of developing and improving
   
   each service (2) Personal information of those who make inquiries about our services 2
   ・To provide information on services and respond to inquiries, etc.
   ・To provide free consultations regarding the contents of inquiries
   
   (3) Business partner information
   ・To contact for business negotiations and business operations, orders, preparation of documents associated with contracts, billing, and payment
   ・To provide information and contact, including press releases
   
   (4) Employee information
   ・For personnel management, labor management, salary payment, welfare, tax, social insurance, health management, and safety management
   ・For contact after retirement
   ・For use as specified in the work regulations
   
   (5) Applicant information
   ・For recruitment activities (acceptance of applications, document screening, interviews, notification of results, etc.)
   
   (6) Inquirer information
   ・To respond to inquiries, complaints, consultations, disclosure, etc.
   
   <Purpose of use of personal information that is not held personal data>
   ・To operate and perform each service based on the contract
   ・Call recordings of UPSELL CLOUD (our service) are for the purpose of improving response quality and reconfirming the content of calls
   ・Call recordings of UPSELL CLOUD (our service) are for the purpose of internal research and study as statistical information, for the purpose of improving response quality and developing services

3. Regarding the provision of personal information to third parties
   , we will not disclose or provide personal information to third parties except in the following cases:
   (1) When the purpose of use has been explained in advance and consent has been obtained from the customer or the person in question;
   (2) When required by law;
   (3) When the handling of personal information is entrusted in whole or in part to the extent necessary to achieve the purpose of use.

4. Regarding safety control measures for retained personal data
   , we will verify the identity of the person by one of the following methods. We will take
   the following measures as appropriate safety control measures for all personal data, etc. according to the purpose of use.
   
   (Establishment of basic policy)
   In order to ensure the proper handling of personal data, we have established basic policies regarding "compliance with relevant laws, regulations, guidelines, etc." and "contact point for questions and complaints handling."
   
   (Establishment of rules regarding the handling of personal data)
   We have established personal data handling regulations regarding the handling method, responsible person/person in charge and their duties for each stage of acquisition, use, storage, provision, deletion/disposal, etc. We have appointed a personal information protection manager and a personal information protection audit manager to implement safety control measures for personal information.
   
   (Organizational safety control measures)
   We have appointed a person in charge of handling personal data, clarified the employees who handle personal data and the scope of personal data handled by said employees, and established a reporting and contact system to the person in charge in the event of finding facts or signs of violation of laws or handling regulations.
   
   (Personal safety control measures)
   We provide employees with regular training on points to note regarding the handling of personal data. The entrances to the office are equipped with security doors and are locked. The archives in the office are kept locked.
   
   (Physical security control measures)
   In areas where personal data is handled, we manage the entry and exit of employees and the devices brought in, and take measures to prevent unauthorized persons from viewing personal data. We take measures to prevent
   theft or loss of devices, electronic media, documents, etc. that handle personal data, and take measures to prevent personal data from being easily identified when carrying such devices, electronic media, etc., including moving around the office. (
   
   Technical security control measures)
   We implement access control to limit the number of people in charge and the scope of the personal information databases, etc. that are handled.
   We have introduced a mechanism to protect information systems that handle personal data from unauthorized access from outside or malicious software.
   When handling personal data in foreign countries, we will implement security control measures after understanding the systems regarding the protection of personal information in the foreign country.
   
   (Understanding the external environment)
   We use cloud services with servers in foreign countries, and in order to safely manage the personal data we hold, we confirm that the server is located in the EU or the UK, recognized by the Personal Information Protection Commission rules as a foreign country with a personal information protection system that is recognized as being at the same level as Japan, or that it has CBRP certification, and if neither of these apply, we implement appropriate safety management measures such as confirming that the information security of the cloud service is ensured after understanding the system of the foreign country.
   The foreign countries to which we currently provide personal data and their systems are as follows:
   US

5. Procedures for responding to requests for disclosure, etc. of retained personal data and records of third-party provision
   
   (1) Contact point for requests for disclosure, etc.:
   "Personal Information Complaints and Inquiries Desk" (listed at the end of this document)
   
   (2) Form of document to be submitted when making a request for disclosure, etc. and other methods for requests for disclosure, etc.
   Please send the following to our "Personal Information Complaints and Inquiries Desk" by mail or courier. We will respond promptly and without delay. Please note that we do not accept requests for disclosure, etc. by means other than mail or courier (in person at the office, e-mail, fax, etc.).
   
   a) If you do not have the "Application Form for Requests for Disclosure, etc." designated by our company
   , please contact us. We will send it to you from here.
   
   b) Identification documents
   1) If the request is made by the person himself/herself
   , a copy of the person's official certificate
   2) If the request is made by an agent,
   all of the following documents that apply.
   ①Documents confirming the power of attorney
   　i. Legal representative
   　　Family register certified copy or other documents verifying the qualifications
   　ii. Voluntary representative (all of the following)
   　　・Power of attorney designated by our company (If you do not have the power of attorney designated by our company, please contact us.
   　　　We will send it to you as soon as possible.) *A document with the seal of the person who has registered the seal
   　　・Certificate of personal seal registration
   
   ②Documents confirming the identity of the representative
   　　・Public certificate of the representative (copy)
   
   ③Documents confirming the identity of the person
   　　・Public certificate of the representative (copy)
   　　　*Public certificate
   　　　refers to A or B below.
   　　　A. One of the following:
   　　　　Driver's license, driving record certificate, passport, personal number card (only the side with name and photo), residence card, special permanent resident certificate
   　　　B. Two or more of the following documents:
   　　　　Public health insurance certificate, copy of resident's card, certificate of details in resident's card, pension book, late-stage elderly medical insurance certificate, membership card of National Public Service Mutual Aid Association or Local Public Service Mutual Aid Association, membership card of Private School Teachers Mutual Aid System, child support allowance certificate, special child support allowance certificate
   
   * The identity verification documents you present will be used as follows. Please only make requests for disclosure, etc. if you agree.
   ・ This personal information will be used to respond to requests for disclosure, etc. from the person in question.
   ・ Please make sure that sensitive personal information that is not necessary for identity verification is illegible by blacking out or otherwise.
   ・ Except as required by law, this personal information will not be provided to a third party without the person's consent.
   ・ The handling of this personal information may be entrusted. When entrusting, we will provide necessary and appropriate supervision to the entrusted party to ensure the safety management of personal information.
   ・If we are unable to verify your identity using identity verification documents, etc., we may not be able to respond to your request for disclosure, etc.
   ・For other information about our handling of personal information, please see our website below.
   https://upselltech-group.co.jp/privacy/
   
   c) Fees
   For each request for "notification of purpose of use" or "disclosure," a fee of 1,000 yen will be charged. Please enclose a postal money order for 1,000 yen together with the above documents.
   If the fee is not enclosed as stated above, we will inform you of this, but if you do not pay within the specified period, your request for disclosure, etc. will be considered as not having been made. Please note that, as a general rule, documents submitted will not be returned.

6. Please contact the following person for any requests for disclosure, complaints, consultations, or inquiries.
   Upsell Technologies Inc. Personal Information
   Complaints and Consultations Desk
   6th Floor, Rikuo Nishiikebukuro Building, 5-16-19 Nishiikebukuro, Toshima-ku, Tokyo 171-0021
   Department in charge: Management Department TEL: 03-5986-0777

7. Name of the certified personal information protection organization and contact point for complaint resolution Currently
   , our company is not a target business of a certified personal information protection organization.

8. Regarding the acquisition of personal information through methods that the individual cannot perceive
   , in order to ensure the security of the website visited and to improve usability
   , we acquire information about the visitor through access logs and cookies.