Privacy Policy

Privacy Policy

Link and Motivation Inc. (“LMI”) provides support for corporate and individual growth using its core technology, “Motivation Engineering”, which refers to a technology developed independently by LMI based on the academic backgrounds of psychology, behavioral economics, social systems theory, etc., and to a methodology for promoting individual motivation and organizational activation.
LMI and LMI group operate three business divisions: the “Organizational Development Division”, the “Individual Development Division” and the “Matching Division”. The “Organizational Development Division” provides services to corporate clients to support strengthening their "engagement" with their stakeholders (employees, prospective employees, customers and shareholders) using “Motivation Engineering”. The “Individual Development Division” helps individual customers build careers autonomously and independently by applying “Motivation Engineering” to businesses of career schools and cram schools, etc. The "Matching Division" provides solutions in the form of placement services to companies and public educational institutions that want to secure the human resources needed for organizational growth.
In providing these services, safe management of information resources, including personal information, is a key issue for LMI. To ensure that LMI unfailingly manages information safely, its officers and employees strive to handle personal information appropriately pursuant to the following personal information protection policy.

1. LMI will comply with Japanese laws, guidelines set forth by the government and other rules concerning the handling of personal information when handling personal information used in all of its business activities (including retained personal data) and when handling the personal information of its employees and other individuals. In addition, LMI will establish a management system to protect personal information that is compliant with the “Personal information protection management systems—Requirements” of the Japanese Industrial Standards (JIS Q15001).
2. When acquiring and using personal information, LMI will specify the purpose of its use of personal information and will handle the information appropriately only within the scope required to achieve the specified purpose. LMI will not handle personal information for a purpose that exceeds the scope required to achieve the specified purpose of use (use other than for intended purposes). LMI will also adopt appropriate management measures to prevent use other than for intended purposes.
3. LMI will acquire personal information through lawful and fair methods.
4. LMI will not provide any personal information it has acquired to a third party unless it has obtained the consent of the individual concerned or is legally obligated to do so, etc.
5. LMI will ensure that whenever personal information is obtained, used or provided, the individual who has provided the information is appropriately involved. Furthermore, when complaints or requests for consultation are received regarding the handling of personal information, LMI will promptly investigate the relevant facts, etc. and respond appropriately in good faith within a reasonable period of time.
6. LMI will take organizational, personnel related, physical and technological measures to securely manage personal information and will work diligently to prevent and counteract any leakage or loss of or damage to said information.
7. LMI will establish a management system to protect personal information and will periodically revise and improve this system to ensure that it continues to operate effectively.

Enacted: April 1, 2004
Final revisions: August 1, 2020
Yoshihisa Ozasa, Chairman and Representative Director
Link and Motivation Inc.

Inquiries, Complaints, and Consultations regarding the Privacy Policy

Please contact the Customer Help Desk as provided below for inquiries, complaints, or consultations regarding the Privacy Policy.

Handling of Personal Information

“Personal Information” refers to information relating to a living individual, containing a name, date of birth, or other description, etc. whereby a specific individual can be identified (including information which can be readily collated with other information and thereby used to identify a specific individual).

LMI uses personal information within the scope required to complete the tasks and achieve the intended purposes listed below.

LMI will comply with relevant laws, regulations and guidelines, and implements necessary and appropriate measures (”security control measures”) to prevent leaks, loss or damage to personal data it handles, and to securely manage personal data, as follows.

(1) Formulation of a basic policy

In order to ensure the proper handling of personal data, LMI has formulated a Personal Information Protection Policy as its basic policy.

(2) Establishing rules for handling of personal data

LMI has established internal rules that stipulate how personal data is handled, who is responsible, who handles it, and what their roles are.

(3) Organizational security control measures

LMI has appointed a Personal Information Protection Manager as the person in charge handling personal information in the organization, has established a personal information protection management system and implements internal controls for the protection of personal information. LMI ensures employees (including contract employees and temporary employees) comply with internal rules related to security control measures, and has established a system for reporting to and contacting persons in charge, including the Personal Information Protection Manager, if an employee discovers or suspects an actual or potential violation of laws and/or internal rules. In addition, when outsourcing work that involves the handling of personal information, LMI takes steps to strictly supervise and monitor contractors to ensure their rigorous adherence to security control measures related to personal information.

(4) Personnel security control measures

LMI regularly provides education and training to employees on the proper handling of personal information.

(5) Physical and technological security control measures

In addition to controlling physical access by employees and third parties to areas where personal data is handled, LMI implements anti-theft measures such as the secure storage of documents, media, and devices, etc. containing personal information. In addition, LMI controls access to personal data and information systems that handle personal data, implements antivirus and anti-malware measures, and monitors information systems.

1. E.g.) LMI prohibits the storage of personal data outside designated storage locations, applies high-level policies for authentication passwords, and acquires and analyzes personal data related operation logs.

　

(6) Understanding the external environment

LMI stores some of the personal data it handles on servers located in the United States that are controlled by Box, Inc. LMI implements security control measures based on an understanding of systems for protecting personal information in the United States. For an overview of such systems in the United States, please refer to the results of the Investigation of Systems for the Protection of Personal Information in Foreign Countries, published by the Government of Japan’s Personal Information Protection Commission （https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku）(in Japanese).

In order to enable the Group to offer comprehensive services, LMI may jointly utilize personal information (excluding My Numbers) as follows.

(1) Items of personal information to be jointly utilized

(Personal information of customers and other non-LMI individuals)

• name (including place of employment, department, position title, etc. that identify a specific individual), address, phone number, fax number, email address, etc.
• matters concerning inquiries
• matters concerning the provision of services (in addition to account information required to use the services and information on activity history, such as browsing, searching, location information, etc.)

(Personal information of employees and other LMI individuals)

• name and other information on employment and evaluation management

(2) Scope of joint utilizers

Group companies (see here for the most recent list of Group companies)

(3) Purpose of joint utilization

Information may be jointly utilized only when necessary within the scope described in “2. Intended Purposes of Use of Personal Information.”

(4) Protection Officer of jointly utilized personal information

Link and Motivation Inc. Personal Information Management Representative.

(5) Acquisition method

Personal information acquired through the use of LMI services shall, in principle, be shared via an internet-based system equipped with encryption, etc.

LMI accepts requests from individuals that it disclose retained personal data, inform the individuals of the retained personal data's intended purpose of use, amend incorrect retained personal data, discontinue use of retained personal data, cessation of provision to a third party or disclosure of a record of provision to a third party (“Disclosure, etc.”).

(1) Contact information for requests for Disclosure, etc.

1. 1. Help desk for complaints and consultation
2. 2. Requests by mail should be sent to the following address with the necessary documentation attached:
   Customer Help Desk
   At Group Design Office
   Link and Motivation Inc.
   Kabukiza Tower 15F,
   4-12-15 Ginza, Chuo-ku,
   Tokyo 104-0061

(2) Items to be submitted

1. 1. Request for Disclosure, etc of Personal information form
2. 2. Personal identification materials (driver's license, passport, etc.)
3. 3. A legal representative must submit a document confirming his/her legal authority in addition to the document described in item 2 above.
   A privately appointed agent must submit a power of attorney in a form designated by LMI and a seal registration certificate in addition to a document listed in item 2 above.

1. Note: Please redact your permanent legal domicile, etc. and other personal information requiring special care from documents to be submitted. Documents from which this information has not been redacted when received by LMI will be redacted by LMI and LMI will treat said information as though it was not received.

(3)Handling fees

LMI will collect a fee of 500 yen per request for Disclosure, etc., based on the Act on the Protection of Personal Information. Please enclose a 500 yen postal money order purchased at your own cost with the required documents relevant to the request. (Please also note that the amount of the fee may be changed without notice.)

1. Note: We will notify you if there is a shortage of fee or the fee are not enclosed, but if payment is not completed within the prescribed period, we will treat as if there was no request for Disclosure, etc.

Please contact the LMI Customer Help Desk as provided in "6. Consultations and Complaints regarding the Handling of Personal Information" for the specific procedures related to requests for Disclosure, etc.

Please contact the Customer Help Desk as provided below to request consultation or submit a complaint regarding LMI’s handling of personal information.

Personal Information Protection Supervisor
Unit Manager, Group Design Office
Link and Motivation Inc.
Kabukiza Tower 15F, 4-12-15 Ginza, Chuo-ku, Tokyo
104-0061, Japan
Ozasa Yoshihisa, Chairman and Representative
Director

Inquiries, Complaints, and Consultations regarding the Handling of Personal Information

Please contact the Customer Help Desk as provided below for inquiries, consultations or complaints regarding the personal information protection policy.

LMI is a covered business operator for accredited services of the following accredited personal information protection organization accredited under the law.

The following organization, which accepts complaints and requests for consultation regarding LMI’s handling of personal information.

Personal Information Protection Consultation Desk
PrivacyMark Promotion Center
JIPDEC (Japan Information Processing Development Center)s
Phone:
Toll-free (within Japan only): 0120-700-779
International calls: +81-3-5860-7565

1. Note: "Retained personal data" refers to personal data which LMI has the authority to disclose, correct, add to, delete from, cease utilization of, erase and cease providing to third parties.

External Transmission of User Information

Through the website, application service, etc. (hereinafter referred to as the “Site, etc.”) provided by our company, we may collect information about users who browse and use the Site, etc. (hereinafter referred to as “Users”) on their computers, smartphones, and other terminals (hereinafter referred to as “Terminals”) by using cookies, etc., and send such information to the telecommunications equipment (Web server etc) of persons other than the Users, Cookies, etc. The use of cookies, etc. on the Site, etc. is described below. Users may change the settings for the use of cookies, etc. at any time by changing the browser settings. However, disabling cookies, etc. may affect the use of this Site and other services.

【Corporate Website（https://www.lmi.ne.jp/）】

【Motivation Cloud（https://www.motivation-cloud.com/）】

【Stretch Cloud（https://stretch-cloud.lmi.ne.jp/）】

【Solution（https://solution.lmi.ne.jp/）】

【Motivation Company Club（https://www.lm-mcc.com/MotivationCompanyClub/s/login/）】

【MEANING OF WORK（https://lm-tmw.com/）】

For inquiries, complaints, or consultations regarding the external transmission of information on this site, etc., please contact the Customer Service Desk below.