Personal Information Protection 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 staffing and dispatching to corporations and public educational institutions seeking to recruit personnel necessary 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 July 8, 2019
Yoshihisa Ozasa, Chairman and Representative Director
Link and Motivation Inc.

Handling of Personal Information

1. 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).

2. Intended Purposes of Use of Personal Information

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

1 Personal information acquired in connection with the entrustment of various businesses related to organizational and personnel consulting, hiring, staffing, dispatching, training and educational support, etc.
  • To carry out the entrusted business activities
2 Personal information of customers who use our services
  • To perform various service-related procedures
  • To provide services
  • To provide service-related guidance
  • To improve and augment the services
  • To respond to client inquiries, to contact clients in various forms
3 Personal information related to participants in events, conferences and seminars
  • To provide guidance in relation to and operate and manage events, conferences and seminars
  • To provide said personal information to sponsors and co-organizers of events, conferences and seminars
  • To provide guidance concerning services provided by LMI
4 Personal information related to customers' officers and employees
  • To carry out business activities and customer management
5 Personal information of shareholders and investors
  • To carry out shareholder management under the law
  • To provide guidance of various IR activities
6 Personal information handled in staffing and dispatching business activities
  • To carry out employment placement and dispatching business activities
7 Personal information of employment applicants
  • To contact employment applicants regarding their selection and employment application results
8 Personal information of individuals to whom LMI consigns business activities
  • To formulate business activity requests
  • To carry out contract management
9 Personal information related to employees and retirees
  • To carry out employment and personnel management
1 Personal information acquired in connection with the entrustment of various businesses related to organizational and personnel consulting, hiring, staffing, dispatching, training and educational support, etc.
  • To carry out the entrusted business activities
2 Personal information of customers who use our services
  • To perform various service-related procedures
  • To provide services
  • To provide service-related guidance
  • To improve and augment the services
  • To respond to client inquiries, to contact clients in various forms
3 Personal information related to participants in events, conferences and seminars
  • To provide guidance in relation to and operate and manage events, conferences and seminars
  • To provide said personal information to sponsors and co-organizers of events, conferences and seminars
  • To provide guidance concerning services provided by LMI
4 Personal information related to customers' officers and employees
  • To carry out business activities and customer management
5 Personal information of shareholders and investors
  • To carry out shareholder management under the law
  • To provide guidance of various IR activities
6 Personal information handled in staffing and dispatching business activities
  • To carry out employment placement and dispatching business activities
7 Personal information of employment applicants
  • To contact employment applicants regarding their selection and employment application results
8 Personal information of individuals to whom LMI consigns business activities
  • To formulate business activity requests
  • To carry out contract management
9 Personal information related to employees and retirees
  • To carry out employment and personnel management

3. Joint Utilization of Personal Information

In order to enable the Link and Motivation Group (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.

(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.

4. Procedures for Disclosure, Amendment, 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 and discontinue providing retained personal information to third parties (“Disclosure, etc.”).

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

  1. Help desk for complaints and consultation
  2. Requests by mail should be sent to the following address with the necessary documentation attached:
    Customer Help Desk
    At Group Design Headquarters
    Link and Motivation Inc.
    GINZA SIX 12F, 6-10-1 Ginza, Chuo-ku, Tokyo 104-0061

(2) Items to be submitted

  1. Notification of intended purposes of use of personal information / disclosure request form
  2. Request for amendment, etc. of personal information
  3. Request for discontinuance of use of personal information
  4. Personal identification materials (driver's license, passport, etc.)
  5. 5. A legal representative must submit a document confirming his/her legal authority in addition to the document described in item 4 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 4 above.
  6. 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.

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.)

  • 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 "5. Consultations and Complaints regarding the Handling of Personal Information" for the specific procedures related to requests for Disclosure, etc.

5. Consultations and Complaints regarding the Handling of Personal Information

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
Group Manager, Group Design Office
Link and Motivation Inc.

Inquiries, Consultations and Complaints regarding the Personal Information Protection Policy

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

    Customer Help Desk
    At Group Design Headquarters
    Link and Motivation Inc.
    GINZA SIX 12F
    6-10-1 Ginza, Chuo-ku
    Tokyo 104-0061
    JAPAN
    E-mail: contact@lmi.ne.jp

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

  • 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 and which is neither personal data specified under the Cabinet Order to Enforce the Act on the Protection of Personal Information as likely to cause harm to the public or other interests if its existence or absence is publicized nor personal data scheduled for deletion within six months.

6. Handling of Access Logs

For the purpose of improving its services, LMI may use "Google Analytics," a service provided by Google Inc., to analyze LMI's corporate website and other websites it operates and cloud services provided by LMI. When LMI uses "Google Analytics", Google Inc. collects, records and analyzes your LMI website and cloud system usage history based on “cookies” issued by LMI. LMI receives the analysis results from Google, Inc. and uses them to learn about your usage of LMI's websites and cloud system. Information collected, recorded and analyzed by "Google Analytics" does not contain any personal information capable of identifying a specific individual and shall be managed by Google, Inc. based on Google’s privacy policy.

Please visit the "Google Analytics" website for a description of the Google Analytics Terms of Service and visit Google, Inc.'s website for a description of the Google Privacy Policy.
Google Analytics Terms of Service:
https://marketingplatform.google.com/about/analytics/terms/jp/

Google, Inc. Privacy Policy:
http://www.google.com/intl/ja/policies/privacy/

Note that “cookies” (information transmitted from a server to a user's browser which is stored on the user's computer and used on the server end to identify the user) are limited to content used to improve usability and services and does not include personal information.