Colt Technology Services Privacy Policy

Originally enacted: April 1, 2005
Amended: March 1, 2016

At Colt Technology Services we appreciate the trust our customers have placed in us. Because you trust us with personal and other confidential information we have about you, we respect your privacy and take our responsibilities regarding the security of your information very seriously. We are committed to providing you with the highest quality of service while safeguarding your information. We are aware of our obligations regarding information in our custody that is confidential to our customers – whether created by contract (under a non-disclosure agreement or service contract) or under statute such as the Law concerning Protection of Personal Information (Law No. 57 of 2003, hereinafter the “Personal Information Protection Law) and the Telecommunications Business Law (Law No. 86 of 1984, hereinafter, the “TBL”) – and are committed to ensuring that procedural safeguards are in place to protect against unauthorized disclosure of confidential information.

We are also aware that in certain instances customer confidential information may include “Personal Information” that allows a customer to be identified. Specifically, the Personal Information Protection Law defines personal information as information concerning living individuals, whereby a specific individual can be identified by name, date of birth, or other statements or the like contained in said information (including information that can easily be compared with other information to identify a specific individual) (“Personal Information”). Corporations and other groups do not correspond to “individuals” for purposes of the Personal Information Protection Law, but information concerning an officer of a corporation or the like does correspond to Personal Information.

This Privacy Policy describes the policies and procedures regarding the means in which we may use customer information containing Personal Information, and how we comply with Personal Information Protection Law, the Guidelines on Personal Information Protection in Telecommunications Business of the Japanese Ministry of Internal Affairs and Communications (MIC) (MIC Notice No. 695 of August 31, 2004 and Final Revision made MIC Notice No. 216 of June 24, 2015), the Guidelines for Personal Information Protection Law Concerning Fields of Economy and Industry of the Japanese Ministry of Economy, Trade and Industry (METI) (METI and MHLW Notice No. 4 of October 22, 2004 and Final Revision made METI and MHLW Notice No. 4 of December 12, 2014) and the TBL associated with Confidential Communications, and other applicable laws and ordinances.

We may modify or supplement this Privacy Policy from time to time. If we make any changes, we will provide a revised Privacy Policy that describes our new practices through the Colt Technology Services website.

Information we may collect

To provide its customers with telecommunication services, IT management services, cloud services and other services, we collect information that may not be available publicly. The types of information we may collect may include details of any customer’s name, address, telephone number, email address, fax number, video picture and voice. We will also collect transaction and experience information, as necessary. We also collect feedback from customers regarding our products, services and quality through customer satisfaction surveys distributed by mail or e-mail. In addition, we often sponsors seminars for customers, potential customers and others, where Personal Information may be collected.

Practices and procedures we follow to collect Personal Information and Purpose of Use

For the following purposes of use we collects Personal Information about you and your account from you through the use of order and registration forms, direct contact with you (for example, over the telephone, through our website and every time you email us your details). At data centers operated by us, surveillance cameras are installed to monitor and keep record of customers, visitors and others accessing, entering and existing for security purpose.

  • to administer your contracts and our business;
  • for billing, customer service and network management;
  • to provide you with information on our products and services or our third party partners tailored to your needs;
  • to obtain feedback from you in customer surveys so that we may design and improve products and services;
  • so that we know who you are to prevent unauthorised access to your information;
  • to perform statistical analyses;
  • to invite you to our-sponsored events and seminars;
  • to comply with the laws and regulations governing our business;
  • to ensure the security of our data centers; and
  • to do employment screening of your job application and labor management after your employment

We understands the importance of your Personal Information, and will only use your Personal Information in a way that is fair and lawful taking into account the extent to which it is necessary for us to use your Personal Information in its dealings with you and the purposes which are disclosed to you in this Privacy Policy, or which are relevant to the reason for your giving your Personal Information to us.

Security Management Measures

We control employee access to Personal Information. Our information security administrators educate and train our employees, including contract employees and temporary staff, to maintain strict confidentiality standards. Any employee who violates these standards is subject to discipline. We maintain organizational and technical protection measures (such as physical, electronic, and procedural safeguards) (“Security Management Measures”) to protect information and to prevent unauthorized or unlawful disclosure or access to or, negligent or unlawful loss, destruction, or alteration of customer information. We supervise our employees and provide education and training regarding our Security Management Measures to our personnel in an effort to manage the security of Personal Information that we collect.

How we share or provide Personal Information with or to third parties

We will not sell, trade or rent your Personal Information to others. We do not share or give customer information to unaffiliated firms for use in their marketing campaigns or sales programs. We may, however, entrust the handling of Personal Information to the service providers which we supervise, or if we receive your consent, we may share and/or transfer your Personal Information within our corporate family of companies and to carefully selected business partners and third party suppliers as joint use, when it is necessary to do so to process transactions, respond to your inquiries or as otherwise relevant to our dealings with you. In addition, we may share the information with government agencies or authorized third parties as required by law. For example, we may be required to share such information in response to a warrant issued by a court judge, or for a reason exempted from liability. Other than as set out in this Privacy Policy, or unless we have your consent, we will not disclose or share your Personal Information with any other third party

Retention of Personal Information

We will retain your Personal Information for as long as either required to by law, or as is relevant for the purposes for which it was collected. We will endeavor to maintain accurate and up-to-date Personal Information, within the scope necessary for the purpose for which such Personal Information was collected.

Questions from Individuals for their Personal Information

If you have a question or concern about this Privacy Policy or a complaint about the way we have used or is managing your Personal Information, you should contact our Personal Information Protection Manager, who has the responsibility to ensure our compliance with this Privacy Policy, and to respond to all enquiries from customers or any governmental authority.

Our Personal Information Protection Manager can be reached as follows.

3-1-35 Shibaura, Minato-ku Tokyo 108-0023 Japan,
Colt Technology Services Co., Ltd.
Risk Management Department
Attention: Personal Information Protection Manager

For more details on any inquiry, please refer to an explanatory statement on inquiries on personal information registered to us.