DISCO Inc. Global Privacy Policy (GDPR/CCPA, etc.)

This page has been translated from the official Japanese language version into English solely for the convenience of international readers. The Japanese original text shall prevail in case of any discrepancy.

I. Our Privacy Statement.

The protection of your personal data is of great importance to DISCO Inc. (“Company,” “we,” “us,” “our”).
We process the personal data of customers, including candidates who use the CFN (Career Forum.Net) and GC (GlobalCareer.com) platforms, the visitors of our website and the contact person of our client companies in the UK or the EEA, to whom those regulations apply (referred to as a “Customer” or “you” throughout this global privacy policy) in accordance with the applicable EU and EU Member States’ regulations on data protection, in particular the General Data Protection Regulation 2016/679 and the GDPR as amended by the Data Protection, Privacy and Electronic Communications(Amendments etc.) (EU Exit) Regulations 2019 and incorporated into UK law by the European Union (Withdrawal) Act 2018 (the “UK GDPR”; the GDPR and UK GDPR are collectively the “GDPR”), the California Consumer Privacy Act (the “CCPA”), and other personal information protection regulations. This global privacy policy explains how we, as the data controller, obtain and process your personal data and your rights, etc. in relation to our processing. This global privacy policy also supplements our Privacy Statement available at: <https://www.disc.co.jp/en/privacy/> and prevails over any conflicting provisions therein. The GDPR Special Provisions and CCPA Special Provisions are included in this Addendum, but if this Addendum conflicts with the special provisions, the special provisions will prevail.

II. Legal Bases for Processing / Categories of Personal Data Subject to Processing

We process the following categories of your personal data.

  1. 1. Categories of Personal Data Subject to Processing We collect the following data directly from you when you sign up to use our services or visit our website or platform:
    • Identity and Contact Data, including real name, nickname, alias, current address, postal address, telephone number, login ID for account, email address, Skype ID, Facebook or other SNS ID, work permit/visa status.
    • Profile, including the languages you speak, language skill and your characteristics such as birth date, age, sex, gender, and citizenship.
    • Education Information, including educational information and educational background such as university name, major category, major, degree, graduation date, GPA.
    • Employment Information, including employment information and employment history such as company name, type of business, position title, period at position, job category, career level, employment type, job description, current/most recent annual income, skills and qualifications.
    • Internet or other similar network activity information, including internet protocol address, IMEI, Universally Unique Identifier, cookie data, browsing history or search history of our website, referrer URL, language preference, and other information regarding your interaction with our websites and platforms. We collect most of this information through cookies and similar technology, you can find more information about this in the cookies section below.
    • Events, including the events and job fairs that you are interested in and any information you provide to us when you make a reservation or attend one of our events and job fair.
    • Direct marketing preference, your direct marketing preferences.
    • Other information you provide in your resume, job applications, surveys, replies to questions for applicants set by companies (we will receive replies and submit them to the relevant companies only when questions are set by companies) and other similar correspondence in connection with your use of our websites and online services.

    Provision of your personal data is mandatory in some cases. Without you providing the required data, we would not be able to provide our service to you. Where the provision of the information is mandatory we will make it clear to you at the time we collect it.

    We do not conduct any solely automated decision-making that produces any legal or similar material effect on you.

III. Sources of Personal Data

We obtain your personal data directly from you (with respect to both online and offline interactions you may have with us or our service providers including from the devices you use to access our websites, mobile applications, and online services) or indirectly through third parties such as those stated below.

  • third parties, including third parties to which you have previously provided your information such as social media platforms (e.g., Facebook)

IV. Retention Period for Personal Data

We will retain your personal data for as long as necessary to fulfil the aforementioned purposes for obtaining and processing your personal data. Specific retention periods are decided based on the following considerations: the purpose for obtaining and processing the personal data; the nature of the personal data; and the necessity of retaining the personal data for legal or business reasons.

V. Sharing and Disclosure of Personal Data

We share and disclose your personal data to the following third parties for the purposes stated in this global privacy policy.

  • DISCO International, Inc., as a processor for the Company
  • Recruiting/hiring companies to whom you apply through the CFN/GC services
  • Marketing and sales promotion service providers
  • System development and maintenance service providers

As a result of the aforementioned sharing and disclosure, in some cases your personal data will be transferred to the following third countries:
  • Japan
  • the United States
  • the UK (if you are located in the EEA)
  • Hungary
  • Vietnam
  • countries in which companies you apply to are located

VI. Your Rights

You have the rights regarding personal data obtained and processed by us in accordance with applicable personal information protection regulations.
If you intend to exercise these rights, please inquire using the contact details at the end of this global privacy policy.
You can lodge a complaint in relation to our processing of your personal data with the competent Data Protection Supervisory Authority.

VII. Amendment to this Global Privacy Policy

We amend this global privacy policy from time to time. We will contact you through this website and by e-mail if necessary, when we make any substantive or material amendments.

VIII. Contact Details

For questions or inquiries regarding this global privacy policy, please contact the below contact person. If we establish a representative in each country based on applicable personal information protection regulations, the contact details will be listed in the special rules (for the representative for the GDPR, see “4. Representatives in the EEA and the United Kingdom” in “IX. Special Provisions concerning the GDPR”).

Data Controller
DISCO Inc.
Iidabashi First Building 9F,
2-5-1 Koraku, Bunkyo-ku, Tokyo 112-0004
privacy-madoguchi@disc.co.jp

IX. Special Provisions concerning the GDPR

These special provisions apply to processed personal data to which the GDPR applies.

  1. 1. Legal Bases for Processing of Personal Data
    • When processing is required for the pursuit of legitimate interests: We obtain and process your personal data for the following purposes because it is necessary to do so in order to pursue our legitimate interests (for details regarding the balancing test for legitimate interests, please inquire using the contact details in the section “VIII. (Contact Details)” of this global privacy policy):
      • To send and authenticate account login IDs and passwords;
      • To send information pertaining to employment, career change, and further education from the Company, or individual companies, schools and organizations, etc. which entrusted such information to the Company, to the candidates who are interested in those individual companies, schools or organizations, etc.;
      • To conduct studies and surveys pertaining to employment, career change, further education and studying abroad;
      • To provide information considered useful for preparing to work for a company as a new working adult, or for career enhancement and skill improvement;
      • To verify clients and their contact persons in the event of use of our products and services, to confirm the Company’s standards for use of products and services upon such use, and to conduct various other types of verification/confirmation;
      • To reply to and contact persons who have made an inquiry, registered a complaint, or requested a consultation;
      • To confirm the identity of persons who make an inquiry;
      • To perform and analyze the results of market surveys for the purpose of improving existing products and services and developing new products and services; and
      • To establish, exercise or defend legal claims.
    • When processing is required for the performance of or entry into a contract with you to provide services to you: We obtain and process your personal data for the following purposes because it is necessary to do so in order to perform contractual obligations to provide services to you:
      • To provide services to members in accordance with the membership agreement;
      • To verify your identity;
      • To process your payment details for participating in our events and providing products and services you have requested;
      • To receive and confirm reservations;
      • To announce results of our lotteries;
      • To provide you with customer service;
      • To perform work within the scope of work requests received from you; and
      • To perform necessary office procedures and billing operations in connection with providing products and services.
    • When your express consent is obtained in advance: We will obtain and process your personal data for the following purposes if we have obtained your express consent in advance:
      • To provide notification of upcoming events, etc. in connection with events organized or operated by the Company as well as other marketing communications we think you may be interested in; and
      • To place cookies or similar technologies on your device.
    You have the right to withdraw your consent at any time by the method communicated to you by us when seeking your consent. However, your withdrawal of consent will not affect the legality of processing conducted based on your consent before its withdrawal. You have an absolute right to opt-out of direct marketing at any time. You can do this by following the instructions in the communications when using electronic messages, or by contacting us using the details set out below.
  2. 2. Legal Bases for Transfers of Personal Data
    The legal bases for transfers we perform of personal data to outside the EEA or the United Kingdom shall be an adequacy decision, where one has been made with respect to the destination country (GDPR Article 45), or, where one has not been made, the transfer’s being necessary for performance of the agreement between the data subject and the controller (GDPR Article 49(1)(b)).
  3. 3. Your Rights
    You have the following rights regarding personal data obtained and processed by us.
    • Obtaining information regarding processing of data: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you (Articles 13 and 14 of the GDPR).
    • Access to personal data: You have the right to obtain from us confirmation as to whether personal data concerning you are being processed, and, if so, then access to the personal data and certain related information (Article 15 of the GDPR).
    • Rectification or erasure of personal data: You have the right to have us rectify inaccurate personal data concerning you without undue delay and the right to have us complete any incomplete personal data (Article 16 of the GDPR). Also, if certain conditions are satisfied, you will have the right to have us delete personal data concerning you without undue delay (Article 17 of the GDPR).
    • Restriction on processing of personal data: If certain conditions are satisfied, you will have the right to have us restrict processing of personal data concerning you (Article 18 of the GDPR).
    • Objection to processing of personal data: If certain conditions are satisfied, you will have the right to object to processing of personal data concerning you (Article 21 of the GDPR).
    • Data portability of personal data: If certain conditions are satisfied, you will have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format and the right to transfer those data to another controller without hindrance from us (Article 20 of the GDPR).
    • Not to be subject to automated decision-making: If certain conditions are satisfied, you will have the right not to be subject to solely data-based, automated decision-making (including profiling) that produces any legal or similar material effect on you (Article 22 of the GDPR).
    These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the local data protection laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

    You can lodge a complaint with the Data Protection Supervisory Authority of your habitual residence (in the case of an EEA Member State, here ; in the case of the United Kingdom, the UK Information Commissioner’s Office).
  4. 4. Representatives in the EEA and the United Kingdom
    *When making inquiries to the representatives, please be sure to do so with < DISCO Inc.> entered in the subject line.

    <Within the EEA>
    datarequest@datarep.com
    Data Protection Representative Limited
    72 rue de Lessard, Rouen, 76100, France

    <Within the United Kingdom>
    datarequest@datarep.com
    Data Protection Representative Limited
    107-111 Fleet Street, London, EC4A 2AB, United Kingdom

X. Special Provisions concerning the CCPA

  1. 1. California Personal Information
    We describe our general practices of handling personal information in the section of our Privacy Policy titled, “Types and Purposes of Use of Personal Information Acquired by the Company”.
    • (1) Categories of California Personal Information
      In the past 12 months, we have collected the following categories of California Personal Information.
      Category Example
      Identifiers A real name, nickname, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, Skype ID, Facebook ID, or other SNS ID, IMEI, UUID
      Cookie, work permit/visa status.
      Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). The identifiers above, telephone number, education information, employment information, and employment history.


      This category may overlap with other categories.
      Protected classification characteristics under California or federal law. Age, sex, gender, and citizenship, etc.
      Information on personal assets; information on purchases, acquisitions, and products and services considered for purchase; and other commercial information on purchase and consumption histories and trends, etc. Events (including events and job fairs that you are interested in and information you provide to us when making a reservation for or attending one of our events or job fairs) and your settings concerning direct marketing.
      Internet or other similar network activity. Browsing history, search history, referrer URL, language preference, and other information regarding a consumer’s interaction with our websites and online services.
      Professional or employment-related information. Company name, type of business, position title, period at position, job category, career level, employment type, job description, skills, qualifications, current/most recent annual income, and other information you provide in your resume, job applications, surveys, replies to questions for applicants set by companies and other similar correspondence in connection with your use of our websites and online services, birth date, age, languages you speak, and language skill.
      Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Educational information (including educational information and education history information such as university names, major categories, majors, degrees, graduation dates, GPAs, etc.)
      California Personal Information does not include publicly available information from government records, deidentified or aggregate consumer information, or other personal information excluded from the CCPA’s scope.
    • (2) Categories of Sources of California Personal Information
      Within the past 12 months we have obtained California Personal Information from the following sources:
      • directly and indirectly from you, with respect to both online and offline interactions you may have with us or our service providers including from the devices you use to access our websites, mobile applications, and online services; and
      • from third parties, including third parties to which you have previously provided your information and authorized them to disclose your information to us, such as social media platforms (e.g., Facebook log-in).
  2. 2. Recipients of California Personal Information
    Within the preceding 12 months, we have disclosed California Personal Information to the following categories of third parties
    Categories of Personal Information Categories of 3Ps with Whom we Shared Personal Information for a Business Purpose
    Identifiers.
    • Recruiting/hiring companies to whom you apply through the CFN/GC services
    • Marketing and sales promotion service providers
    • System development and maintenance service providers
    • Our subsidiaries (which serve as marketing, sales promotion or event management service providers)
    Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
    • Recruiting/hiring companies to whom you apply through the CFN/GC services
    • Marketing and sales promotion service providers
    • System development and maintenance service providers
    • Our subsidiaries (which serve as marketing, sales promotion or event management service providers)
    Protected classification characteristics under California or federal law.
    • Recruiting/hiring companies to whom you apply through the CFN/GC services
    Information on personal assets; information on purchases, acquisitions, and products and services considered for purchase; and other commercial information on purchase and consumption histories and trends, etc.
    • Recruiting/hiring companies to whom you apply through the CFN/GC services
    • Marketing and sales-promotion service providers
    • System development and maintenance service providers
    • Our subsidiaries (which are serving as marketing, sales-promotion, or event-management service providers)
    Internet or other similar network activity.
    • N/A
    Professional or employment-related information.
    • Recruiting/hiring companies to whom you apply through the CFN/GC services
    Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
    • Recruiting/hiring companies to whom you apply through the CFN/GC services
    We do not sell, and, within the preceding 12 months, we have not sold, California Personal Information, including the California Personal Information of consumers who we actually know are less than 16 years of age.
  3. 3. Your Rights Regarding California Personal Information.
    California residents have certain rights with respect to California Personal Information collected by businesses. If you are a California resident, you may exercise the following rights regarding your California Personal Information, subject to certain exceptions and limitations:
    • The right to know the categories of California Personal Information we collect, use, disclose, and sell about you, the categories of sources from which we collected your California Personal Information, our purposes for collecting or selling your California Personal Information, the categories of your California Personal Information that we have disclosed for a business purpose, and the categories of third parties with which we have shared personal information. You also have the right to request a copy of specific pieces of your California Personal Information.
    • The right to delete the California Personal Information we have collected from you or maintain about you.
    • The right to opt out of a sale of your California Personal Information. Please note however that we do not sell your California Personal Information, and therefore we do not support requests to opt out of a sale of California Personal Information.
    • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights, including by denying you goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your California Personal Information. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
    • Other California Privacy Rights. Under California’s “Shine the Light” law (Civil Code Section § 1798.83), you, as a California resident, may ask us to provide a list of what personal information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. You may also ask us to refrain from sharing your personal information with third parties for their marketing purposes. Please note however that we do not disclose your personal information to third parties for their direct marketing purposes, and therefore we do not support aforementioned requests.

    Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request. Although you will not be required to create an account with us to submit a request or have it fulfilled, we may ask you to provide certain California Personal Information as part of our verification process, including name, email address and member ID, which we already maintain

    Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by submitting the written power of attorney or by providing the agent with written permission to act on your behalf. As permitted by law, we may require verification of the agent’s authorization or require you to verify your own identity in response to a request even if you choose to use an agent.

    Please note that we may not be able to respond to your request or provide you with your California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.
  4. 4. California Do Not Track Disclosure.
    Our website and mobile app are not designed to respond to “do not track” signals or other consumer choice mechanisms from browsers for personal information collected over time and across third-party websites or online services.

Established May 25, 2018
Revised April 1, 2022