Cross Fields (the “Organization”) hereby establishes this Privacy Policy (the “Policy”) as the fundamental guideline governing the handling and management of personal information acquired by the Organization in connection with the operation of its business.
Article 1. Definition of Personal Information
For purposes of this Policy, “Personal Information” means “personal information” as defined under the Act on the Protection of Personal Information of Japan (the “APPI”), including information relating to a living individual, such as the individual’s name, date of birth, address, telephone number, and other contact details, as well as other descriptions or data that may identify a specific individual (including, but not limited to, information relating to appearance, voice, or any other personally identifiable information).
Article 2. Purpose of Use of Personal Information
The Organization shall acquire and use Personal Information solely for the following purposes (the “Purposes”):
- For the provision of services, the processing of applications, health management, and the execution of other administrative and operational tasks relating to the Organization’s businesses.
- For the smooth operation, safety management, and emergency response in relation to Organization’s businesses.
- For notifications and communications concerning events organized by the Organization.
- For the implementation of questionnaires, the preparation of publicity materials, and the collection of related information.
- For the examination, determination, and recording of the acceptance or rejection of applicants for employment with the Organization.
- For the communications with employees and former employees, and for human resources and labor management matters including employee management, performance evaluation, payment of salaries and other compensation, handling of transfers, promotions, leaves of absence, retirements, commendations, disciplinary actions, and other related matters.
- For the communications with supporters of the Organization in relation to donations and other related matters.
Article 3. Provision of Personal Information to Third Parties
The Organization shall not provide any Personal Information of a data subject to any third party without the prior consent of such data subject, except when permitted or required under applicable laws and regulations.
Notwithstanding the foregoing, the Organization may entrust the processing of Personal Information to a third party to the extent necessary for the execution of the Organization’s operations, the conduct of its businesses activities, and the achievement of the Purposes, in accordance with the APPI. In such a case, the Organization shall provide such entrusted third party with the Personal Information to the extent necessary for such processing, and shall supervise such entrusted party to ensure that the Personal Information is processed in compliance with applicable laws and regulations. The entrusted third party shall not use the Personal Information provided for any purpose other than those expressly instructed by the Organization.
Article 4. Requests for Disclosure, Correction, or Deletion of Personal Information
1.Disclosure of Information
In the event that the Organization receives a request from a data subject for the disclosure of Personal Information, the Organization shall first verify the identity of the requesting individual. Upon completion of such verification, the Organization shall review such request in accordance with the APPI. Should the Organization determine that the requested information cannot be disclosed, in whole or in part, the Organization shall notify the data subject to that effect.
2.orrection and Deletion of Information
In the event that a data subject becomes aware that certain Personal Information previously submitted to the Organization is inaccurate, the data subject shall request the correction of such information as soon as practicable. The Organization shall review such request, and if it determines that a correction is warranted, it shall amend the relevant Personal Information accordingly. If the Organization determines that correction is unnecessary or inappropriate, it shall notify the data subject of such determination.
The Organization shall retain Personal Information of the data subject for the period necessary to achieve the Purposes set forth in this Policy, and thereafter for any additional period as may be required under applicable laws and regulations or under the internal rules of the Organization.
Article 6. Data Security
- The Organization shall implement appropriate technical, physical, and organizational measures and controls in order to protect the transmission and storage of information collected by the Organization.
- The Organization shall adopt reasonable safeguards for Personal Information in accordance with its importance and the level of protection required.
- The Organization shall make reasonable efforts to protect the Personal Information under its control from threats of unauthorized access, and shall endeavor to prevent leakage, loss, or damage of such Personal Information.
- In the event that any leakage of Personal Information or other security incident occurs, the Organization shall promptly notify the affected data subject and shall take the necessary measures in accordance with applicable laws and regulations.
Article 7. Amendment of this Policy
The Organization may, at its sole discretion, amend or update this Policy at any time and for any reason. In the event of any amendment to this Policy, the Organization shall provide reasonable prior notice to the data subject of the details of such amendment before the amendment takes effect. The amended Policy shall be posted on the Organization’s website and shall become effective as of its effective date.
Article 8. Business Operator Handling Personal Information
The name, address, and representative of the business operator handling Personal Information are as follows:
- Name of Business Operator: Cross Fields
- Address: Machihara Building 4F, 3-8-3 Nishi-Gotanda, Shinagawa, Tokyo, JAPAN
- Name of Representative: Daichi Konuma
Enacted on July 10, 2025
