S&K Brussels Consulting Co., Ltd.

Privacy Policy

S&K Brussels Consulting Co., Ltd ("S&K Brussels Consulting," "we," "our") has established the following privacy policy ("Privacy Policy") for the handling of personal information within S&K Brussels Consulting. S&K Brussels Consulting shall comply with this policy as well as the Act on the Protection of Personal Information (Act No. 57 of 2003) ("APPI") and all other applicable laws and regulations.

1. Acquisition of Personal Information

S&K Brussels Consulting shall specify the purposes of use of Personal Information and acquire Personal Information in the necessary scope and appropriate manner. S&K Brussels Consulting shall, except in those cases based on the APPI and or other applicable laws and regulations, not acquire special care-required personal information ("Sensitive Personal Information") without the prior consent of the individual concerned.

2. Purposes of Use of Personal Information

S&K Brussels Consulting shall use Personal Information only within the scope of the purposes stated below unless separately notified or except otherwise approved by laws and regulations.

Purposes of Use of Personal Information Categories of Personal Information
1.
  • Provision of consulting services;
  • Responding to various types of inquiries, or the like; or
  • Other purposes incidental to those mentioned above.
 Information obtained in connection with the provision of consulting services by S&K Brussels Consulting, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.);
  • Client information (client information made available to S&K Brussels Consulting in the course of providing consulting services to our clients); and
  • Business and professional information (job title, function or position, organization, work experience, and academic experience, information relating to business activities such as attendance at business workshops, lectures, seminars, meetings, and other professional events, and any other personal data related to business and professional activities, etc.).
2.
  • Provision of information regarding activities of S&K Brussels Consulting (including sending or transmitting letters of greeting, season’s greetings, etc.);
  • Provision of information regarding workshops, lectures, seminars, and other events, and accepting applications to attend or participate in such events;
  • Sending or transmission of, or receipt of applications for, newsletters;
  • Provision of other information, or receipt of requests for, or inquiries regarding, the provision of such information; or
  • Other purposes incidental to those mentioned above.
 Information obtained in connection with the provision of consulting related information or details concerning the possibility of providing consulting related information by S&K Brussels Consulting, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.); and
  • Business and professional information (job title, function or position, organization, work experience, and academic experience, information relating to business activities such as attendance at business workshops, lectures, seminars, meetings, and other professional events, and any other personal data related to business and professional activities, etc.).
3.
  • Provision of information, or receipt of applications for, or inquiries regarding recruitment;
  • Employment selection (for job applicants);
  • Ongoing communications and provision of information regarding S&K Brussels Consulting to applicants for recruitment or those who have received an informal employment commitment;
  • Personnel management and training for those who have received formal employment offers; or
  • Other purposes incidental to those mentioned above.
 Information obtained in connection with the recruitment of consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Information to be submitted at the time of employment (curriculum vitae, work experience, results of aptitude tests, grades and degree certificates issued by higher education institutions such as universities and professional education institutions, grades and certificates issued by accredited qualification test institutes, etc.)
4.
  • Personnel management and training; or
  • Other purposes incidental to those mentioned above.
 Information obtained in connection with the recruitment of consultants, other professionals, staff, or interns of S&K Brussels Consulting, and in connection with personnel management and training for those who have received formal employment offers, including the following:
  • Information submitted at the time of employment (curriculum vitae, work experience, results of aptitude tests, grades and degree certificates issued by higher education institutions such as universities and professional education institutions, grades and certificates issued by accredited qualification test institutes, etc.); and
  • Personnel Performance Evaluation Information
5.
  • Assessing the health of consultants, other professionals, staff, or interns of S&K Brussels Consulting
 Information obtained in connection with the management of the health condition of consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Sensitive Personal Information (health data such as health checkup results, etc.)
6.
  • Withholding tax collection and social insurance-related affairs, etc.
 Information obtained in connection with withholding tax collection and social insurance-related affairs of consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Specific Personal Information (including information on family dependents); and
  • Salary and compensation-related documents
7.
  • Provision of payroll and social insurance services
 Information obtained in connection with the provision of payroll and social insurance services of consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Salary related documents (including bank account information)
8.
  • Provision of payroll and social insurance services
  • Emergency communications involving consultants, other professionals, staff, or interns of S&K Brussels Consulting
 Information obtained in connection with the provision of payroll and social insurance services and emergency preparation for consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.) of the above attorneys, other professionals, staff, or interns’ respective family members.
9.
  • Provision of payroll and social insurance services, related communications, etc.
 Information submitted by retirees of S&K Brussels Consulting at the time of resignation, including the following:
  • Information submitted at the time of resignation, address, and contact details after resignation.
10.
  • Provision of compensation and expense reimbursement-related services
 Bank account information
11.
  • Registration of S&K Brussels Consulting’s system
 Biometric information, passwords
12.
  • Publication on the S&K Brussels Consulting’s website and in various media for publicity, advertising, recruitment activities, etc.
 Photography and interview information (interview information such as name, organization, photo, and business description)

3. Provision of Personal Data to Third Parties and Extraterritorial Transfers

S&K Brussels Consulting shall comply with the APPI and all other relevant laws and regulations regarding the provision of personal data to third parties and extraterritorial transfers, including, where necessary, obtaining the consent of the relevant individual. In relation to some of the personal information handled by S&K Brussels Consulting, the consent of the individual concerned under the APPI shall not be obtained, as the provision and extraterritorial transfer of said personal information to third parties is conducted in a manner that can ensure the continued implementation of measures equivalent to those required to be taken by personal information handling business operators under the APPI below.

  • Provision to third parties and extraterritorial transfer from S&K Brussels Consulting to S&K Brussels BV in accordance with this Privacy Policy.
  • Provision to third parties and extraterritorial transfer, such as S&K Brussels BV and other companies with whom S&K Brussels Consulting has entered into an outsourcing agreement that includes non-disclosure obligations regarding the handling of personal information.

The foreign countries to which the extraterritorial transfer of personal data may be provided are Belgium, where S&K Brussels BV is located. For information on the personal information protection systems of these countries, please refer to the following:

  • The personal information protection system in Belgium:
    • Belgium is an EEA member country and is prescribed by the Personal Information Protection Commission of Japan as a country establishing a personal information protection system recognized to have equivalent standards to that in Japan in regard to the protection of an individual’s rights and interests.
    • https://www.ppc.go.jp/files/pdf/200201_h31iinkaikokuji01.pdf

4. Joint Use of Personal Data

S&K Brussels LPC and/or S&K Brussels BV may jointly use personal data acquired by S&K Brussels Consulting in accordance with the description in "1: Joint Use within S&K Brussels Group."

[1: Joint Use within S&K Brussels Group]

a) Scope of joint use

S&K Brussels Consulting, S&K Brussels LPC and S&K Brussels BV (collectively, "S&K Brussels Group")

b) Person(s) responsible for the management of said personal data

S&K Brussels Consulting

c) Purpose of use and categories of personal information to be jointly used by the persons using the data

Purposes of Joint Use of Personal Data Categories of Personal Data to be Jointly Used
1.
  • Provision of consulting services;
  • Responding to various types of inquiries, or the like; or
  • Other purposes incidental to those mentioned above.
 Information obtained in connection with the provision of consulting services by S&K Brussels Consulting, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.);
  • Client information (client information made available to S&K Brussels Consulting in the course of providing consulting services to our clients); and
  • Business and professional information (job title, function or position, organization, work experience, and academic experience, information relating to business activities such as attendance at business workshops, lectures, seminars, meetings, and other professional events, and any other personal data related to business and professional activities, etc.). S&K Brussels Consulting
2.
  • Provision of information regarding activities of S&K Brussels Consulting (including sending or transmitting letters of greeting, season’s greetings, etc.);
  • Provision of information regarding workshops, lectures, seminars, and other events, and accepting applications to attend or participate in such events;
  • Sending or transmission of, or receipt of applications for, newsletters;
  • Provision of other information, or receipt of requests for, or inquiries regarding, the provision of such information; or
  • Other purposes incidental to those mentioned above.
 Information obtained in connection with the provision of consulting related information or details concerning the possibility of providing consulting related information by S&K Brussels Consulting, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.); and
  • Business and professional information (job title, function or position, organization, work experience, and academic experience, information relating to business activities such as attendance at business workshops, lectures, seminars, meetings, and other professional events, and any other personal data related to business and professional activities, etc.).
3.
  • Provision of information, or receipt of applications for, or inquiries regarding recruitment;
  • Employment selection (for job applicants);
  • Ongoing communications and provision of information regarding S&K Brussels Consulting to applicants for recruitment or those who have received an informal employment commitment;
  • Personnel management and training for those who have received formal employment offers; or
  • Other purposes incidental to those mentioned above.
 Information obtained in connection with the recruitment of consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Information to be submitted at the time of employment (curriculum vitae, work experience, results of aptitude tests, grades and degree certificates issued by higher education institutions such as universities and professional education institutions, grades and certificates issued by accredited qualification test institutes, etc.)
4.
  • Personnel management and training; or
  • Other purposes incidental to those mentioned above.
 Information obtained in connection with the recruitment of consultants, other professionals, staff, or interns of S&K Brussels Consulting and in connection with personnel management and training for those who have received formal employment offers, including the following:
  • Information submitted at the time of employment (curriculum vitae, work experience, results of aptitude tests, grades and degree certificates issued by higher education institutions such as universities and professional education institutions, grades and certificates issued by accredited qualification test institutes, etc.); and
  • Personnel Performance Information
5.
  • Assessing the health of consultants, other professionals, staff, or interns of S&K Brussels Consulting
 Information obtained in connection with the management of the health condition of consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Sensitive Personal Information (health data such as health checkup results, etc.)
6.
  • Provision of payroll and social insurance services, related communications, etc.
 Information submitted by retirees of S&K Brussels Consulting at the time of resignation, including the following:
  • Information submitted at the time of resignation, address, and contact details after resignation.
7.
  • Registration of S&K Brussels Consulting’s system
 Biometric information and passwords
8.
  • Publication on the S&K Brussels Consulting’s website and in various media for publicity, advertising, recruitment activities, etc.
 Photography and interview information (interview information such as name, organization, photo, and business description)

5. Security Management of Personal Data

S&K Brussels Consulting takes the following appropriate measures to prevent disclosure, loss, impairment, and or any other mishandling of personal data:

a) Formulation of a basic policy

This Privacy Policy has been established as a basic policy to ensure the appropriate handling of personal information and to provide a point of contact for questions and complaints.

b) Establishment of rules for the handling of personal data

Basic handling procedures have been established for the collection, use, and storage of personal data.

c) Organizational security management measures

(i) The responsible person confirms that personal information is handled in accordance with the established handling procedures.

(ii) A reporting and communication system from employees to the responsible person has been established.

d) Human security management measures

(i) Regular training is provided to employees, etc., on points to keep in mind regarding the handling of personal data.

(ii) Matters relating to the confidentiality of personal information are included in employment contracts and outsourcing agreements.

e) Physical security management measures

(i) Measures are taken to ensure that personal data cannot be easily accessed by anyone other than employees, etc., who are authorized to handle personal data and the relevant individual.

(ii) Measures are taken to prevent theft or loss of equipment, electronic media, and documents that handle personal information.

(iii) Measures are taken to ensure that personal information is not easily revealed when equipment, electronic media, etc., that handle personal information are transported, including transfers between offices of S&K Brussels Consulting.

f) Technical security management measures

(i) Equipment capable of handling personal data and employees, etc., who handle such equipment are clearly identified to prevent unwanted access to personal data.

(ii) Mechanisms are in place to protect information systems that handle personal information from unauthorized external access or unauthorized software.

g) Understanding the external environment

S&K Brussels Consulting stores personal information on servers located in Japan, which are provided by a cloud service provider located in Japan.

6. Requests for Notification of Purposes of Use, Disclosure, Correction, Discontinuation of Use, or other Handling of Personal Information

Upon receiving a request to disclose the retained personal data or its purpose(s) of use; to disclose, correct, supplement or delete the personal information; to temporarily suspend or permanently discontinue the use of the personal data; to discontinue the provision of personal data to a third party; etc., S&K Brussels Consulting shall, after confirming the identity and relevance of the person making the request, respond promptly and in good faith, in accordance with the provisions of the APPI. Please note that we may not be able to respond to a request if it does not satisfy the requirements prescribed by the APPI, or if there is cause to decline the request in accordance with applicable laws and regulations.

7. Contact for Inquiries

Requests for disclosure, comments, questions, complaints, and other inquiries with respect to our handling of personal information should be referred to our Data Protection Manager Office at the contact details below:

Data Protection Manager Office
S&K Brussels Consulting Co., Ltd
ACN Omori-ekimae Building 6th floor
1-17-13 Omori-kita, Ota-City, Tokyo 143-0016
Japan
E-mail: dpm@sandkbc.com

8. Amendment to this Privacy Policy

In an effort to improve our policies and procedures for the handling of personal information, S&K Brussels Consulting shall periodically review and amend this Privacy Policy.

Last updated on November 1, 2023

European Economic Area /
United Kingdom Privacy Policy

1. OUR EEA/UK PRIVACY POLICY

This European Economic Area / United Kingdom Privacy Policy ("EEA/UK Privacy Policy") is provided on behalf of S&K Brussels Consulting Co., Ltd. ("S&K Brussels Consulting," "we," "us" or "our") and applies to the personal data we collect or otherwise process about individuals located in the European Economic Area ("EEA") and the United Kingdom ("UK"). The purpose of this EEA/UK Privacy Policy is to explain our practices for collecting, sharing and using the personal data we obtain about you, from our interactions with you or via third parties, and to inform you of your rights and options regarding the ways in which your data is processed.
We collect and process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and other data protection laws and regulations applicable to the EEA and the UK.
If you have any queries relating to this EEA/UK Privacy Policy, please contact our Data Protection Manager Office at dpm@sandkbc.com (additional contact details are set forth in Section 9 below, entitled "CONTACT US").

2. WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU?

We process the following categories of personal data in the course of our business operations:

  • Identity and contact details, including name, title, postal address, e-mail address, phone number, date of birth, passport number, gender, photographic identification, professional license number, government-issued identification number, etc.;
  • Client information made available to us by or on behalf of clients or generated by us in the course of providing consulting services to our clients, including in the context of a dispute, compliance matter, investigation, litigation, settlement, etc.;
  • Financial and payment information, including bank account details and any other personal data necessary for payment;
  • Business and professional information, including job title, function or position, organization, work experience and academic experience, information relating to business activities such as attendance at business seminars, meetings and other professional events, and any other personal data related to your business and professional activities;
  • Sensitive data, including data pertaining to racial or ethnic origin, political opinions, religious or philosophical beliefs and health data, which may be relevant to our provision of consulting services pertaining to sensitive matters, such as criminal and employment issues.
  • Any other information that you provide us and which can be used to identify you.

3. HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect information about you during our direct interactions with you, as well as from third parties.
We receive or otherwise gather personal data directly from you, including when you enquire about, or communicate with us in respect to, our consulting services; when you register for or attend our events; when you participate in surveys or questionnaires or subscribe to our mailing list; when you contact us in the context of recruitment; and when you in any way engage with us or our personnel in the operation of our business.
Your personal data may also be provided to us by third parties, including when we provide consulting services to third parties pertaining to matters in which you are involved; during communications with third parties regarding any professional activities in which you are involved; and when we receive or obtain your personal data in the context of our third party recruitment activities, including from publicly-available sources.

4. HOW DO WE USE YOUR PERSONAL DATA?

We limit our collection and use of your personal data to that which is necessary in relation to the purposes for which they are collected or otherwise processed. The legal basis for processing your personal data will generally be our legitimate interest in relation to providing consulting services to our clients, however we also process personal data to fulfill contractual and other legal obligations.
The specific purposes and legal bases governing our collection and processing of your personal data are set forth below. Should we intend to process your personal data for any purpose other than the purposes noted below, we will notify you by amending this EEA/UK Privacy Policy in accordance with Section 8 below, entitled "UPDATES TO PRIVACY POLICY".

Specific Purpose Categories of Personal Data Legal Basis
To provide consulting services to our clients, including in the context of a dispute, compliance matter, investigation, litigation, settlement or other legal matter
  • Identity and contact details
  • Client information
  • Business and professional information
  • Sensitive data
  • Legitimate interest: communicating with the relevant parties and providing consulting services
To provide consulting services to our clients, including in the context of a dispute, compliance matter, investigation, litigation, settlement or other legal matter
  • Sensitive data
  • Consent
  • Legal obligation; or
  • Establishment, exercise or defense of legal claims
To send invoices and receive fees; to communicate about and otherwise manage other payments, fees and charges.
  • Identity and contact details
  • Client information
  • Financial and payment data
  • Business and professional information
  • Legitimate interest: communicating with the relevant parties, managing payments, fees and charges and collecting consulting fees
To respond to inquiries and fulfill requests.
  • Identity and contact details
  • Client information
  • Any other information you provide
  • Legitimate interest: communicating with the relevant parties and providing requested information
To manage marketing and public relations activities, including organizing or advertising business seminars, conferences, webinars and workshops; to respond to or organize media requests.
  • Identity and contact details
  • Business and professional information
  • Legitimate interest: communicating with the relevant parties and managing business and marketing activities
To manage subscription preferences and send marketing communications and questionnaires.
  • Identity and contact details
  • Business and professional information
  • Consent
To manage human resources; to process employee/personnel information for the provision of benefits and related services.
  • Identity and contact details
  • Business and professional information
  • Legitimate interest: communicating with the relevant parties and managing employment matters
To manage recruitment activities.
  • Identity and contact details
  • Business and professional information
  • Legitimate interest: communicating with candidates and other relevant parties and evaluating candidates for recruitment

*Please contact us should you wish to obtain further information about processing based on legitimate interest.

 

Please note that we only process sensitive personal data in the following circumstances: you have given us your explicit consent; the processing is necessary to meet a legal or regulatory obligation; or the processing is otherwise expressly permitted under the GDPR or other relevant laws or regulations.

5. HOW LONG DO WE KEEP YOUR DATA?

We retain your personal data for as long as necessary to fulfill the purpose(s) for which we collected it, but in any case, for the duration of our contractual or business relationship with you and/or your organization, or as otherwise legally or statutorily required, including by EU and UK legislation applicable to our business activities.
To determine the appropriate retention period for your personal data, we take into consideration the purpose(s) for its collection and use; whether we can achieve those purpose(s) by other means; the amount, nature and sensitivity of the data; the potential risk of harm in the case of its unauthorized use or disclosure; and all applicable legal and statutory requirements.

6. HOW DO WE SHARE YOUR PERSONAL DATA?

Your personal data may be transferred to, as well as accessed and stored within, a country or territory outside the EEA and UK, including to countries whose laws may not offer the same level of protection of personal data as the EEA and the UK. We are committed to complying with the GDPR and the relevant data protection laws in the UK regarding the transfer of personal data from the EEA and UK, and we will ensure that any international transfers are subject to adequate safeguards as required under the GDPR, including the European Commission’s Standard Contractual Clauses and adequacy decision for Japan, as well as the relevant data protection laws in the UK such as the UK’s International Data Transfer Agreement.
We may also share your personal data with public institutions and companies outside of S&K Brussels Consulting, including our business partners and clients, provided and to the extent that such sharing is necessary for the provision of our consulting services or any other business operations.
In certain circumstances, such as investigations and legal proceedings, we may find it necessary to disclose your personal data to law enforcement agencies, regulatory bodies, courts and other public institutions. In such instances, we will share your personal data to the extent that we are compelled, instructed or otherwise requested to do so by such institutions and authorities. We may also share your personal data if we determine that disclosure is necessary to comply with any law or regulation applicable to us or to satisfy our professional duties toward our clients.
We may additionally disclose your personal data if we determine in good faith that the disclosure is reasonably necessary to protect the legitimate rights and interests of S&K Brussels Consulting, our personnel, our clients and business partners and the general public; and to pursue available remedies or limit damages.
If you would like to know more about our policies and practices regarding the sharing of personal data, please contact us using the information set forth in Section 9 below, entitled "CONTACT US".

7. YOUR RIGHTS

Under the GDPR and the relevant data protection laws in the UK, you have rights which you can exercise in relation to your personal data that we hold and process. These rights are set forth below.

  • Right to Access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, in the case of such processing, to access that personal data and certain information related to its processing, including the purpose(s) of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be disclosed; the retention period or criteria used to determine such period; etc.
  • Right to Rectification: You have the right to request, and to receive without undue delay, the rectification of inaccurate personal data concerning you; and, taking into account the purpose(s) of the processing, the right to have any incomplete personal data completed.
  • Right to Erasure: You have the right to request, and to receive without undue delay, the erasure (deletion) of your personal data in the following circumstances: the personal data is no longer necessary in relation to the purpose(s) for which it was collected or otherwise processed; you withdraw consent or exercise your right to object (see below) and there are no other legal or compelling legitimate grounds for processing; the personal data was unlawfully processed; or erasure is required to comply with a legal obligation applicable to S&K Brussels Consulting.
  • Right to Restriction of Processing: You have the right to have your personal data blocked from normal processing (restricted) where certain conditions apply.
  • Right to Object to Processing: You have the right to object to the processing of your personal data on grounds relating to your particular situation and where certain conditions apply, provided that there are no compelling legitimate grounds for the processing which would override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. For instance, if you would not like to receive any marketing communications from S&K Brussels Consulting, please contact us at: dpm@sandkbc.com.
  • Right to Data Portability: Where processing of your personal data is based on consent or on a contract, and is carried out by automated means, you have the right to obtain a copy of your personal data in a structured, commonly used and machine-readable format, and have the right to transmit that data to another controller without hindrance from us.
  • Right to Withdraw Consent: Where processing of your personal data is based on consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing prior to such withdrawal. To withdraw your consent, please contact us at dpm@sandkbc.com. Once we have received notification that you have withdrawn your consent, we will cease processing your personal data for the purpose(s) to which you originally consented, unless there is no other legal ground for further processing.

If you intend to exercise any of your rights described above, please contact us using the contact details provided under Section 9 below, entitled "CONTACT US". Please note that we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive.
If you are not satisfied with the way in which we have proceeded with your request to exercise your rights, or the way in which we collect or otherwise process your personal data, you may lodge a complaint with a Supervisory Authority in the EEA (and in particular, with the Supervisory Authority in the EEA member state of your habitual residence, place of work or place of an alleged GDPR infringement) and/or the UK Information Commissioner’s Office.

8. UPDATES TO PRIVACY POLICY

We may revise or update this EEA/UK Privacy Policy from time to time. Any changes to this EEA/UK Privacy Policy will become effective upon the posting of the revised EEA/UK Privacy Policy on our website.

9. CONTACT US

For any questions or requests relating to this EEA/UK Privacy Policy, please contact our Data Protection Manager Office at:

Data Protection Manager Office
S&K Brussels Consulting Co., Ltd.
ACN Omori-ekimae Building 6th floor
1-17-13 Omori-kita, Ota-City, 143-0016 Tokyo
JAPAN
E-mail: dpm@sandkbc.com

This EEA/UK Privacy Policy was last updated on November 1, 2023

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