Privacy Policy

The RSM Shiodome Partners Group (“we”, “us” or the "Group") recognizes the importance of protecting personal information. We comply with the Act on the Protection of Personal Information of Japan (“APPI”) and other applicable laws and regulations, and have established this Privacy Policy to ensure the appropriate handling and protection of personal information.

This Policy applies to all legal entities that comprise the Group. The Group’s legal entities are listed below, and each entity is referred to in this Policy as an "Entity".

• RSM Shiodome Partners Limited
• RSM Shiodome Partners Tax Co.
• RSM Shiodome Partners SR Co.
• RSM Shiodome Partners AS Co.
• RSM Shiodome Partners JS Co.
• Shiodome Business Solutions Limited
• Shiodome Cash Management Limited
• Shiodome Partners (Philippines) Inc.

1. Personal Information We Collect

In the course of providing our professional services, the Group may collect the following categories of personal information:

• Contact information, such as your name, address, telephone number and email address;
• Information relating to directors, officers and employees of our client;
• Information relating to service requests and enquiries;
• Information collected through your use of our website, including cookies, advertising identifiers and access logs;
• Information collected through individual identification codes (such as My Number and passport numbers); and
• Personal information collected in connection with social insurance, tax and residency status procedures.

We may collect personal information directly from individuals, from service providers or other third parties in connection with our services, and from publicly available sources, as permitted under applicable Japanese laws and regulations.

2. How We Use Personal Information

We use the personal information we collect for the following purposes:

• To provide our professional services and carry out our business operations;
• To respond to inquiries and requests for consultation;
• To perform our contractual obligations, including contract administration, billing, payment, and other related administrative procedures;
• To improve and enhance the quality of our services; and
• To comply with applicable laws and regulations.

3. Handling Related to Personal Information

The Group may collect information related to personal information, such as cookies and advertising identifiers. Where we obtain such information from a third party and use it as personal data, we will take appropriate measures in accordance with APPI and other applicable laws and regulations, including obtaining the individual's consent where required.

4. Disclosure to Third Parties

Except as required or permitted under applicable laws and regulations, the Group will not disclose personal information to any third party without the individual’s consent. The Group may share and jointly use personal information among its entities to the extent necessary for providing our services and conducting our business. The purposes of such joint use shall be limited to those set out in this Privacy Policy. The scope of such joint use shall be limited to all Entities comprising the Group. RSM Shiodome Partners Limited is responsible for the management of personal data subject to such joint use. The categories of personal data subject to joint use are those described in Section 1 of this Privacy Policy. We will prepare and retain records relating to disclosures to third parties as required under the APPI and other applicable laws and regulations.

Each entity acts as a business operator handling personal information under the APPI and is responsible for the handling of personal information in connection with its own business activities.

5. Cross-border Transfer of Personal Data

Where the Group transfers personal data to a third party located outside Japan, it will comply with the Act on the Protection of Personal Information of Japan ("APPI") and implement one of the following measures:

• Obtaining the individual’s consent;
• Transferring the personal data to a recipient that has established a system meeting the standards prescribed under Article 24 of APPI; or
• Transferring the personal data to a recipient located in a country or region designated by the Personal Information Protection Commission(“PPC”).

In addition, the Group may also transfer personal data to member firms of the RSM International network where necessary for the provision of our professional services.

Some cloud service providers used by the Group may store personal data on servers located outside Japan. In such cases, the Group will exercise appropriate supervision over its service providers. Information regarding the country or region in which recipients are located and the personal information protection measures adopted by such recipients is available upon request through the contact details below.

6. Outsourcing

The Group may entrust the handling of personal information to service providers to the extent necessary to achieve the purposes described in this Privacy Policy. In such cases, we will exercise appropriate supervision over such service providers.

7. Security Measures

The Group implements appropriate organizational, personnel, physical and technical security measures to prevent unauthorized access to, leakage, loss or damage of personal information. These measures include access controls, log management and employee training, and are reviewed on an ongoing basis.

8. Pseudonymized and Anonymized Personal Information

If the Group handles pseudonymized personal information or anonymized personal information under APPI and applicable laws and regulations, we will do so in accordance with the APPI and other applicable laws and regulations and will manage such information appropriately. At present, the Group does not intend to make ongoing use of such information.

9. Requests Regarding Retained Personal Data

Individuals may exercise the following rights in relation to their retained personal data held by the Group:

• Request notification of the purpose of use;
• Request access to retained data (which may be provided in writing or by electromagnetic means);
• Request correction, addition, or deletion of retained personal data;
• Request suspension of use or deletion, including where there is a risk of harm to the individual's rights or legitimate interests;
• Request suspension of disclosure to third parties; and
• Request disclosure of records relating to disclosures to third parties.

To exercise any of the above rights, please contact us using the inquiry desk provided below. We may request appropriate identification to verify your identity before responding to your request.

10. Recruitment

The following provisions apply specifically to personal information collected in connection with the Group's recruitment activities.

(1) Personal Information We Collect

In connection with our recruitment activities, the Group may collect the following categories of personal information:

• Contact information, such as your name, address, telephone number, and email address;
• Information relating to your educational background, employment history, qualifications, licenses and certifications contained in your résumé/CV, or other application documents;
• Information obtained through interviews, aptitude tests, and other recruitment assessments; and
• Other information voluntarily provided by applicants during the recruitment process.

(2) How We Use Recruitment Information

We use the personal information collected during the recruitment process for the following purposes:

• To assess applicants through document screening, interviews, and aptitude testing;
• To communicate recruitment decisions;
• To complete onboarding and other employment related procedures for successful applicants; and
• To communicate with applicants and provide information relating to recruitment activities.

(3) Retention and Disposal

The Group retains personal information collected during the recruitment process only for as long as necessary to achieve the purposes described above. Personal information relating to unsuccessful applicants may be retained for a reasonable period where necessary for recruitment administration, notifying applicants of future employment opportunities, or analysing and improving our recruitment activities. Once such information is no longer required for these purposes, it will be securely deleted or otherwise disposed of. If an applicant is employed by the Group, the relevant personal information will continue to be retained and managed as part of the individual's employee records in accordance with the Group's internal policies.

(4) Disclosure to Third Parties

Applicants' personal information will not be disclosed to third parties without the applicant’s consent, except where required or permitted under applicable laws and regulations. The Group may jointly use applicants' personal information among its Entities to the extent necessary for conducting recruitment activities, in accordance with this Privacy Policy.

(5) Requests Regarding Personal Information

Applicants may exercise the rights in Section 9 of this Privacy Policy in relation to their personal information. To submit a request, please contact us using the inquiry desk provided below.

11. Personal Information of Employees

The Group handles personal information relating to its employees (including officers, part-time employees, temporary employees and dispatched workers) appropriately in accordance with its internal policies and procedures. For further details, please contact the HR department of the relevant Group entity.

12. Contact Desk

We have established a centralized contact point for all Group entities to receive inquiries, comments, complaints, and requests regarding the handling of personal information, including requests for disclosure and other rights under applicable laws and regulations.

Please contact us using the contact details provided below.

* For the complaint handling contact of any certified personal information protection organization, please refer to the certified personal information protection organization to which the Group belongs.