Privacy Policy

Acquisition, Use, and Provision of Personal Information

By submitting your details through our website’s Contact Page or using any service that we may provide, you are agreeing to this policy and must read it in its entirety. You also consent to the practices described in this policy, and must not submit your details or use our services unless you accept the policy terms.

Personal information we collect

“Personal Information” includes any data related to an identified or identifiable person. We obtain personal information from various sources including enquiries submitted through the online form on our Contact Us page, or by communicating with us though phone, post, email, social media, or other means. Personal information is also automatically collected each time you visit the website, as cookies are used by Google Analytics to gather technical and usage data during your visit.

Information we may collect include the following:

• Identity data: may include your first and last name
• Contact data: may include your email address and telephone number
• Technical data: may include your internet protocol (IP) address, location, web browser used, operating system, and other technical details
• Usage data: may include how often you use our website, how long you visit our website, the flow of web pages visited, and other usage details
• Special categories of personal data: may include data related to gender, ethnicity, age, or other personal information in the case of any cover letters and curriculum vitae (CVs) submitted for the purposes of employment
• Other data: we may also collect your contact details when you provide them in the context of becoming a customer, vendor, or partner

How we may use personal information

We regard the protection of personal information to be a vital part of our business, as it is essential for the successful delivery of services to customers, vendors, and partners.

When handling personal information, we will only use the data for purposes that are within the scope of helping our company successfully deliver our services to customers, vendors, and partners. We will only use personal information obtained by other methods only within the scope of their intended purposes, such as using cover letters and CVs submitted for strictly hiring purposes. However, this rule does not apply in instances related to the following situations:

• Situations where we have received the explicit consent of the person in question.
• Situations where we are required to disclose the personal information by law, ordinance, etc.
• Situations where we must disclose personal information to protect the lives, physical well-being, or property of the person in question or the general public.
• Situations where we are required to cooperate with an institution of the central government, a local authority, or a party acting under the charge of an institution of the central government or local authority to carry out an activity provided by law.

How we may share your personal information

From time to time we may entrust the processing of personal information to a third party in order to improve the efficiency of providing our services to customers, vendors, and partners. In such instances, we will require the third party to control the personal information based on a written agreement or other documentation that’s identical to the guidelines in this Privacy Policy.

Entrusted Personal Information

From time to time, we may be entrusted with personal information for business purposes. When performing activities to administer personal information, we will prescribe the work contents based on an agreement or other documentation, and use the personal information according to the guidelines within such documentation.

Proper Control and Safe Retention of Personal Information

We will retain strict control of personal information and keep such details accurate, up- to-date, and within the scope necessary to fulfil its purposes. We will implement appropriate data security measures and corrective actions to prevent unlawful access to, loss, destruction, and falsification of personal information. We will also conduct timely audits to evaluate the effectiveness of our data security measures.

Data Controller

In respect to the personal data of our website users, customers, vendors, and partners, the Data Controller is Cleary and Co. We will continuously strive to prepare and update rules, policies, and other guidelines to protect personal information.

Complaints, Consultations, and Subject Access Requests (SARs)

If we receive a complaint or a request for a consultation regarding personal information in our possession from and individual or their representative, we will respond after confirming the identity of the person in question.

Administration of Personal Information

Purposes of Use

The Company retains personal information to conduct the following business operations:

• Strategy development
• Improvement of interactive strategies, best practices case studies, user analyses, performance evaluations, and customer loyalty studies
• Implementation and operation services
• Report to, conduct business discussions with, conduct meetings with, and enact agreements with its customers
• Respond to inquiries from customers, vendors, and partners
• Select and hire employees, manage job applicants, and report to employees
• Manage employees

Discretionary Provision of Personal Information

When we ask someone to provide personal information, the provision of that information is wholly voluntary. However, when such personal information is not received, it may be impossible in some cases for our company to render service. In addition, the inability to provide such information may also interfere with administrative activities related to employment with our company.

Cookie Policy

Our websites uses cookies for some purposes. “Cookies” are information our web server sends to a visitor’s browser. The term refers to the technology that’s used to send and store small amounts of information on a visitor’s computer when someone accesses a company’s website. The information stored in the cookie is restricted to information that does not identify the individual, such as the session ID. If you do not wish to accept the cookie, you can change the settings on your browser. In some cases, however, this may prevent you from receiving certain services.

We currently use, or may use the following types of cookies:

• Strictly necessary cookies: These cookies are required for our website to operate, and include cookies that enable you to visit certain areas of our website.
• Analytical/performance cookies: These cookies enable us to recognise and count how many people visit our website, and what pages they view during their visits. They help us improve how our website functions and provides information to visitors.
• Functionality cookies: These are cookies that recognise when you return to our website. They enable us to personalise our content and set preferences such as your choice of language or region.
• Targeting cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We use this information to ensure advertising displayed on our website is more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

If you do not wish to have cookies placed on your computer you should set your browsers to refuse cookies before using our website. However, the drawback is that certain features of our website may not function properly without the aid of cookies.

Access Log to This Website

The IP address used when an individual connects to the Internet is recorded when they visit our website. We may use this information to prevent unlawful computer access, respond when such access is detected, and identify and solve the cause of problems that occur with the server. We only use this information to manage and operate our website safely and appropriately, and will not use information related to IP addresses to obtain visitors’ personal information.

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Administration of Personal Information for Employment Selection

We will maintain and protect personal information received from job applicants for employment, and request that applicants read and understand the following policies before submitting their cover letters and CVs:

Purposes of Use

• We use personal information such as name, sex, and date of birth to identify applicants for employment
• We use contact information such as telephone number, email address, and mailing address to respond to employment enquiries and inform applicants of interview dates and other relevant matters.
• We use names and other identification information such as employment history and qualifications for personnel and human resources management purposes once an individual has been hired.

Provision of Personal Information

We do not disclose, provide, or entrust third parties with the personal information of job applicants unless we have obtained their consent, except in the situations described above or when required by law. From time to time, we may disclose such information without applicants’ consent, when requested by a government agency to disclose personal information based on lawful procedures.

Discretionary Provision of Personal Information

Providing us with your personal information is completely voluntary. However, when such information is not provided, it may interfere with administrative activities related to employment.

Notification of the Purpose of Use for Personal Information

You have the right to request how your personal information is being used. If you require this information, please send your enquiry to: [email protected].

Disclosure, Correction, Addition, and Deletion of Personal Information

Applicants for employment have the right to request the disclosure of their own personal information, and the right to demand corrections to, or deletions of their personal information. If you require this information, please send your enquiry to: [email protected].

Right to Delete or Stop the Use and Sharing of Personal Information

You have the right to request that the use of your personal information be stopped, that your information be deleted, or that it not be shared with third parties. If these actions are required, please send your enquiry to [email protected].

Enquiries Concerning Personal Information and SAR Submission

For all enquiries concerning your personal information or to submit a SAR request to get a copy of your personal data, please send your enquiry to [email protected].

Enquiries Concerning the Disclosure, Correction, Addition, and Deletion of Personal Information

Who Can Submit Requests

• The person in question
• A representative who has been entrusted by the person in question
• Lawful representatives of minors and adult guardians

Format for Requests

All requests must be submitted in writing. Please submit the required documents by email to [email protected].

Required documents

• Reason for Request.
• Copy of an identification card issued by a public institution.
  Note: When the document contains information on registered domicile, please black out such information

When a request will be made by a representative, the following documents are required in addition to the above:

• Power of attorney: The format is discretionary. However, this document must include a valid address and signature or seal from the person in question, as well as the representative’s name and address.
• Copy of the representative’s identification card issued by a public institution: One copy of a driver’s license, passport, pension book, health insurance card, alien registration, or similar identification document should be submitted.

Note: When the identification document contains information a registered address, please black out such information.

We may contact individuals by telephone or other means to verify personal identity.

Replies to Requests

We will reply in writing concerning the personal information within 30 days after verifying personal identities. To prevent the leak or loss of personal information during mailing, we will use “Restricted Delivery Mail Service.” Depending on the details of the request, there may be occasions when we may be unable to respond within the time limit indicated above.

When We Cannot Accept a Request

Unfortunately, we cannot accept requests in the following cases:

• When we cannot verify the identity of the person in question or the representative.
• When documents are incomplete.
• When there is a potential for endangering the life, physical well-being, property, or other rights and interests of the person in question or a third party.
• When doing so would create a significant obstacle to our company’s operations and activities.
• When responding would violate a law.

Administration of Personal Information obtained concerning a request

We do not use personal information obtained from enquiries for purposes other than the disclosure, deletion, and correction of information in our possession. We will retain such Personal Information request for three years after responding to the request. We will dispose of all documents used for personal identification at the point in which we have fulfilled such requests.

Enquiries Concerning Personal Information and SAR Submission

For all enquiries concerning your personal information or to submit a SAR request to get a copy of your personal data, please send your enquiry to [email protected].

• We are the sole owners of the information collected on this site.
• We only have access to/collect information that you voluntarily give us via email or other direct contact from you.
• We will not sell or rent this information to anyone.
• We will use your information to respond to you, regarding the reason you contacted us.
• We will not share your information with any third party outside of our organization, other than as necessary to fulfil your request.