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Privacy Notice

BrainFirm Co., Ltd.

Effective as of August 16, 2022


BrainFirm is committed to protecting the privacy of personal data and maintaining the principles of integrity and trust in the course of BrainFirm's business.

This privacy notice aims to give you information on how BrainFirm collects and processes your personal data through your use of this website, and through interactions with its clients, suppliers, and other third parties.

The data we may collect about you

"Personal data" means any information about a person that can be used to identify that person. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:


  • Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender, job title and employer; photograph / identity documents (where necessary for identification when attending BrainFirm functions).

  • Contact Data includes postal address, email address and telephone numbers and corporate contact details (including business "direct dial" or office address).

  • Public Data includes information we collect when providing our services to our clients, which may include data that is public or is contained on public data sites (such as LinkedIn, company registrar websites and our clients' own websites), including information about whether you may be or be connected with a person listed on government sanctions lists.

  • Service Data includes information we collect when providing our services to our clients, which includes personal data collected as part of surveys carried out by BrainFirm in the course of performing its services (including Identity Data, Contact Data, Public Data and information such as occupation and income).

  • Correspondence Data includes personal data we obtain as a result of our correspondence, including personal data contained in feedback and complaints, the progress of complaint resolution, and the outcome of complaints.

  • Financial Data includes bank account and payment card details (where necessary to conclude or perform service contracts with you).

  • Marketing and Communications Data includes your preferences in receiving marketing materials from us and our third parties and your communication preferences.

  • Technical Data includes internet protocol (IP) address, your login data for our websites and other online services, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and information about how you use our website.


How is your personal data collected?

We use different methods to collect personal data from and about you. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. We may also receive personal data about you from various third parties (such as our clients and suppliers, particularly if they are your employer) and public sources, such as identity and contact data from publicly availably sources (see "Public Data" above) and reports from external professionals.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we have / will enter into with you.

  • Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override our legitimate interests.

  • Where we need to comply with a legal or regulatory obligation.


Purposes for which we will process your personal data

The table below sets out the purposes for which BrainFirm may process your personal data, and the lawful grounds for that processing. Depending on the purpose/s for which we are processing your data, we may do so under more than one lawful grounds.

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Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out.



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Disclosures of your personal data

We may need to share your personal information within BrainFirm in order to provide you with our services or manage our business.

We may also employ the services of third party service providers who provide services to us. These service providers have agreed to confidentiality restrictions and will use any personal information we share with them (or which they collect on our behalf) solely for the purpose of providing those services. We take appropriate steps to ensure that such third parties treat your Personal Information with the same care that we do. Where third party service providers receive your information we remain responsible for the use of your personal data.

We may be required to disclose your personal data to law enforcement bodies, regulators, agencies or other third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.


Direct Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you have given us your consent to send you marketing material by email or post, you have the right to opt out of receiving that material. We will also get your express opt-in consent before we share your personal data with any company outside BrainFirm for marketing purposes. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or you can contact us at any time.


International transfers

BrainFirm is performing internationally, with businesses inside and outside Japan. Third party service providers who handle data on our behalf may be based in locations around the world. For these reasons, your personal data may be transferred to other countries outside of Japan. Whenever we transfer your personal data out of Japan, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and/ or

  • Where we use third party providers based in the US, we may transfer data to them if they have adequate measure in place, which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Japan.


Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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Although you are encouraged to contact us if you would like to exercise your rights, some of these rights are only available in certain circumstances and so we may not be required to comply with every request.


Contact us

The primary point of contact for all issues arising from this privacy policy is the BrainFirm Data Protection Team. If you have any complaints or queries relating to the processing of your personal data by any member of BrainFirm, or to exercise any rights in respect of your personal data, you should contact us.

We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honor your wish to exercise your rights.


To contact your data protection supervisory authority

You have a right to lodge a complaint with your local data protection supervisory authority at any time. In Japan, this is the Personal Information Protection Commissioner (

Should you have a complaint, we hope that you can approach us first so that we can try to resolve your concern.


Changes to this privacy policy and informing us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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