S&K Brussels

Privacy Policy

In addition to complying with the Act on the Protection of Personal Information (Act No. 57 of 2003) (the "Personal Information Protection Act") and all other applicable laws and regulations regarding the handling of personal information, S&K Brussels LPC, S&K Brussels BV and Sugimoto & Kawashima PLLC (collectively, "S&K Brussels"), together with S&K Brussels Consulting Co., Ltd, S&K Brussels Consulting USA Corporation, and S&K Brussels Consulting Europe Limited (collectively, "S&K Brussels Consulting"), S&K Brussels GRPP Co., Ltd.( "S&K Brussels GRPP"), and S&K Brussels Group Co., Ltd. ("S&K Brussels Group") (each of the aforementioned parties, collectively or individually, the "Group," "we" or "our") endeavor to protect personal information in accordance with this privacy policy (the "Privacy Policy").

  • Acquisition of Personal Information
    We will only acquire personal information by legitimate and fair means.
  • Purposes of Use of Personal Information
    Except where permitted under the Personal Information Protection Act or any other relevant laws and regulations, we shall not use an individual's personal information for any purpose other than those listed below, without first obtaining that individual's consent:
    • Performance of legal and consulting services provided by S&K Brussels; performance of consulting services provided by S&K Brussels Consulting, S&K Brussels GRPP, and S&K Brussels Group (such services, collectively, the "Group Services");
    • Provision of information concerning the Group Services;
    • Notifications of, and invitations to, workshops, speeches, seminars and other similar events;
    • Provision of publications (including newspaper and journal articles, research publications, opinion pieces, etc.), courtesy announcements, newsletters and greeting cards;
    • Responses to inquiries;
    • Recruitment-related communications, including selection, screening and responses to employment-related applications, and personnel management after recruitment;
    • Any other purpose incidental to those listed above; and
    • Any other purpose necessary for the smooth and effective performance of the Group Services.
  • Provision of Personal Information to Third Parties
    We shall comply with the Personal Information Protection Act and all other relevant laws and regulations regarding the provision of personal information to third parties, including, where necessary, obtaining the consent of the relevant individual.
  • Shared Use of Personal Information
    We may share personal information acquired by the Group in accordance with the policies listed below.
    a) a) Categories and Items of Personal Information Subject to Shared Use
    The categories of personal information that may be shared are as follows:
    • Contact information (including name, address, phone number, fax number, email address, etc.);
    • Employment and recruitment-related information (including name of company or organization, position, qualifications, educational information, etc.);
    • Other categories of personal information possessed by the Group in accordance with this Privacy Policy.
    b) Parties Involved in Shared Use
    The parties which may share the personal information, and to which the personal information may be shared, are: S&K Brussels LPC, S&K Brussels BV, Sugimoto & Kawashima PLLC, S&K Brussels Consulting Co., Ltd, S&K Brussels Consulting USA Corporation, S&K Brussels Consulting Europe Limited, S&K Brussels GRPP Co., Ltd., and S&K Brussels Group Co., Ltd.
    c) Purposes of Shared Use
    The purposes of shared use for the above-mentioned parties are those listed under Section 2 above, entitled "Purposes of Use of Personal Information".
    d) Responsible Party
    The party responsible for the management of personal information subject to shared use is S&K Brussels LPC.
  • Security of Personal Information
    We have established appropriate physical, electronic and procedural safeguards to protect the personal information from unauthorized access and disclosure, and from unintentional loss, destruction and alteration. In addition to technical safeguards, we instruct and train our management and personnel regarding the legal requirements and internal policies pertaining to data security, and exercise necessary and appropriate supervision in the case of outsourced processing activities.
  • Requests Regarding Personal Information
    Upon receiving a request to disclose the personal information or its purpose(s) of use; to amend, supplement or delete the personal information; to temporarily suspend or permanently cease the use of the personal information; to cease providing the personal information to a third party; etc., we shall promptly respond to that request in good faith and in accordance with the Personal Information Protection Act, after first confirming that the request was made by the individual to whom the personal information relates.
    Please note that we may not be able to respond to a request if it does not satisfy the requirements prescribed by the Personal Information Protection Act, or if there is cause to decline the request in accordance with applicable laws and regulations.
  • Contact for Inquiries
    All requests, opinions, questions, complaints and other inquiries with respect to our handling of personal information should be referred to our Data Protection Manager Office using the contact details below:
    Data Protection Manager Office
    S&K Brussels LPC
    Sanno Bridge B1F
    2-5-6 Sanno
    Ota-City, Tokyo 143-0023
    JAPAN
    E-mail: dpm@sandkbrussels.com
  • Continuous Improvement and Changes to the Privacy Policy
    In an effort to improve our policies and procedures for the handling of personal information, we will periodically review and amend this Privacy Policy.

Last updated on January 15, 2021.

European Economic Area Privacy Policy

  • OUR EEA PRIVACY STATEMENT
    This European Economic Area Privacy Policy ("EEA Privacy Policy") is provided on behalf of S&K Brussels LPC, S&K Brussels BV, Sugimoto & Kawashima PLLC, S&K Brussels Consulting Co., Ltd., S&K Brussels Consulting USA Corporation, S&K Brussels Consulting Europe Limited, S&K Brussels GRPP Co., Ltd., and S&K Brussels Group Co., Ltd. (collectively, "S&K Brussels," "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. The purpose of this EEA 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 European Union, EEA and the United Kingdom.
    If you have any queries relating to this EEA Privacy Policy, please contact our Data Protection Manager Office at dpm@sandkbrussels.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 legal and 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, credit and debit card numbers 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, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership and health data, which may be relevant to our provision of legal 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.
  • 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 legal and 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 legal and 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.
  • 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 legal and consulting services to our clients, however we also process personal data to fulfill contractual and other legal obligations, and to establish, exercise or defend the legal claims of our clients.
    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 Privacy Policy in accordance with Section 8 below, entitled "UPDATES TO PRIVACY POLICY".
    Specific Purpose Categories of Personal Data Legal Basis
    To provide legal and consulting services to our clients, including in the context of a dispute, compliance matter, investigation, litigation, settlement or other legal matter; to establish, exercise or defend the legal claims of our clients.
    • Identity and contact details
    • Client information
    • Business and professional information
    • Sensitive data
    • Legitimate interest: communicating with the relevant parties and providing legal and consulting services
    • Performance of contract
    • Establishment, exercise or defense of legal claims: for processing sensitive personal data
    • Consent
    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 legal and consulting fees
    • Performance of contract
    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
    • Consent
    • Performance of contract
    To manage marketing and public relations activities, including organizing or advertising business seminars, conferences, webinars and workshops; to respond to or organize media requests; to manage subscription preferences and send marketing communications and questionnaires.
    • Identity and contact details
    • Business and professional information
    • Legitimate interest: communicating with the relevant parties and managing business and marketing activities
    • Performance of contract
    • 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
    • Performance of contract
    • Legal obligation
    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
    • Legal obligation
    • Precontractual measures
    *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; the processing is in connection with the establishment, exercise or defense of our or our client's legal claims; or the processing is otherwise expressly permitted under the GDPR or other relevant laws or regulations.
  • 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, Belgian, and Irish 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.
  • 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 United Kingdom, including to countries whose laws may not offer the same level of protection of personal data as the EEA. In particular, we may share your personal data with S&K Brussels entities outside of the EEA, including in Japan. We are committed to complying with European data protection laws regarding the transfer of personal data from the EEA and United Kingdom, 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.
    We may also share your personal data with public institutions and companies outside of S&K Brussels, including our business partners and clients, provided and to the extent that such sharing is necessary for the provision of our legal services, 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, 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".
  • YOUR RIGHTS
    Under the GDPR, 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 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.
    • 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, please contact us at: dpm@sandkbrussels.com.
    • Right to Data Portability: Where processing of your personal data is based on consent or on a contract or 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@sandkbrussels.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 are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
    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 (and in particular, with the Supervisory Authority in the EU member state of your habitual residence, place of work or place of an alleged GDPR infringement).
  • UPDATES TO PRIVACY POLICY
    We may revise or update this EEA Privacy Policy from time to time. Any changes to this EEA Privacy Policy will become effective upon the posting of the revised EEA Privacy Policy on our website.
  • CONTACT US
    For any questions or requests relating to this EEA Privacy Policy, please contact our Data Protection Manager Office at::
    Data Protection Manager Office
    S&K Brussels LPC
    Sanno Bridge B1F
    2-5-6 Sanno
    Ota-City, Tokyo 143-0023
    JAPAN
    E-mail: dpm@sandkbrussels.com

    This EEA Privacy Policy was last updated on January 15, 2021
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