California Consumer Privacy Policy Addendum

EFFECTIVE DATE: 6, August, 2020
LAST REVIEWED/UPDATED on: 6, August, 2020

Space Design, Inc. provides serviced apartments, serviced offices, hotels, hostels and other accommodation services to employees of companies and other organizations as well as individual persons who require temporary and long-term accommodation and/or office space.

At Space Design, Inc. (“we,” “us,” “our”), we take the privacy rights of California consumers under the California Consumer Privacy Act (“CCPA”) seriously. If you are a California resident, the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA (“California Personal Information”). For such residents, the provisions of this California Consumer Privacy Policy Addendum (“California Addendum”) supplement our Privacy Policy https://www.space-d.co.jp/co/ja/company/privacypolicy/ and prevail over any conflicting provisions therein.

Ⅰ. California Personal Information

  1. Categories of California Personal Information
    We collect, and in the past 12 months, we have collected, the following categories of California Personal Information:
  • Customer Identifiers: Identifiers such as first and last name, postal address (temporary and/or permanent), place of residence, date of birth, online identifier, email address, passport number, copies of government ID’s including driver’s licenses and driver’s license numbers.
  • Customer Record Information: Personal information described in Section 1798.80(e) of the California Civil Code such as physical characteristics or description, telephone number, passport number, copies of government ID’s including driver’s licenses and driver’s license numbers, employment. Bank account number if necessary for refunding.
  • Protected Information: Protected classifications under California or federal law such as age, nationality, citizenship, marital status. Medical condition, physical or mental disability, gender, pregnancy or childbirth and related medical conditions may be obtained voluntarily from your side such as yourself, your employers, your or your employers’ agents if necessary for service requirements or considerations.
  • Commercial Information: Commercial or transactions information such as records of services purchased, obtained or considered, transaction history, dates of arrival and departure, family members and their information (if accompanied), and other information necessary to provide the services, including accommodation requirements and emergency contact information.
  • Internet Information: Internet or other electronic network activity information such as browsing history
  • Sensory Information: Sensory information such as audio, electronic, visual, or similar information, including call recordings from customer service interactions.
  • Professional Information: Professional or employment-related information such as employer, job title, income, length of employment, and other statements will be obtained from employers, if necessary for credit check for apartment or serviced office leasing contracts.

California Personal Information does not include publicly available information from government records, deidentified or aggregate consumer information, and other personal information excluded from the CCPA’s scope such as personal information covered under the Fair Credit Reporting Act (FCRA).

  1. Categories of Sources of California Personal Information
    We may obtain, and within the past 12 months, we have obtained, California Personal Information from the following sources:
  • Directly from California residents like yourself.
  • From California resident’s employer or our partner relocation/rental-housing company or agent including the suppliers of the accommodation services engaged by California resident’s employers.
  • Indirectly from such as observations on California resident’s interaction with our website using cookies).
  1. Our Use of California Personal Information.
    We use the California Personal Information we collect for the business purposes as defined in the CCPA. For example, we may use California Personal Information for the purposes below:
  • Perform our services and fulfill or meet the reason you provided the information to us. For example, we may use your California Personal Information to provide our services, respond to your inquiries, make proposals, arrange necessary accommodations, and enter into lease agreements or accommodation service agreements.
  • Process your requests, purchases, transactions, and payments and prevent transactional fraud. For example, we may use your California Personal Information to verify your identity and perform credit check, payment processing, and deposit refund.
  • Support checking-in, moving-in, checking-out, and damage recovery processes.
  • Arrange services and facilities such as cleaning services, and concierge and hotline or emergency assistance.
  • Provide optional services available at serviced offices such as meeting room arrangements, mailing, and rental equipment services.
  • Provide service updates and other service-related information.
  • Manage renewal, amendments, or termination of contracts.
  • Support the handling of feedback, complaints and disputes.
  • Detect or prevent security incidents or other illegal activity and prosecuting the responsible parties.
  • Maintain the safety, security, and integrity of our services, website and other technology assets, and business.
  • For legal compliance and to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • Analyze and monitor our website use, personalize your experience with us, and improve our website and services.
  • Other purposes described to you when collecting your California Personal Information or as otherwise described in the CCPA.
  1. Disclosure of California Personal Information

We may disclose, and within the last 12 months, we have disclosed, the following categories of California Personal Information to the following categories of third parties for business purposes. When we disclose California Personal Information for business purposes, we enter a contract that describes the purpose and requires the recipient to both keep that California Personal Information confidential and not use it for any purpose except performing the contract.

  • Customer Identifiers:
    • Operational service providers such as security companies, hotline service companies, room management and accommodation service companies for our operating properties, only first name and last name will be disclosed.
    • Relocation and rental-housing partners.
    • Your employers to the extent necessary. For example, we share your emergency contact information with your employer lessee.
    • IT system maintenance providers.
    • Government entities to meet our legal obligations.
    • Other legal professional service providers such as lawyers to the extent necessary to meet our legal obligations or respond to court order.
  • Customer Record Information:
    • Operational service providers such as security companies, hotline service companies, room management and accommodation service companies for our operating properties, telephone number will be disclosed in case you contact them and require call-back to you.
    • Relocation and rental-housing partners.
    • Your employers to the extent necessary. For example, we share your arrival and departure schedules and emergency contact information with your employer lessee.
    • IT system maintenance providers.
    • Government entities to meet our legal obligations.
    • Other legal professional service providers such as lawyers to the extent necessary to meet our legal obligations or respond to court order.
  • Protected Information:
    • Your employers to the extent necessary to arrange, bind, or settle payments of apartment leasing contracts with us for you, with certain extra charge for personal service requirements, if necessary.
    • Relocation and rental-housing partners to the extent necessary to arrange, bind, or settle payments of apartment leasing contracts with us for you, with certain extra charge for personal service requirements, if necessary.
    • IT system maintenance providers.
    • Government entities to meet our legal obligations.
  • Commercial Information:
    • Operational service providers such as security companies, hotline service companies, room management and accommodation service companies for our operating properties, only date of arrival and departure family member and their information if accompanied will be disclosed.
    • Relocation and rental-housing partners.
    • IT system maintenance providers.
    • Government entities to meet our legal obligations
    • Other legal professional service providers such as lawyers to the extent necessary to meet our legal obligations or respond to court order.
  • Internet Information:
    • Service providers such as IT system maintenance providers, data analytics providers, and marketing and subscription management vendors.
    • Government entities to meet our legal obligations.
  • Sensory Information: Sensory information such as audio, electronic, visual, or similar information, including call recordings and customer service interactions.
    • Operational service providers such as security companies, hotline service companies.
    • IT system maintenance providers.
    • Government entities to meet our legal obligations.
  • Professional Information: Professional or employment-related information such as employer, job title, income, length of employment, and statements from employers.
    • Bind apartment leasing contracts with us for you.
    • IT system maintenance providers.
    • Government entities to meet our legal obligations.
  1. Sale of California Personal Information
    We do not sell California Personal Information. Within the last 12 months, we have not sold California Personal Information, including California Personal Information of individuals we know to be under the age of 16, for monetary or other valuable consideration as a “sale” under California law.

 

Ⅱ. Cookies & Analytics

  1. Cookies

Our website uses cookies for essential functionality and site analytics purposes. Cookies are files sent by web servers to web browsers and stored by web browsers. The information is then sent back to the server each time the browser requests a page from the server. This enables a web server to identify and track web browsers. On our website, we track general visitors’ information, including the IP-address of your access device and other browser information. These details are used to provide essential functionality of our website, personalize your experience, and for site analysis, including analysis of visitation and clicking behavior on our website. This helps us improve our website usability. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all available features.

  1. Google Analytics

To assess the web traffic to our website and how effectively our online campaigns are, we use Google Analytics. We restrict Google’s use of our information.

For more information regarding how Google collects and uses your information, please visit: https://policies.google.com/technologies/partner-sites. Google also provides you choices on how your information is collected by Google Analytics by offering you an opt-out browser add-on which can be located at: https://tools.google.com/dlpage/gaoptout?hl=en.

  1. HubSpot

We use HubSpot to analyse who are visiting our website. HubSpot is a tool that helps provide our marketing and sales team with lead generation. They deliver reports on the information such as IP addresses related to the individuals visited our website, for how long and how many visits.

HubSpot also allows us to collect information from you when you subscribe to our online mailing list form. We use HubSpot as a mailing list tool, so that we can store your name, email address, company and phone number. Subscribers can opt- out and unsubscribe any time.

We use HubSpot to chat to visitors directly via our website. This tool helps us answer any questions from prospective customers and to help existing customers with any queries or requests. When one of our advisors is not online, it will display a form instead.

For more information regarding how Hubspot collects and uses your information, please visit
https://legal.hubspot.com/product-privacy-policy

 

III. Your Rights Regarding California Personal Information.

California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your California Personal Information, subject to certain exceptions and limitations:

  • The right to know the categories of California Personal Information we collect, use, disclose, and sell about you, the categories of sources from which we collected your California Personal Information, our purposes for collecting or selling your California Personal Information, the categories of your California Personal Information that we have disclosed for a business purpose, and the categories of third parties with which we have shared personal information. You also have the right to request a copy of specific pieces of your California Personal Information.
  • The right to request that we delete the California Personal Information we have collected from you or maintain about you.
  • The right to opt out of a sale of your California Personal Information. Please note that we do not sell your California Personal Information, and therefore, we do not offer support for opt-out of a sale.
  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights. Please note that we do not prepare certain financial incentive program for your prior opt-in consent.
  • Other California Privacy Rights. Under California’s “Shine the Light” law (Civil Code Section § 1798.83), you, as a California resident, may ask us to provide a list of what personal information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Please note that we do not disclose your personal information to third parties for their direct marketing purposes.

To exercise any of the above rights, please contact us using the following information:
E-mail: p-policy_sd@space-d.co.jp

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request. Although you will not be required to create an account with us to submit a request or have it fulfilled, we may ask you to provide certain California Personal Information as part of our verification process, including name and email address, which we already maintain.

Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by submitting the written power of attorney or by providing the agent with written permission to act on your behalf. As permitted by law, we may require verification of the agent’s authorization or require you to verify your own identity in response to a request even if you choose to use an agent.

Please note that we may not be able to respond to your request or provide you with your California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.

 

Ⅳ. California Do Not Track Disclosure.

As of the Effective Date listed below, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of personally identifiable information regarding your online activities over time and across third-party web sites or online services.


Ⅴ. Contact for More Information.

For questions or concerns about our Privacy Policy, this California Addendum or our data practices, please contact us by using the information below.

  • E-mail: p-policy_sd@space-d.co.jp
  • Tel: +813-3502-7000
    Available from 10:00 am to 5:00 pm (Japan standard time)
    (except Saturdays, Sundays, local national holidays, and the year-end and New Year holidays)
  • Physical address: 4th Floor, KDX Shinbashi Building, 2-2-9 Shinbashi, Minato-ku, Tokyo, 105-0004, JAPAN

 

Ⅵ. Updates to This California Addendum.

We reserve the right to update this California Addendum from time to time at our discretion. When we make changes to this California Addendum, we will post the updated notice on our website and update the effective date of the changes to this California Addendum. It is your responsibility to regularly review the applicable conditions.