1. Data Controller
The data controller who is responsible for the processing of personal data is Space Design, Inc., 4th Floor, KDX Shinbashi Building, 2-2-9 Shinbashi,Minato-ku, Tokyo, Japan.
If you are employees of our corporate clients, your employers or the suppliers of the accommodation services engaged by your employers will be the data controllers, and we act only as the processer, receiving data from them.
2. What personal data & source
Space Design, Inc. processes the following personal data:
- Name, (temporary and/or permanent) address and place of residence, e-mail, telephone;
- Gender, nationality, marital status, family members and their personal information;
- Date of birth, employer, job title, income, length of service;
- Online identifier
We generally obtain your personal data directly from you or via your employer or our partner relocation/rental-housing company or agent including the suppliers of the accommodation services engaged by your employers. In some instances, Space Design, Inc. will collect and aggregate data using cookies. For further details please see point 4.
We do not collect or process Special Categories of Personal Data stated in the Article 9 of GDPR (General Data Protection Regulation).
Personal information of the children under 16 years will be collected via their parents or with their consent.
3. The purpose and legal basis of the data processing
Space Design, Inc. processes personal data for the following purposes:
- Responding to inquiries, providing our service information, making proposals/arranging conditions, credit check and entering into lease agreements or accommodation service agreements;
- Support with checking or moving in;
- Arranging services and facilities such as cleaning services, and concierge and hotline/emergency assistance;
- Providing option services for Serviced Office such as meeting rooms, post receptions and deliveries, and rental equipment services;
- Providing service updates and information;
- Renewal or change of contracts:
- Termination, check-out/damage recovery and deposit refunding;
- The handling of complaints and disputes;
- Obtaining feedback about our services;
- Analyzing and monitoring website use;
- Archiving purposes;
Compliance with legal obligations.
The legal basis for the processing is that the processing is necessary for the performance or the entering into of a contract between us and you, for the compliance with legal obligations and for the representation of legitimate interests of Space Design, Inc. and the users of our services. These legitimate interests include the ability for us to offer our services and the ability for expats and their employers to use them.
5. Google Analytics
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.
7. Recipients of personal data
We only share your personal data with third parties to the extent if it is necessary for the performance of our services. In that context, for example, data can be shared with:
- Cleaning companies, security companies, and hotline service companies
- Subcontractor who provides serviced apartment room management systems as well as the operation of the accommodation services under the local Private Lodging Law (“Minpaku”) for our operating properties
- Partner relocation/rental-housing companies or agents
- Relevant government agencies, when legally obliged;
- Your employers, if necessary;
8. Retention of personal data
We do not store your data for longer than necessary for the purposes mentioned under 3. In consideration of the applicable local laws and business practice, any data related to our tenants and guests will be deleted no later than 10 years after the end of our assignment for the leasing agreements and 5 years after the end of our assignment for the accommodation agreements, unless the data must be retained for a longer period in connection with a legal obligation. Personal data belonging to other individuals such as website visitors or simple inquiry senders shall not be stored any longer than strictly necessary for the purpose for which we collect the personal data.
9. Security Measures
Space Design, Inc. is acting in compliance to GDPR and will take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that is administrated by us. Our security measures are, pursuant to technological progress, constantly being reviewed and improved.
10. Your rights
You have the right to request Space Design, Inc. to access your personal data. If the information is incorrect, incomplete or irrelevant, you have the right to request rectification. You also have the right to object to the processing and to request Space Design, Inc. to delete the data.
Insofar as the processing is based on your consent, you have the right to withdraw the permission at any time. Withdrawal does not affect the lawfulness of the processing on the basis of the consent before it is withdrawn.
If you wish to make use of your aforementioned rights, please contact Space Design, Inc. by letter or e-mail using the contact details provided below. Space Design, Inc. will make a decision on your request within four weeks.
You also have the right to lodge a complaint with the supervisory authority, in particular in the EU Member State of your habitual residence, place of work or of an alleged infringement of the GDPR at all times. However, we would appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us beforehand.
For questions or comments about the processing of your personal data, and to exercise your above-mentioned rights, please contact Space Design, Inc. via: firstname.lastname@example.org
Inquiry Tel: +813-3502-7000／E-mail: email@example.com
4th Floor, KDX Shinbashi Building, 2-2-9 Shinbashi,
Minato-ku, Tokyo, 105-0004
Available from 10:00 am to 5:00 pm
(except Saturdays, Sundays, local national holidays, and the year-end and New Year holidays)
12. Revision of Policy