The Company provides three types of "ANONIMA" service (hereinafter, the "Service"): (1) Blow Whistle, (2) Be Heard, and (3) Take Survey. Users* can use the Service anonymously to send and receive information, such as writing and receiving messages and responding to questionnaires. The Service does not collect or possess any information that personally identifies you, such as your name or email address. This is our definition of "zero data." The Service does acquire a user's personal information if the content of the messages posted by the user includes information that identifies the user. Even in such cases, the Service stores messages in the database in an encrypted form, and has no information that identifies the individual who wrote the message, making it impossible to identify the individual who wrote the message. However, the administrator* who receives your messages may be able to identify you from the content of your messages. For that reason, we recommend that users do not include any personally identifiable information in the messages they write. The Company's stance in providing the Service is that it is important for users to feel safe and secure in using the Service anonymously, without providing any personally identifiable information. In the course of providing the Service, the Company collects and stores information that identifies the recipients/administrators* mentioned above. See our Privacy Policy for details on how this information is handled. *Terminology Users "User" refers to an individual who a company that has entered into an agreement with us (hereinafter, the "Customer") has permitted to use the ANONIMA service (hereinafter, the "Service") and who has registered for this Service according to the procedure specified by the Company. Users can use the Service to blow the whistle, send messages, and respond to surveys. Recipients of messages written by users are administrators designated by their company and identified by the individual. When posting messages, users will recognize individual recipients in advance. Recipients/Administrators These terms refer to the Company Admin, Whistle-blowing Admin, and Be Heard Admin, which are specified by the Company. Recipients/administrators can manage company accounts, receive messages posted by users, and reply to them. The Company asks recipients/administrators to provide their names and email addresses in order to identify individuals.
Tesserae Japan Inc., a company incorporated under the laws of Japan, with its registered office at 2-6-10 Kanda-Sarugakucho Chiyoda-ku Tokyo 101-0064 Japan, and registered under the number 2010001208119 (hereafter “Tesserae”), acts as a data controller when it processes personal data of Anonima users and Corporate users of the Customer who use its services (“data subjects” or “you”), for those cases where the EU General Data Protection Regulation n° 2016/679 (hereafter “GDPR”) applies. Tesserae provides a platform for unidentified exchanges between an organisation (our Customer) and the person the Customer identifies as its employees (the users of the Anonima platform). Limited personal data will be processed, as described in this privacy policy. Categories of personal data. Tesserae processes the following categories of personal data of the following data subjects: - Anonima users: personal identification data (hashed phone number), electronic identification data (cookies, connection times), professional information (i.e. your affiliation to the organisation, which is Tesserae’s Customer); - Corporate users: personal identification data (name, surname, email address), electronic identification data (cookies, connection times). Purpose. Tesserae will process these personal data for the purpose of user administration. The legal basis for these processing operations is the legitimate interests of both Tesserae and the Customer in performing the contract between Tesserae and the Customer. The data subjects’ data will be stored for the duration of the contract between Tesserae and the Customer. Recipients. The personal data may be transferred to processors (such as IT service providers). Data transfers. Tesserae may process personal data in the following regions: Japan, USA and EU. Data subjects’ rights. As a data subject, you may request access to your personal data, rectification or erasure of your personal data, restriction of processing, portability of your data and you may object to the processing of your personal data on grounds relating to your particular situation. Tesserae will try its best to meet your request at the soonest, while also respecting confidential information. You can exercise your rights by sending an e-mail to info@anonima.net, providing proof of your identity. As a data subject, you are entitled to lodge a complaint with a supervisory authority. Should you have any question regarding the protection of your personal data by Tesserae, do not hesitate to send us an email to info@anonima.net. Tesserae regularly reviews its processing of personal data of data subjects and strives to continuously improve its privacy policy. It may therefore amend or update its privacy policy from time to time as necessary. The revised privacy policy will take effect as soon as it is posted on Tesserae’s website.
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