プライバシーポリシー / Privacy Policy

Reference translation. The Japanese version prevails. Items marked OWNER_FILL or PROPOSED are not yet final.

Privacy Policy (reference translation)

MOKLAV GLOBAL GK ("we") handles personal information in compliance with the Act on the Protection of Personal Information (APPI) and the Telecommunications Business Act.

1. Business operator

• Name: MOKLAV GLOBAL GK
• Address: 〒373-0036 群馬県太田市由良町1671番地1 アレリエスC-202号 (Gunma, Japan)
• Representative: Representative Member RANA RAJAN

2. Information we collect

1. Account data: email address, name (optional), credentials (passwords stored hashed), 2FA settings.
2. Usage logs: login history (IP address, time, browser), activity logs, API usage.
3. User Data: DNS records, website files, email, databases and other data you store.
4. Requests and reports: inquiries, abuse reports, infringement claims and disclosure requests.
5. Payment data: [OWNER_FILL]. Optional sentence, use only if true: "Card numbers are held by our payment processor, not by us."

3. Purposes of use

1. Providing the service, identity verification and account management.
2. Billing (once billing starts).
3. Preventing fraud and attacks, and enforcing the AUP.
4. Handling faults, maintenance and quality improvement.
5. Responding to inquiries, claims and requests.
6. Important service notices. Marketing email is sent only with your consent.
7. Legal compliance.

4. Secrecy of communications

We protect the secrecy of communications (Telecommunications Business Act, Art.4). We do not use email contents or other communication data, except:

• with your consent;
• as required by law;
• in self-defence or emergency;
• to the extent needed to operate the service, maintain it, handle faults or respond to attacks.

5. Provision to third parties

We do not provide personal data to third parties without your consent, except:

1. As required by law. This includes court disclosure orders under the Information Distribution Platform Act.
2. To protect life, body or property when consent is hard to obtain.
3. For public health or children's welfare when consent is hard to obtain.
4. To cooperate with public authorities where asking for consent would impede their work.
5. When we outsource handling within the purposes of use, or in a business succession.

6. Outsourcing

We may outsource handling of personal data as needed for the purposes above. We select contractors appropriately and supervise them.

• Types of outsourced work: [OWNER_FILL]
• Contractor names, if disclosed: [OWNER_FILL]

7. Storage location and transfers abroad

[OWNER_FILL: choose A or B]

Variant A (Japan only)
Personal data is stored on servers in Japan and is not handled abroad.

Variant B (handling abroad)

• We may handle personal data in [OWNER_FILL: country, e.g. India], in the following way: [OWNER_FILL: e.g. remote maintenance access, or outsourcing to a local entity].
• We take safety measures informed by that country's data protection regime. For India, that is the Digital Personal Data Protection Act, 2023.
• When we provide personal data to a third party abroad, we follow APPI Art.28 in one of two ways:
• with your consent, after telling you the country, its regime and the recipient's measures; or
• only to a recipient that has an equivalent system in place, with information provided on request.

8. Cookies and external transmission

• We use only the cookies needed to keep you logged in and to remember your language and display settings. We use no advertising cookies.
• Disclosure under Telecommunications Business Act Art.27-12: our website and panel currently send no user information to third parties (no analytics or ad tags). If this changes, we will list the recipients, the data and the purposes here. [OWNER_FILL: confirm for the panel]

9. Security measures

• Policy: this policy is published.
• Organizational: the Representative Member is responsible for personal data handling.
• Personnel: confidentiality and proper handling by everyone who handles personal data.
• Physical: [OWNER_FILL]
• Technical: encryption in transit, access control, two-factor authentication and audit logs.
• External environment: see §7.

10. Retention

[OWNER_FILL: retention period for each category]
We delete data without delay once it is no longer needed, unless the law requires us to keep it.

11. Requests and complaints

1. You may request any of the following for personal data we hold:
• notice of the purposes of use;
• disclosure, including in electronic form;
• correction, addition or deletion;
• stopping use or erasure;
• stopping provision to third parties;
• disclosure of records of provision to third parties.
2. Contact: [OWNER_FILL; currently rana@moklav.co.jp]
3. We verify your identity (or your agent's) and respond without delay.
4. Fee: [OWNER_FILL]
5. Complaints are handled at the same contact.

12. Data breaches

We report breaches to the Personal Information Protection Commission and notify affected individuals as required by law.

13. Changes

We announce important changes on our website in advance.

• Enacted: [OWNER_FILL]
• Last revised: [OWNER_FILL]