Privacy Policy
Information Security Policy
At Visual Bank Inc. and its group subsidiaries, amana images Inc., and THE PEN inc. (collectively as “Visual Bank Group,” “we,” “our,” or “us”), we recognize that in today’s digital society the proper management of information assets is a critical responsibility. We are committed to protecting such assets against threats including leakage, destruction, and unauthorized alteration. To that end, we have established this Information Security Policy and ensure that all officers and staff members; including employees, contractors, part-time staff, and on-site vendors understand and follow.
Information Security Objectives
We are committed to implementing appropriate information security management, preventing information security incidents, and thereby earning the trust of all stakeholders. Should an incident occur, we will act promptly to minimize its impact, restore operations quickly, and take measures to prevent recurrence.
Scope
This policy applies to all officers, staff members, and the critical information assets managed by Visual Bank Group.
Visual Bank Group’s Initiatives
1. Protection of Information Assets
We will implement necessary measures to maintain the confidentiality, integrity, and availability of all information assets, including personal and sensitive data.
2. Compliance with Laws and Regulations
We will comply with all applicable laws, regulations, internal rules, and contractual obligations related to information security.
3. Promotion of Security Management
We will establish and maintain an Information Security Management System (ISMS), appoint a Chief Information Security Officer, and operate a company-wide Information Security Committee. The Committee and Committee Members in each department, will drive security activities, conduct regular reviews, and ensure continuous improvement.
4. Education and Training
We will provide ongoing education and training to all officers and staff to raise awareness and strengthen secure practices.
5. Incident Response
We acknowledge that information security incidents may occur and prioritize prevention. If such incidents arise, we will respond promptly, take corrective measures, and implement appropriate safeguards.
*An “information security incident” refers to any event that disrupts or could disrupt secure business operations.
Personal Information Protection Policy
We handle the personal information of our customers, business partners, and other related parties in the course of our business activities. We comply with all applicable laws and regulations governing the protection of personal information, while also taking into account relevant international standards and best practices. We have established internal rules and governance frameworks, and we hereby adopt this Personal Information Protection Policy, affirming our commitment to its implementation and ongoing maintenance.
To implement this Policy, we have established internal Personal Information Management Regulations and ensure that all officers, employees, and related parties are properly informed of and strictly comply with them.
To prevent the loss, destruction, falsification, or unauthorized disclosure of personal information, we maintain an information security management system and implement appropriate safeguards, including measures against unauthorized access and computer viruses.
To ensure proper management of personal information, we conduct periodic and ad hoc reviews. If deficiencies are identified, we promptly take corrective action and strive for continuous improvement.
We acquire personal information only through lawful and fair means. We either obtain the consent of the individual with respect to the intended purposes of use or provide such purposes on our official website.
When acquiring personal information from third parties, we handle such information appropriately in accordance with applicable data protection laws.
We recognize that individuals (data subjects) have the right to request disclosure, correction, suspension of use, or deletion of their personal information. We respond to such requests promptly and in good faith, and we have established a dedicated contact point for personal information inquiries.
When outsourcing the handling of personal information or engaging in joint use within the scope of the stated purposes, we conduct due diligence on the recipient and implement necessary measures, including the execution of appropriate contracts.
Personal information will be used only within the scope necessary for the execution of business operations and only by authorized personnel. It will not be used in any manner that may encourage or give rise to unlawful or improper conduct.
As a general rule, we prohibit the disclosure or provision of personal information to third parties and will not use such information for unlawful or illegitimate purposes.
To prevent unfair discrimination, prejudice, or disadvantage, we will not collect, use, or disclose personal information relating to:
(1) Ideology, beliefs, or religion
(2) Race, ethnicity, lineage, domicile of origin (excluding prefecture-level information), criminal record, or other matters that may cause social discrimination
(3) Workers’ rights to organize, collective bargaining, or other collective activities
(4) Participation in demonstrations, exercise of the right to petition, or other political rights
(5) Sexual orientations
Personal information handling business operator:
Visual Bank Inc.
6F, C-Cube Minami-Aoyama Building,
7-1-7 Minami-Aoyama, Minato-ku, Tokyo
Representative Director: Saneyuki Nagai
amana Images Inc.
6F, C-Cube Minami-Aoyama Building,
7-1-7 Minami-Aoyama, Minato-ku, Tokyo
Representative Director: Ippei Mochizuki
THE PEN Inc.
6F, C-Cube Minami-Aoyama Building,
7-1-7 Minami-Aoyama, Minato-ku, Tokyo
Representative Director: Saneyuki Nagai
Purpose of Use of Personal Information
We will use the personal information entrusted to us in the course of our business activities only to the extent necessary to achieve the following purposes:
1. Purposes of Use
(1) Customer Information
We collect the following categories of customer personal information:
Membership information registered by customers (e.g., name, contact details, email address, membership ID)
Payment information registered by customers (e.g., cardholder name, card number, expiration date, issuing bank, and bank account details)
Content of customer inquiries (including recordings or video records, if applicable)
Service usage history and transaction history with Visual Bank Group
Information provided by third parties
Website visit history (e.g., IP address, device, cookies, advertising click history)
Responses to surveys and questionnaires
Customer personal information will be used for the following purposes:
To process applications, provide services, and respond to inquiries regarding Visual Bank Group’s services
To make proposals or provide information on our services, and for billing purposes
To improve existing services and develop new services
To distribute advertisements, promotional information, newsletters, or similar communications regarding our products, services, and campaigns (only where permitted by law and with prior consent where required)
To provide information about exhibitions, seminars, and other events
To request participation in surveys and to publish aggregated survey results
To conduct marketing research and demand analysis necessary for research and development
To monitor services and implement risk management measures
To detect and prevent fraudulent use
To conduct management analysis of our business operations
To carry out other business operations deemed necessary to appropriately and smoothly fulfill transactions with customers
To provide personal information to third parties within the scope necessary to achieve the above purposes
(2) Business Partner Information
Business partner personal information will be used for the following purposes:
To communicate regarding commissioned work and business negotiations
To make proposals or provide information on our services
To make payments related to commissioned work, using contact details and bank account information
(3) Shareholder Information
Shareholder personal information will be used for the following purposes:
To communicate with shareholders, provide information, pay dividends, deliver shareholder benefits, and manage shareholder records in accordance with the Companies Act and other applicable laws, using contact details and bank account information
(4) Visitor Information
Personal information of visitors to Visual Bank Group’ will be used for the following purposes:
To facilitate contact with relevant staff and to manage entry and exit from our facilities, including the use of images from security cameras
(5) Recruitment Candidate Information
Personal information of individuals applying to join Visual Bank Group will be used for the following purposes:
To communicate regarding recruitment, selection, and employment decisions, and to carry out administrative procedures necessary for onboarding, using contact details, employment history, qualifications, date of birth, and family information
To improve future recruitment activities, using survey responses and related information
2. Joint Use of Personal Information
We may share personal information with affiliated companies in the following manner:
(1) Items of personal information jointly used and purposes of use:
The purposes of use shall fall within the scope described in Section 1, “Purposes of Use”, specifically; (1) Customer Information; (2) Business Partner Information; and (5) Recruitment Candidate Information with any subsidiaries of Visual Bank Group.
(2) Scope of parties jointly using information:
Joint use of (1) Customer Information and (2) Business Partner Information:
Visual Bank Group companies that jointly provide services;
Credit card issuers and payment processing companies used by customers, for the purposes of fraud detection and prevention
Joint use of (5) Recruitment Candidate Information:
Visual Bank Group subsidiaries
(3) Name, address, and representative of the entity responsible for management of personal information:
Visual Bank Inc.
6F, C-Cube Minami-Aoyama Building,
7-1-7 Minami-Aoyama, Minato-ku, Tokyo
Representative Director: Saneyuki Nagai
3. Inquiries Regarding Personal Information
For questions, consultations, disclosure requests, or complaints concerning personal information, please contact:
Personal Information Inquiry Desk (for all subsidiaries):
Information Security Committee, Visual Bank Inc.
Contact Form
A prescribed fee may be charged for disclosure requests.
4. Provision to Overseas Third Parties
We may entrust the processing or storage of personal information to service providers located outside Japan. Where such transfers occur, we assess the personal data protection regime of the relevant country and implement necessary safeguards.
Entity Authorized to Act Under the Visual Bank Group Name: amana images Inc.
Service: HubSpot (HubSpot, Inc.)
Purpose: Customer CMS services
Country: United States
Established on June 26, 2025
Revised as of November, 20, 2025
[Contact Form]
https://visual-bank.co.jp/en/contact
Established as of June 26, 2025