In addition to complying with the Act on the Protection of Personal Information (the “Personal Information Protection Act”) and all other laws and regulations regarding the handling of personal information, Mori Hamada & Matsumoto (partnership), Mori Hamada & Matsumoto LPC, MHM Tax Advisory Services, associated offices in Japan, and overseas bases of those entities (including the following: Beijing Office; Mori Hamada & Matsumoto Intellectual Property Co., Ltd., Shanghai Office; Mori Hamada & Matsumoto (Singapore) LLP; Chandler MHM Limited; Myanmar Legal MHM Limited; HCMC Office; Hanoi Office; ATD Law in association with Mori Hamada & Matsumoto; Tayag Ngochua & Chu, a member firm of Mori Hamada & Matsumoto, Mori Hamada & Matsumoto NY LLP (collectively or individually, the “MHM Group” or “we”) will comply with the following privacy policy:

1. Acquisition of Personal Information

We will only acquire personal information by legitimate means.

2. Purpose of Use of Personal Information

We will use the personal information we acquire for the following purposes. Except where permitted under the Personal Information Protection Act or any other relevant law or regulation, we will not use an individual’s personal information for any purpose outside of those listed below, without that individual’s prior consent.

• Conducting legal services;

• Notification of workshops, speeches, seminars and other events;

• Sending (by mail, fax, e-mail or other means) publications, articles, other legal information, and greeting cards, such as New Year’s cards;

• Responding to inquiries;

• Screening or contacting candidates for recruitment and personnel management after recruitment; or

• Any other purpose incidental to those listed above.

3. Provision of Personal Information to Third Parties

We will comply with the Personal Information Protection Act and all other relevant laws and regulations regarding the provision of personal information to third parties.

4.  Sharing of Personal Information

We may, in accordance with the policies listed below, share within the MHM Group personal information acquired by the MHM Group.

The categories of personal information that may be shared are as follows:

Contact information, such as names, addresses, phone numbers and email addresses, and all other categories of personal data that the MHM Group possesses.

The parties who may share personal information are as follows:
Entities within the MHM Group

The purposes of use of parties using personal information are as follows:

• Conducting legal services;

• Notification of workshops, speeches, seminars and other events;

• Sending (by mail, fax, e-mail or other means) publications, articles, other legal information, and greeting cards, such as New Year’s cards;

• Responding to inquiries;

• Screening or contacting candidates for recruitment and personnel management after recruitment; and

• Any other purpose incidental to those listed above.

The party who is responsible for management of personal information to be shared is as follows:
Mori Hamada & Matsumoto (partnership)

5. Security of Personal Information

We will handle all personal information in an appropriate manner and put in place proper measures to prevent the disclosure or loss of, tampering with, or damage to, any personal information in our custody, by implementing operational procedures and instructing our staff.

6. Requests Regarding Personal Information

If we receive from an individual whose personal information we hold a request to disclose that information, to amend, supplement or delete that information, to temporarily suspend or permanently cease the use of that information, to cease providing that information to a third party, or to inform that individual of the purpose of use of that information, then we will promptly respond to that request in good faith in accordance with the Personal Information Protection Act, after first confirming that the request is from the individual to whom the information relates.

Please note that we may not be able to respond to your request if it does not meet the requirements of the Personal Information Protection Act or if we are authorized by that law or other related legislations to refuse your request for disclosure or otherwise.

We also ask for your understanding if we charge a handling fee with respect to any request regarding the purpose of use of or disclosure of the personal information held by the MHM Group.

7. Contact for Inquiries

All requests, opinions, questions, complaints and other inquiries with respect to our handling of personal information should be made via our Contact Form.

8. Continuous Improvement

We continuously strive to improve our policies and procedures for the handling of personal information, and as a result this privacy policy may be amended, as required.

EEA Privacy Policy

This EEA Privacy Policy ("EEA Privacy Policy") applies to MHM Group’s processing of personal data in the context of MHM Group’s offering of goods and services to, or monitoring the behaviour of, individuals located in the European Economic Area ("EEA"). This EEA Privacy Policy sets out how MHM Group ("we", "us" and "our") will process as a data controller the personal data of our customers and business partners and their employees ("you" and "your") and the measures and processes we have put in place to ensure its adequate protection in accordance with the EU General Data Protection Regulation 2016/679 ("GDPR").

1. Lawful Processing

We will always process your personal data based on one of the legal basis provided for in GDPR (Articles 6 and 7). In addition, we will always process your sensitive personal data in accordance with the special rules provided for in GDPR (Articles 9 and 10). We will only process your personal data based on the following legal grounds:

(a)  to perform your instructions or contracts between you and us;
(b)  your consent given to us to process your personal data in such manner (you may withdraw your consent to this processing at any time; however, this will not affect the lawfulness of any processing carried out before such withdrawal of your consent);
(c)  to comply with our legal and regulatory obligations; and
(d)  where we have a legitimate interest to do so, balancing this interest against your interests and fundamental rights.

2. Personal Data We Process

We may process the following types of personal data about you: personal details (e.g., name, photograph); demographic information (e.g., gender, age, nationality); identifier information (e.g., passport, driver’s license, national identity number); contact details (e.g., address, telephone number, email address); matter details (e.g., your instructions to us);  payment details; information about your use of our websites; information about your interactions with our services, promotions or advertising; and any views or opinions you provide to us.

3. How We Use Your Personal Data

We will process your personal data for the following purposes:

(a)  Provision of legal services;
(b)  Communications and marketing: notification of workshops, speeches, seminars and other events; sending publications, articles, other legal information, and greeting cards;
(c)  Responding to inquiries;
(d)  Recruitment, job applications and personnel management: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; acceptance details; and personnel management after recruitment;
(e)  Compliance with legal and regulatory obligations to which we are subject;
(f)  Other legitimate interests, including analyzing use of our website or services, tailoring website and news content, setting preferences in our website or electronic mailings, improving our websites, offering and managing programs and events, fulfilling our obligations to our clients and others, and managing our client and vendor relationships; or
(g)  Any other purpose incidental to those listed above.

4. When We May Disclose Your Personal Data

We do not and will not sell, rent out or trade your personal data. We will only disclose your personal data to the following recipients:

(a)  to MHM Group entities;
(b)  to third parties approved or designated by you;
(c)  to third parties who process your personal data on our behalf; and
(d)  to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.

5. International Transfers of Personal Data

Your personal data may be transferred to (including accessed in or stored in) a country or territory outside the EEA, including to countries whose laws may not offer the same level of protection of personal data as are enjoyed within the EEA. In particular, we may share your personal data with MHM Group entities outside of the EEA including Japan. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by GDPR. If you would like to know more about such details, you can contact us using the information in the section "Contact Us" in this EEA Privacy Policy.

6. Security

We are committed to safeguarding and protecting your personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect your personal data from accidental or unauthorised destruction, loss, alteration, disclosure or access.

7. Your Rights in Relation to The Personal Data We Collect

7.1 If you wish to:

(a)  update, modify, or delete your personal data, or obtain a copy of your personal data that we hold; or
(b)  restrict or stop us from using any of your personal data which we hold,

you can request this by contacting us using the contact details set out below, subject to exceptions allowed by law.  

7.2 In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.

8. Retention of  Personal Data

We will only retain your personal data as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

9. Direct Marketing

If you tell us that you do not wish any of our group companies to provide you with information about our products and services and other marketing materials, we will not contact you further for the purpose of direct marketing. You can contact us using the contact details set out below.

10. How We Update or Change This Policy

We may change or update this EEA Privacy Policy in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. If we materially change the way we collect, use or disclose your personal data we will notify you in advance by email and/or by placing a prominent notice on this website.

11. Contact Us

If you have any queries about the contents of this EEA Privacy Policy or your personal data, or wish to make a request in relation to your personal data, please contact us via our Contact Form.

12. How to Lodge a Complaint to The Regulator

You are entitled to lodge a complaint with a competent data protection regulator if you consider that we have breached your data protection rights.