Privacy Policy

1. Introduction

Netsmart Cloud ("we", "our", "us") operates the website at netsmartcloud.digital and related educational services for product teams. We respect your privacy and are committed to handling personal information responsibly and transparently. This Privacy Policy explains how we collect, use, store, and share information about individuals who interact with our website and services.

By using our website or submitting information through any form on this site, you acknowledge that you have read and understood this policy. This policy applies to all visitors, regardless of location, though we give particular attention to our obligations under Japanese law.

2. Applicable Law

Our primary legal framework for personal data handling is the Act on the Protection of Personal Information (個人情報の保護に関する法律, "APPI") of Japan, as amended and enforced by the Personal Information Protection Commission (PPC). Where individuals from the European Economic Area interact with our services, we also observe the applicable requirements under the General Data Protection Regulation (GDPR) as relevant.

Under the APPI, we are considered a "Business Operator Handling Personal Information" (個人情報取扱事業者). We fulfill the obligations placed on such operators, including specifying the purpose of use, notifying individuals of that purpose, and managing personal data with appropriate security measures.

3. Information We Collect

We collect the following categories of personal information:

Contact and inquiry data: When you submit a contact form or audit request form, we collect your name, email address, telephone number, and the content of your message or inquiry. Where you indicate your professional role, we collect that as well.

Technical and usage data: Our web server and analytics tools may collect information about your browser type, device, IP address, pages visited, time spent on the site, and referring URL. This information is used in aggregated or anonymized form to understand how the site is used and to improve it.

Cookie data: We use cookies and similar tracking technologies. Please refer to our Cookie Policy for full details.

We do not collect sensitive personal information as defined under the APPI (such as medical, financial, or racial/ethnic origin data) and we do not request or store payment card information.

4. Purpose of Collection

We use the personal information we collect for the following purposes, each of which we specify in accordance with Article 17 of the APPI:

Responding to inquiries: To review your message or audit request and to contact you by email or telephone to discuss your inquiry.

Providing educational services: To communicate information about our API design education curriculum, audit services, and related materials relevant to your expressed interest.

Website improvement: To analyze how visitors interact with the site and to improve its content, structure, and usability. This analysis relies primarily on aggregated data.

Legal compliance: To fulfill our obligations under applicable Japanese law and to respond to lawful requests from public authorities where required.

We will not use your personal information for any purpose materially different from those listed above without notifying you and, where required, obtaining your consent.

5. Legal Basis for Processing

Under the APPI, we process personal information on the basis of the lawful purposes specified at the time of collection. For individuals in the EEA, our legal bases include: your consent (for cookie-based analytics), the performance of a pre-contractual or contractual relationship (for responding to audit requests), and our legitimate interests (for improving our services), provided those interests do not override your fundamental rights.

Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal.

6. Data Sharing and Disclosure

We do not sell, rent, or trade personal information to third parties. We may share your information in the following limited circumstances:

Service providers: We use third-party services to operate our website infrastructure, email delivery, and analytics. These providers access personal data only to perform services on our behalf and are required to protect it appropriately. They may not use it for their own independent purposes.

Legal requirements: We may disclose personal information if required to do so by law, court order, or the request of a government authority with jurisdiction over us, including the Personal Information Protection Commission of Japan.

Business transfers: In the unlikely event of a merger, acquisition, or transfer of our business assets, personal data may be transferred as part of that transaction. We would notify affected individuals prior to any such transfer.

7. International Data Transfers

Our primary operations are based in Japan. Where personal data is processed or stored using cloud infrastructure or third-party services located outside Japan, we take steps to ensure that appropriate protections are in place. For transfers outside Japan, we apply the requirements of the APPI regarding third-party provision to foreign entities (Article 24), including confirming that the recipient country provides a comparable level of protection or obtaining your consent where required.

8. Data Retention

We retain personal information for as long as is necessary to fulfill the purpose for which it was collected. Inquiry data is generally retained for up to two years after the inquiry is resolved, unless a longer retention period is required by law. Technical and usage data is retained in aggregated form and is not linked to identifiable individuals after thirty days from collection.

When personal information is no longer needed, we delete or anonymize it using appropriate methods that prevent reconstruction of the original data.

9. Your Rights

Under the APPI, you have the right to request disclosure of personal information we hold about you, to request correction of inaccurate information, and to request cessation of use or deletion of your personal information where applicable legal grounds exist. To exercise any of these rights, please contact us using the information in Section 14.

We will respond to verified requests within the timeframe required by applicable law. We may need to verify your identity before processing a request. There is no charge for submitting a request, though we reserve the right to charge a reasonable fee for requests that are manifestly unfounded or excessive.

If you are in the EEA, you also have the right to lodge a complaint with your local supervisory authority. If you are in Japan and believe we have not handled your data in compliance with the APPI, you may contact the Personal Information Protection Commission.

10. Security Measures

We implement technical and organizational measures to protect personal information against unauthorized access, loss, alteration, or disclosure. These include encrypted transmission (HTTPS), access controls limiting who within our organization can access personal data, and regular review of our security practices. No system is completely secure, and we cannot guarantee absolute security, but we take our obligations to protect your data seriously and act promptly if a breach is discovered.

11. Cookies and Tracking

We use cookies to operate the website and to analyze usage patterns. You can manage your cookie preferences through the cookie consent tool on this website. For full details about the types of cookies we use and how to control them, please read our Cookie Policy.

12. Children's Privacy

Our website and services are intended for professionals and are not directed at individuals under the age of 16. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without appropriate parental consent, we will take steps to delete that information promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. When we make material changes, we will update the "Last Updated" date at the top of this document. We encourage you to review this policy periodically. Continued use of the website after a change is posted constitutes your acknowledgment of the updated policy.

14. Contact Us

For questions, requests, or concerns regarding this Privacy Policy or our personal data practices, please contact us: