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Data Processing Agreement (DPA)

The primary language version is legally binding. See データ処理合意書.

Updated: 15 October 2026

This Data Processing Agreement (hereinafter "the Agreement") establishes the terms under which Timolabaadvisory 合同会社 (hereinafter "the Processor") processes personal data entrusted by B2B clients (hereinafter "the Controller") in accordance with the Act on the Protection of Personal Information (APPI) and related Japanese legislation.

Summary:

  • The Processor handles only recording materials and client contact details based on the Controller's instructions.
  • Data is generally retained for 12 months following the completion of a session.
  • XSERVER Inc. and FormSubmit are utilized as sub-processors.
  • Data subject rights are managed according to the Privacy Policy.

1. Definitions and Purpose

The purpose of this Agreement is to define the responsibilities regarding the handling of personal data provided by the Controller to the Processor. This Agreement functions as an integral part of the Terms and Conditions and strictly prohibits the Processor from handling data for any purpose other than those explicitly instructed by the Controller.

2. Scope and Categories of Processing

The categories of data processed are as follows:

  • Data Subjects: Employees of the Controller, recording artists, voice-over talents, and podcast guests.
  • Data Items: Full names, email addresses, telephone numbers, and recorded audio data (which may include biometric characteristics).
  • Purpose: Completion of vocal recording, instrument recording, mixing, mastering, and podcast production services.

3. Processor Obligations and Security

The Processor implements appropriate safety management measures in accordance with the APPI. This includes restricting access permissions, strict password management, and physical access control to the studio located at Kita 3-jo 12-4, Chuo-ku, Sapporo. The Processor shall not disclose data to third parties without the prior written instruction of the Controller.

4. Sub-processors

The Processor utilizes the following sub-processors to the extent necessary for service delivery:

  • XSERVER Inc. (Address: Grand Front Osaka Tower A 32F, 4-20 Ofuka-cho, Kita-ku, Osaka 530-0011): Provision of website hosting and data storage.
  • FormSubmit (USA based): Transfer of data via inquiry forms. Data transfers to the USA are handled according to the provisions in the Privacy Policy.

5. Data Retention and Erasure

The Processor retains recording sessions and associated files as an archive for a maximum of 12 months after project completion. Data exceeding this period, or data for which a deletion request has been received from the Controller, will be erased using non-recoverable methods. Detailed procedures for data return and deletion are governed by the Terms and Conditions.

6. Incident Reporting and Audits

In the event of a suspected data breach or loss, the Processor shall notify the Controller within 24 hours of discovery. The Controller reserves the right to conduct audits, upon reasonable notice, to verify the Processor's compliance with this Agreement.

7. Legal Compliance and Jurisdiction

This Agreement is governed by and construed in accordance with the laws of Japan. Any disputes arising from this Agreement shall be subject to the exclusive jurisdiction of the Sapporo District Court in the first instance.

Complaints or inquiries from data subjects may be submitted to the following supervisory authority:

Personal Information Protection Commission (PPC)
Address: 3-3-1 Kasumigaseki, Chiyoda-ku, Tokyo 100-0013
URL: https://www.ppc.go.jp

Contact Information:

Timolabaadvisory 合同会社 (Capital: ¥1,000,000 / Director: Mei Abe)
Address: Kita 3-jo 12-4, Chuo-ku, Sapporo (060-0003)
Phone: 011-850-6845
E-mail: [email protected]