Explanation of Recording and Provision of Work Data
This is a reference translation. The Japanese version prevails.
This document explains the provision of work data recorded with PAC Build by users of PAC Build ("Users") to PAC Inc. (the "Company"), the provision by the Company to third parties in Japan and abroad (including provision under Articles 27 and 28 of the Act on the Protection of Personal Information), and the joint use by the Company and Airion Inc., and is intended to obtain the consent of each Worker. The User shall present and explain this document to Workers and obtain each Worker's consent (including oral consent). The information on provision to third parties in foreign countries is provided pursuant to Article 28, Paragraph 2 of that Act and Article 17, Paragraph 2 of the Enforcement Rules of that Act.
1. Overview of Recording and Provision
The User records Workers' work with PAC Build for either or both of the following purposes.
Self-Use (for the automation or streamlining of the User's operations or other use of physical AI by the User itself)
Data Collection Use (for collecting data to be provided to businesses that develop physical AI)
The time periods and scope of recording shall be as explained in advance by the User to Workers.
| Item | Details |
|---|---|
| Data to be recorded | Physical data recorded with PAC Build, such as hand movements during work (coordinate data), video, audio, and force/tactile data obtained with glove-type devices and the like (including operation data and robot sensor data when a person remotely operates a robot to perform work). Masking of faces and other information that could identify the individual is carried out by the User (the Worker himself or herself, or the business to which the Worker belongs) at its own responsibility. |
| Flow of provision | The User provides the data to the Company, and the Company provides it to recipients. In addition, if the User enables the AI functions of PAC Build (automatic evaluation, assistants, etc.), the Company transmits images extracted from video and other data to providers of external AI services to the extent necessary for such functions (these functions are disabled by default). |
| Use by the Company | Training, development and improvement of AI models; improvement of the Company's services; joint use with Airion Inc. (the details of joint use are as set forth in the Company's privacy policy); and provision to recipients |
| Recipients | Businesses in Japan and abroad that develop AI models, etc. (including businesses that receive onward provision from recipients) and providers of external AI services used for the AI functions of PAC Build (currently expected to include Anthropic, PBC (United States), but not limited thereto) |
| Purposes of use by recipients | Training, development and improvement of AI models, and onward provision to other businesses where the Company has given prior written consent (for providers of external AI services, the provision of the AI functions of PAC Build) |
| Countries and regions of recipients | Japan, the United States, the United Kingdom, EU Member States (including Iceland, Liechtenstein and Norway) and China. These are those currently anticipated, and recipients are not necessarily limited to these countries. |
Since the recipient businesses (other than providers of external AI services) will be determined in the future as purchasers of the data, they cannot be identified at present. The countries and regions of recipients are those currently anticipated.
2. Personal Information Protection Systems of the Countries and Regions of Recipients in Foreign Countries
EU Member States (including Iceland, Liechtenstein and Norway) and the United Kingdom have been designated by the Personal Information Protection Commission as countries and regions having personal information protection systems at a level equivalent to that of Japan. The United States and China have not received this designation.
| Item | United States | China | EU Member States / United Kingdom |
|---|---|---|---|
| Comprehensive personal information protection law | None at the federal level. There are sector-specific laws (such as the Electronic Communications Privacy Act) and state laws (such as the California Consumer Privacy Act). | Exists (Personal Information Protection Law of the People's Republic of China, effective November 1, 2021). | Exists (EU General Data Protection Regulation (GDPR) and UK GDPR). |
| Indicators of the level of the system | Participates in the APEC Cross-Border Privacy Rules (CBPR) System. | Has not received an EU adequacy decision. | Designated as being at a level equivalent to that of Japan. |
| Systems that may materially affect the rights and interests of individuals | There are systems under which government agencies may require businesses to submit information for purposes of national security or criminal investigation. | There are systems requiring personal information to be stored domestically and restricting its transfer abroad. There are also systems under which state security agencies, public security agencies and others may require companies or individuals to provide information, including personal information, for broad purposes. | None in particular |
Details of each country's system are available on the Personal Information Protection Commission's website under "Survey on Personal Information Protection Systems in Foreign Countries."
3. Measures Taken by Recipients to Protect Personal Information
Since the recipient businesses (other than providers of external AI services) have not yet been determined, information on the measures taken by recipients cannot be provided. The Company shall impose the following obligations on recipients in its agreements with them:
- 1. not to use the data for any purpose other than that set forth in the agreement (training, development and improvement of AI models);
- 2. not to attempt to identify Workers from the data;
- 3. not to provide the data to any third party without the Company's prior written consent, and, when providing it to a third party with the Company's consent, to impose on such third party obligations equivalent to those in each item of this section;
- 4. to take security control measures to prevent leakage, etc. of the data; and
- 5. in the event of leakage, etc. of the data, to promptly notify the Company and take necessary measures.
After the recipient businesses have been determined, the Company shall, at the request of the individual, provide the names of the recipients' countries and information on the measures taken by the recipients.
4. Handling of Copyright
If copyright arises for a Worker in recorded video or other data, the Worker assigns such copyright (including the rights provided for in Articles 27 and 28 of the Copyright Act) to the User or licenses its use by the Company (including provision to recipients and masking and other processing). The Worker shall not exercise moral rights of authors against the Company, recipients or their successors.
5. Voluntary Nature of Consent and Withdrawal
A Worker may decline to consent to this document. A Worker shall not be subject to dismissal or other disadvantageous treatment by the User or the Company on the ground that the Worker has not consented to this document or has withdrawn consent.
A Worker may at any time withdraw consent given under this document or request suspension of use or erasure of data in accordance with law. Such a request will be notified to the Company through the User. A Worker may also make a request directly to the Company. The Company's inquiry desk is as set forth in the Company's privacy policy. However, suspension of use and erasure cannot be guaranteed for data already provided to recipients before the withdrawal or request, and AI models trained using it (except those that can reproduce or restore the data).