Legal
Last updated: April 24, 2026
Fujinova operates a compliance management platform for Japan's Specified Skilled Worker (SSW) program. We connect employers, Registered Support Organisations (RSOs), immigration attorneys, placement agencies, and foreign workers in a single system designed to keep every party audit-ready and compliant with Japanese immigration law.
This Privacy Policy explains what personal data we collect, why we collect it, how it is stored and shared, and what rights you have over your data. It applies to everyone who creates an account on the Fujinova platform — regardless of role.
We are subject to Japan's Act on the Protection of Personal Information (APPI), the Philippines Data Privacy Act of 2012 (RA 10173), and, where applicable, the General Data Protection Regulation (GDPR).
How Fujinova Complies with the APPI
| APPI Requirement | What the APPI Requires | How Fujinova Complies |
|---|---|---|
| Purpose specification (Art. 17–18) | Specify the purpose of data collection and not use data beyond that scope without fresh consent | Purposes are disclosed at the point of collection and listed in Section 4; no re-use beyond stated purposes without notice and, where required, new consent |
| Sensitive personal information / 要配慮個人情報 (Art. 2(3), Art. 20) | Prior explicit consent before collecting data such as health records or nationality-adjacent data | Consent obligations and the categories we collect are set out in Section 3 |
| Third-party provision (Art. 27) | Prior consent before providing personal data to third parties, with limited exceptions | We do not sell data; third-party processors (Clerk, Convex, Vercel) act under data processing agreements — see Section 6 |
| Cross-border transfers (Art. 28) | Consent or equivalent safeguards for transfers to countries without a PPC adequacy decision | Transfers to US-based processors are disclosed and consent-based, with contractual safeguards — see Section 7 |
| Right to disclosure (Art. 33) | Disclose held personal data to the data subject without delay upon request | Access requests honored within 30 days — see Section 9 |
| Right to correction and deletion (Art. 34–35) | Correct, delete, or cease using data that is inaccurate or unlawfully handled | Correction and deletion rights are set out in Section 9 |
| Security safeguards (Art. 23) | Take necessary and appropriate measures to protect personal data | TLS encryption, role-based access control, and audit logs — see Section 10 |
| Breach reporting (Art. 26) | Report breaches to the PPC and notify affected individuals | We will report qualifying breaches to the PPC and notify affected users — see Section 10 |
| Supervisory authority | Individuals may complain to the Personal Information Protection Commission (PPC) | PPC contact details are provided in Section 9 |
Account data (all roles)
Name, email address, and role (employer, RSO, worker, attorney, or agency) are collected at sign-up via Clerk, our authentication provider.
Worker profile data
For workers on the platform — typically added by an employer or placement agency — we store: full name, nationality, age, educational background, years of experience, industry and field, JLPT language level, current visa status (pending, active, expired, or departed), visa expiry date, compliance score, and current SSW stage.
Compliance and activity records
Every action logged on the platform is timestamped and attributed to the user who performed it. This includes intake steps (COE application status, employment contract, pre-departure orientation), arrival and settlement activities (housing confirmation, city hall registration, airport pickup), ongoing RSO support logs (language coaching sessions, workplace check-ins, complaint records), and renewal tracking data.
Documents
Workers and their managing parties may upload supporting documents including passport copies, JLPT certificates, health check records, police clearance, employment contracts, and photos. Documents are stored securely and associated with the worker's compliance profile.
Usage and cookies data
We collect standard web usage data: IP address, browser type, device type, pages visited, and session duration. We use session cookies necessary to keep you logged in and to maintain platform security. We do not use tracking cookies, advertising cookies, or third-party analytics cookies. This data is used solely to maintain platform performance and security — not for advertising or profiling.
Under Japan's Act on the Protection of Personal Information (APPI), certain categories of data are classified as specially-designated sensitive personal information (要配慮個人情報) and require explicit consent before collection.
Fujinova collects the following data that falls within or adjacent to this category:
- **Nationality** — required to verify SSW visa eligibility and manage immigration compliance - **Health check records** — uploaded as part of the visa application process (pre-employment medical examination results) - **Visa status** — directly linked to immigration standing and legal right to work in Japan
By creating an account and entering or uploading this data onto the platform, the party responsible for that worker's profile (employer, RSO, or placement agency) confirms that they have obtained the worker's informed consent to collect, store, and process this information for the purpose of SSW compliance management.
Workers who access the platform directly confirm their own consent at the point of account creation.
If you have questions about consent records for a specific worker, contact dennisclemente@gmail.com.
The purpose for which we collect and use each category of personal data is disclosed at the point of collection, consistent with APPI Article 18. The primary purposes are:
- To create and manage your account and verify your role - To build and maintain compliance profiles for each worker - To deliver deadline alerts (visa renewals at 90-, 60-, and 30-day intervals) - To generate audit-ready compliance reports for employers and RSOs - To attribute and timestamp every logged support activity - To calculate employer transparency scores and worker compliance scores - To provide multilingual support and communicate platform updates - To comply with Japanese immigration law and Philippine DMW reporting requirements
We will not use your data for any purpose materially different from those listed above without notifying you and, where required by law, obtaining fresh consent.
We do not use your data for advertising. We do not sell your data to any third party.
Access to data on Fujinova is strictly role-based:
**Employers** can view and manage their assigned workers' Stage 1 (intake) and Stage 4 (renewal) data. They have read-only access to Stages 2–3, which are owned by the RSO.
**RSOs** can view and manage Stages 2 (arrival/settlement) and 3 (ongoing support) for workers assigned to them. They have read-only access to Stage 1 and Stage 4 employer data.
**Workers** can view their own compliance status, document vault, support activity log, and the transparency score of their assigned employer.
**Immigration attorneys** have access only to workers explicitly assigned to them by an employer — consistent with Japan's Personal Information Protection Act requirements.
**Placement agencies** have read-only access to the RSO activity log and pre-departure checklist for workers they placed.
No role can access data outside its permitted scope. Fujinova staff access data only when required to provide technical support, and only with logged justification.
Fujinova uses the following third-party services to operate the platform:
**Clerk** — handles account creation, authentication, and session management. Clerk stores your email address and authentication credentials. See Clerk's Privacy Policy at clerk.com/privacy.
**Convex** — provides our backend database infrastructure. All worker profiles, compliance records, and documents are stored on Convex servers. See Convex's Privacy Policy at convex.dev/privacy.
**Vercel** — hosts the Fujinova web application. Vercel may process request logs including IP addresses. See Vercel's Privacy Policy at vercel.com/legal/privacy-policy.
These providers are contractually obligated to protect your data and may not use it for their own purposes.
Fujinova operates across Japan and the Philippines. Data entered on the platform may be transferred and stored outside the country in which it was collected. Specifically:
**Japan → United States:** Clerk and Convex are US-based companies. Personal data stored on the platform — including worker profiles, compliance records, and documents — is processed on servers located in the United States. The United States does not have a formal adequacy decision from Japan's Personal Information Protection Commission (PPC). By using the platform, you consent to this transfer on the basis that Clerk and Convex maintain data protection standards equivalent to those required under APPI, as reflected in their data processing agreements with Fujinova.
**Japan ↔ Philippines:** Worker data is accessible to placement agencies and the workers themselves, who are typically based in the Philippines. This cross-border access is necessary for the operation of the SSW recruitment and support workflow and is disclosed to workers at the time their profile is created.
If you have concerns about cross-border data transfers affecting a specific worker, contact dennisclemente@gmail.com. You may withdraw consent for cross-border processing, but doing so will prevent the worker's compliance profile from functioning on the platform.
We retain your data for as long as your account is active or as required to fulfil our compliance obligations.
Worker profiles are retained for a minimum of five years after a worker's visa status changes to "departed," consistent with Japanese immigration audit requirements. Employers and RSOs may request earlier deletion, subject to any legal retention obligations.
If you close your account, we will delete or anonymise your personal data within 90 days, except where we are required by law to retain specific records.
Depending on your location, you have the following rights over your personal data:
**Right to access** — you can request a copy of all personal data we hold about you.
**Right to correction** — you can ask us to correct inaccurate or incomplete data.
**Right to deletion** — you can ask us to delete your data, subject to legal retention requirements.
**Right to portability** — you can request your data in a machine-readable format.
**Right to object** — you can object to certain types of processing, including profiling.
**Right to withdraw consent** — where processing is based on consent (including sensitive personal information and cross-border transfers), you may withdraw that consent at any time by contacting dennisclemente@gmail.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, contact us at dennisclemente@gmail.com. We will respond within 30 days.
Japan — Personal Information Protection Commission (PPC)
Users in Japan may lodge a complaint with the PPC, Japan's supervisory authority for personal information protection, at ppc.go.jp.
Philippines — National Privacy Commission (NPC)
Workers and Philippine-based users may file a complaint with the NPC at privacy.gov.ph.
EU/EEA users
Where GDPR applies, you may also contact your local data protection authority.
We implement industry-standard security measures including encrypted data transmission (TLS), role-based access control, and audit logs on all data access. Document uploads are stored with access controls that prevent unauthorised retrieval.
In the event of a data breach affecting personal data, we will report the incident to Japan's Personal Information Protection Commission (PPC) and notify affected users as required under the APPI.
No system is completely secure. If you believe your account has been compromised, contact us immediately at dennisclemente@gmail.com.
We may update this Privacy Policy as the platform evolves. When we make material changes, we will notify you by email or via an in-platform notice at least 14 days before the changes take effect. The date at the top of this page always reflects the most recent update.
For privacy-related questions or requests:
**Email:** dennisclemente@gmail.com **General enquiries:** dennisclemente@gmail.com
Fujinova operates under the laws of Japan for its SSW compliance services and the laws of the Philippines for recruitment-related activities.