Privacy Policy
Effective date: 1 August 2026
Preface
Third Scope Ltd. (Japan), Third Scope Asia PTE. LTD. (Singapore), and Third Scope Europe Ltd. (United Kingdom) (individually or collectively, "we", "us", "our", or the "Company") operate our business across Japan, Singapore, and the United Kingdom under our shared vision: "Designing Intelligence — to design intelligence and open up market possibilities." We believe that handling the personal data of our customers, job applicants, and every visitor to our websites (third-scope.com, sg.third-scope.com, eu.third-scope.com, and their related pages; collectively, the "Site") responsibly is fundamental to earning your trust.
This Privacy Policy ("Policy") sets out our common approach to handling personal data collected through the Site, together with jurisdiction-specific supplementary provisions for Japan, Singapore, and the United Kingdom/European Economic Area ("EEA"), set out as Annexes.
This Policy has been prepared with reference to:
- Japan: the Act on the Protection of Personal Information ("APPI")
- Singapore: the Personal Data Protection Act 2012 ("PDPA")
- United Kingdom: the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018
- European Economic Area: Regulation (EU) 2016/679 ("EU GDPR"), to the extent we process personal data of individuals located in the EU/EEA through eu.third-scope.com
Part 1: Common Provisions
Article 1 (Definitions)
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"Personal data" means information relating to a living individual by which that individual can be identified, in accordance with the applicable definitions under APPI, PDPA, UK GDPR, and EU GDPR respectively.
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"Group" means Third Scope Ltd., Third Scope Asia PTE. LTD., Third Scope Europe Ltd., and Third Scope Marketing Co., Ltd., together with their affiliates.
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"Site Operator" means the entity operating the relevant domain of the Site, as set out below.
Domain Site Operator Location third-scope.com Third Scope Ltd. Japan sg.third-scope.com Third Scope Asia PTE. LTD. Singapore eu.third-scope.com Third Scope Europe Ltd. United Kingdom
Article 2 (Personal Data We Collect)
We principally collect the following personal data in connection with your use of the Site:
- Information you submit through our contact form (name, company, department, job title, email address, phone number, and the content of your inquiry).
- Information you submit through our recruitment/application form (name, contact details, information contained in your CV/resume, and other information relating to the recruitment process).
- Information you submit to download whitepapers or other materials (name, company name, email address, industry, etc.).
- Information you submit to subscribe to our newsletter (name, email address, etc.).
- Information collected automatically through cookies and similar technologies (IP address, browser information, browsing history, access timestamps, etc. — see our separate Cookie Policy for details).
Article 3 (Purposes of Use)
We use the personal data we collect for the following purposes:
- To respond to and manage inquiries and consultations.
- To conduct recruitment processes and communicate results to applicants.
- To provide whitepapers, materials, and related communications.
- To send newsletters.
- To operate, maintain, and improve the Site, including analytics.
- To provide information about our services, seminars, and events, and for marketing purposes (subject to your right to opt out under Article 10).
- To maintain the security of the Site and prevent misuse.
- To comply with legal obligations and to exercise or defend our rights under this Policy or related Terms of Use.
Article 4 (Cookies and Tracking Technologies)
The Site uses cookies and similar technologies for analytics purposes (such as Google Analytics) and for remarketing/retargeted advertising (such as Google Ads and Meta Ads). Please refer to our separate Cookie Policy for details on the categories of cookies used, their purposes, and how to manage or disable them. For users located in the UK and EU/EEA, we obtain prior consent for non-essential cookies through the cookie consent banner displayed on your first visit to the Site.
Article 5 (Security Measures)
- We implement appropriate organizational, human, physical, and technical security measures to prevent the leakage, loss, or damage of personal data.
- Third Scope Ltd. holds an Information Security Management System (ISMS/ISO 27001) certification (registration number: 50301700 ISMS22) and manages information in accordance with this management system. See our separate Information Security Policy for details.
- Where we engage third parties to process personal data on our behalf, we require them to implement appropriate security measures and exercise necessary and appropriate supervision.
Article 6 (Disclosure to Third Parties)
- Except as required by applicable law, we do not disclose personal data to third parties without your prior consent.
- We may engage service providers (including cloud service providers) to process personal data for purposes such as hosting, email delivery, CRM/marketing automation, analytics, and payment processing. We require such providers to implement appropriate security measures under contract.
Article 7 (Intra-Group Sharing and International Transfers)
- Personal data collected through inquiries, recruitment applications, and similar channels may be shared among Third Scope Ltd., Third Scope Asia PTE. LTD., and Third Scope Europe Ltd. to ensure consistent and appropriate handling across the Group.
- As a result of the sharing described above, and our use of cloud service providers whose servers may be located outside your home country, personal data may be transferred to and stored on servers located in Japan, Singapore, the United Kingdom, and other countries.
- Where required under applicable law, we implement appropriate safeguards for international transfers of personal data, such as entering into Standard Contractual Clauses (SCCs), verifying appropriate protections at the recipient, or using other lawful transfer mechanisms, having regard to the data protection framework of the recipient country.
- Jurisdiction-specific details on international transfers are set out in Annexes A through C.
Article 8 (Retention Period)
We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, and delete or anonymize it within a reasonable period thereafter in accordance with applicable law and our internal retention rules.
Article 9 (Your Rights)
Subject to applicable law, you may have rights to request disclosure, correction, addition, deletion, suspension of use, erasure, restriction of processing, data portability, and withdrawal of consent regarding your personal data. Jurisdiction-specific details are set out in Annexes A through C. To exercise these rights, please contact us using the details in Article 12.
Article 10 (Opting Out of Marketing)
You may opt out of receiving marketing communications (such as our newsletter) at any time, either via the unsubscribe link in the relevant email or by contacting us using the details in Article 12.
Article 11 (Children's Personal Data)
The Site is intended primarily for business-to-business communications, including inquiries and recruitment applications, and is not directed at individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a person under 18, we will take appropriate action in accordance with applicable law.
Article 12 (Contact Us)
For questions about this Policy, or to exercise your rights regarding your personal data, please contact our unified privacy contact point:
- Contact: Data Protection Officer, Third Scope Ltd. — Shuto Nakazato
- Email: ga@third-scope.com
- Address: Aoyama SI Building 3F, 1-1-11 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan
Inquiries relating to Third Scope Asia PTE. LTD. or Third Scope Europe Ltd. are, as a general rule, also handled through this unified contact point, which will coordinate with the relevant local team as necessary.
Article 13 (Changes to This Policy)
We may update this Policy from time to time to reflect changes in law or our business. Material changes will be notified via posting on the Site or other appropriate means. Any updated Policy takes effect from the time it is posted on the Site.
Part 2: Annexes
Annex A: Japan (Third Scope Ltd.) — Supplementary Provisions
- Site Operator: Third Scope Ltd. — Aoyama SI Building 3F, 1-1-11 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan.
- Applicable law: the Act on the Protection of Personal Information (APPI).
- Requests regarding retained personal data: Under APPI, you may request notification of the purpose of use, disclosure, correction/addition/deletion, and suspension of use/erasure/suspension of third-party provision of your retained personal data. Requests should be submitted in writing or by email to the contact point in Article 12; we may request identity verification.
- Cross-border provision to third parties: Where we provide personal data to Third Scope Asia PTE. LTD., Third Scope Europe Ltd., or other overseas service providers, we do so either with your prior consent or, where applicable, by ensuring the recipient has implemented a system that satisfies APPI Article 28 and its related requirements.
- Publication of matters concerning retained personal data: This Policy serves as the publication of matters concerning retained personal data required under APPI.
Annex B: Singapore (Third Scope Asia PTE. LTD.) — Supplementary Provisions
- Site Operator: Third Scope Asia PTE. LTD. — One&Co, 20 Anson Road, #11-01 Twenty Anson, Singapore 079912.
- Applicable law: the Personal Data Protection Act 2012 (PDPA).
- Data Protection Officer (DPO): Third Scope Asia PTE. LTD. designates the unified contact point set out in Article 12 (Shuto Nakazato, ga@third-scope.com) as its Data Protection Officer for PDPA purposes.
- Consent Obligation: We collect, use, and disclose personal data with your consent, in accordance with the PDPA, unless an exception under the PDPA applies (for example, where necessary for the conclusion or performance of a contract).
- Transfer Limitation Obligation: Where personal data is transferred outside Singapore (including to our Japan and UK Group companies, and to overseas cloud service providers), we take contractual and other measures to ensure a standard of protection comparable to the PDPA at the recipient, as required under the PDPA and the Personal Data Protection Regulations.
- Access, correction, and complaints: You may request access to and correction of your personal data under the PDPA. Complaints should first be directed to the contact point in Article 12; unresolved complaints may be referred to the Personal Data Protection Commission (PDPC) at https://www.pdpc.gov.sg.
Annex C: United Kingdom and European Economic Area (Third Scope Europe Ltd.) — Supplementary Provisions
- Site Operator: Third Scope Europe Ltd. — Suite 1 Chantal House, 13-17 High Beech Road, Loughton, IG10 4BN, United Kingdom.
- Applicable law: the UK GDPR and the Data Protection Act 2018. Where we process personal data of individuals located in the EU/EEA through eu.third-scope.com, the EU GDPR (Regulation (EU) 2016/679) also applies.
- Data Controller: Third Scope Europe Ltd. is the data controller for personal data collected through eu.third-scope.com.
- Lawful basis: We rely on steps taken prior to entering into a contract or legitimate interests to respond to inquiries, recruitment applications, and material requests, and generally rely on consent for marketing communications.
- Data subject rights: Under the UK GDPR/EU GDPR, you have the right to access, rectify, erase ("right to be forgotten"), restrict processing of, port, object to the processing of, and withdraw consent regarding your personal data.
- International transfers: Where personal data is transferred to our Japan or Singapore Group companies, or to cloud service providers outside the UK/EEA, we use Standard Contractual Clauses (SCCs), the International Data Transfer Agreement (IDTA), or other lawful transfer mechanisms recognized under the UK GDPR/EU GDPR.
- Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority:
- United Kingdom: the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom — https://ico.org.uk
- EU/EEA residents: the data protection supervisory authority of your EU/EEA member state of residence.
- EU Representative: Third Scope Europe Ltd. is a UK company and does not have an establishment in the EU. Where required by the nature and extent of our activities directed at the EU, we will appoint an EU Representative under Article 27 of the EU GDPR and publish their details in this Annex.