システムレンズ評価 · System Lens Evaluation · systemlensevaluation.com
System Lens Evaluation (システムレンズ評価) is a sole proprietorship registered in Japan, operated by Kirsi Erin Page. We provide independent software evaluation and user testing services through the platform at systemlensevaluation.com.
For the purposes of UK GDPR and data protection law applicable to UK and European data subjects, System Lens Evaluation is also affiliated with Hidden Insight Labs Ltd (UK Company No. 16941841), which holds ICO registration number ZC149156.
We process personal data only where we have a lawful basis to do so under UK GDPR (for UK/European data subjects) and Japan's Act on the Protection of Personal Information (APPI) (for Japanese data subjects).
| Processing activity | Legal basis |
|---|---|
| Delivering evaluation services to clients | Contract — Art. 6(1)(b): necessary to perform our contract with you |
| Processing tester participation and assignments | Contract — Art. 6(1)(b): necessary to perform our agreement with you as a tester |
| Processing payments (Stripe / Wise) | Contract — Art. 6(1)(b): necessary to fulfil payment obligations |
| Maintaining NDA and agreement records | Legal obligation / Legitimate interests — Art. 6(1)(c)/(f): compliance and dispute resolution |
| Responding to enquiries from prospective clients | Legitimate interests — Art. 6(1)(f): our interest in managing our business pipeline |
| Website analytics (GA4) | Legitimate interests — Art. 6(1)(f): understanding site performance with anonymised data |
| Email notifications about new assignments (testers) | Consent — Art. 6(1)(a): you have opted in to notifications |
Payment processing for client engagements is handled by Stripe, Inc., a PCI DSS-compliant payment processor. When you make a payment, you are providing your payment details directly to Stripe — we do not receive, store, or have access to your full card number, CVV, or other sensitive payment credentials.
Stripe may collect and process the following on our behalf:
Stripe is an independent data controller for its own fraud prevention and compliance purposes. You can read Stripe's privacy policy at stripe.com/privacy.
We retain records of transaction amounts, dates, and associated client identifiers for our accounting and tax obligations (see Section 8).
System Lens Evaluation is operated from Japan. Japan has received an adequacy decision from the UK (under Article 45 UK GDPR), meaning the UK recognises Japan's data protection standards as equivalent. No additional safeguards are required for transfers between the UK and Japan.
Several of our service providers are based in the United States. We ensure transfers are protected by Standard Contractual Clauses (SCCs) or, where applicable, UK International Data Transfer Agreements (IDTAs) approved by the ICO.
Our tester network includes individuals located globally, including in the EU, UK, Japan, and other countries. We apply UK GDPR protections to all data subjects regardless of location.
| Data type | Retention period | Reason |
|---|---|---|
| Client contracts and engagement records | 6 years from project end | UK Limitation Act 1980 / contractual claims period |
| Payment and invoice records | 7 years from transaction date | Japanese tax law (5 years) and UK HMRC requirements (6 years), retaining the longer period |
| Tester profiles (active) | Duration of active tester status + 12 months | Operational need |
| Tester profiles (inactive / deregistered) | 12 months after last activity or deregistration | Legitimate interest; then deleted or anonymised |
| NDA records | 6 years from signing | Contractual / dispute resolution |
| Test submissions and evaluation data | 3 years from project completion | Operational need and dispute resolution |
| Contact form enquiries (not converted) | 12 months | Legitimate interest in managing our pipeline |
| Stripe transaction records | As per Stripe's own retention policy | Stripe is an independent controller for compliance purposes |
Under UK GDPR, if you are a UK or European data subject, you have the following rights:
Request a copy of the personal data we hold about you.
Ask us to correct inaccurate or incomplete data about you.
Ask us to delete your data where there is no longer a lawful reason to hold it.
Ask us to pause processing your data in certain circumstances.
Receive your data in a structured, commonly-used format.
Object to processing based on legitimate interests.
Withdraw consent at any time where processing is consent-based (e.g. email notifications).
We do not use automated decision-making or profiling that produces legal effects.
Japanese data subjects also have rights under Japan's Act on the Protection of Personal Information (APPI), including the right to disclosure, correction, and suspension of use of personal information. These rights can be exercised using the same contact details in Section 13.
We will respond to all rights requests within one calendar month. We will not charge a fee in most cases.
In the event of a personal data breach, we will notify the ICO within 72 hours where required and inform affected individuals without undue delay.
We review this notice at least annually and whenever there are material changes to how we process personal data. The "last reviewed" date at the top will be updated accordingly.
Where changes are significant, active clients and testers will be notified by email before the changes take effect.
システムレンズ評価 (System Lens Evaluation)
Operated by: Kirsi Erin Page
📧 Email: privacy@systemlensevaluation.com
For UK/European data subjects, you may also contact us in relation to ICO registration ZC149156 via Hidden Insight Labs Ltd, 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ.
Website: ico.org.uk/make-a-complaint
Phone: 0303 123 1113
Post: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: ppc.go.jp/en
We would appreciate the opportunity to address any concerns directly before you contact a supervisory authority.