Handling of Personal Information Protection
Privacy Policy
Sinanen Holdings Co., Ltd. (below, "the Company") considers the protection of personal information to be a social responsibility of a corporation, and has established the following Privacy Policy regarding the handling of personal information.
- When acquiring personal information, the Company shall clarify the purpose of use and obtain the consent of the person concerned. Personal information shall not be used or provided for any purpose other than the intended use.
- Respecting the rights of individuals regarding their personal information, the Company will respond to requests for disclosure, correction, or deletion of their information, or refusal to use or provide their information, within a reasonable period of time and to a reasonable extent.
- Based on our Information Security Policy, the Company will appropriately manage personal information and take measures to prevent unauthorized access, falsification, leakage, and other threats.
- The Company will comply with laws, regulations, ordinances, and other social norms related to personal information, as well as internal rules and regulations, and will respond appropriately.
- The Company will establish and operate an appropriate management system for the protection of personal information. The Company will improve the management system as appropriate and provide ongoing training for employees.
Established October 1, 2015
Revised November 1, 2022
Revised September 1, 2023
Sinanen Holdings Co., Ltd.
Taro Nakagome, President and CEO
Announcement in Accordance with the Act on the Protection of Personal Information
1. Definition of personal information
In this Announcement, personal information means personal information as defined in Article 2, Paragraph 1 of the Act on the Protection of Personal Information (below, "Personal Information Protection Act") (information about a living individual that can be identified as a specific individual and information that can be easily identified as a specific individual by linking it with other information or that contains a personal identification code). In order to ensure the appropriate and smooth operation of its business, the Company collects the following types of personal information.
•Profile information such as name, date of birth, gender, occupation, etc.
•Contact information such as email address, telephone number, address, etc.
•Credit card information, bank account information, e-money information, and other payment methods
•Other information obtained in connection with the provision of services, such as the contents of applications, inquiries, and responses to questionnaires
•Information legally obtained from third parties such as affiliates
2. Purposes of acquisition and use
The Company will acquire personal information through legal and fair means and procedures. In addition, the Company will acquire personal information for the purposes corresponding to the categories in the table below (below, "purposes of use"), and will use personal information within the scope necessary to achieve the purposes of use.
| Contents of personal information | Purposes of use |
|---|---|
| Personal information handled by each service | •To operate and maintain services •To report the status of service use to users •To contact users as necessary for maintenance, important notices, etc. •To provide information on new features, updates, renewals, and campaigns of services •To identify users who have violated the terms of use or who are attempting to use services for illegal or unjust purposes, and to refuse their use of services •To improve the contents of services or develop new services •To provide information on products and services handled by the Company and the Sinanen HD Group (Note 1) (including sending e-mails, flyers, and other direct mailings) •To provide information on events, etc. held by the Company and the Sinanen HD Group * For detailed information on the purposes of use of personal information for each service, please refer to the contract or equivalent document for each service. |
| Personal information related to inquiries | •To respond to opinions, inquiries, etc. from users of services (including to confirm the identity of specific individuals identified by personal information (below, "the individual")). |
| Personal information registered at exhibitions and events | •To conduct questionnaire surveys regarding our products and services •To request cooperation for interviews, etc. •To report on events you have attended |
| Personal information related to business partners | •To communicate, respond to, and manage business and transactional matters |
| Shareholder information (Note 2) | •To respond to the exercise of rights and fulfillment of obligations of shareholders, etc., in accordance with the Companies Act and other related laws and regulations. |
| Information on job hunters | •For employment selection |
| Information on employees | •For employee management |
| Information on retired employees | •To provide information to retired employees |
| Personal information and cookie information obtained from the Company's website | •To survey and analyze service usage history, etc., and use the results to improve and develop the services of the Sinanen HD Group companies and to distribute advertisements. |
| Other | •For purposes incidental to the above |
(Note 1) The Sinanen HD Group refers to companies in which the Company directly or indirectly holds 20% or more of the voting rights of all shareholders.
(Note 2) Please refer to "Stock Information" in "Investor Relations" for inquiries regarding personal information of shareholders.「Click here for details
3. Change of purposes of use
If the Company changes the purposes of use described in 2. above, it will do so within the scope reasonably deemed to be relevant to the purposes of use before the change, and will notify or publicly announce the changed purposes of use by e-mail, on the Company's website, or by any other method the Company deems appropriate.
4. Security control measures
The Company shall take the following measures to ensure the safe management of personal information.
(1) Establishment of basic policy
The Company has established the Privacy Policy to ensure the appropriate handling of personal information.
(2) Establishment of rules and regulations concerning the handling of personal information
The Company has established rules and regulations regarding the protection of personal information, including the responsibilities of information managers and rules for the acquisition, use, provision, and management of personal information.
(3) Organizational security control measures
In addition to appointing a person responsible for the handling of personal information, the Company has appointed a manager in each department that handles personal data and conduct regular audits of the status of personal information handling.
(4) Personnel security control measures
Regular training is provided to employees on matters concerning the handling of personal information.
(5) Physical security control measures
Measures are taken to prevent theft or loss of equipment, electronic media, and documents that handle personal information.
(6) Technical security control measures
Access control is implemented to limit the scope of persons in charge and the personal information database, etc. handled.
(7) Understanding the external environment
When storing personal information outside of Japan, the Company implements appropriate security control measures based on its understanding of the systems for the protection of personal information in the relevant foreign country.
5. Outsourcing of personal information handling operations
The Company may outsource all or part of the handling of personal information to a subcontractor (i.e., outsourcing to another business entity the processing of personal information, including input, editing, analysis, and output) to the extent necessary for the achievement of the purposes of use. In such a case, the Company will fully examine the eligibility of the subcontractor, properly stipulate confidentiality, security control measures, and other matters related to the handling of personal information in the consignment contract, and exercise necessary and appropriate supervision over the subcontractor to ensure the safe management of personal information by the subcontractor.
6. Disclosure and provision of personal information to third parties
We will not disclose or provide personal information to third parties, except in the following cases or other cases recognized as exceptions by the Personal Information Protection Act.
(1) When the individual has consented
(2) When disclosure or provision of personal information is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual
(3) When disclosure is especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the consent of the individual
(4) When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of the affairs concerned
(5) When personal information is provided in conjunction with the Company's entrustment of all or part of the handling of personal information within the scope necessary for the achievement of the purposes of use
(6) When personal information is provided in connection with the succession of business due to merger or other reasons
(7) When in accordance with laws and regulations
7. Joint use
The Company may jointly use acquired personal information within the scope and for the purposes listed below.
(1) Items of personal information to be jointly used
Personal information as described in "1. Definition of personal information"
(2) Scope of joint users
Sinanen HD Group companies
(3) Purposes of use by joint users
Purposes of use as described in "2. Purposes of acquisition and use"
(4) Name of the person responsible for the management of personal information under the joint use
As described in the representative of Sinanen Holdings Co., Ltd.(Company Profile)
8. Use of cookies
(1) The websites of the Sinanen HD Group companies may use cookies or similar technologies to obtain and use information on users' activity history for the purpose of improving the convenience of users browsing the websites, improving the performance of the websites themselves, improving and enhancing the content of services, and displaying appropriate advertising. Although users may disable cookies by changing the settings of their website browsing software (browser), but please note that this may prevent the use of some website features.
(2) Websites of Sinanen HD Group companies use Google Analytics, an access analysis tool provided by Google LLC. Google Analytics also uses cookies to provide the tool provider with information on the user's activity history. This information may be used to deliver advertisements, etc. to users, conducted by Google. Please refer to the following URL for the method to disable (opt-out) the provision of information to such tools.
9. Disclosure, correction, etc.
(1) Requests for disclosure of personal information
The Company will respond appropriately within a reasonable period of time after confirming that the request is made by the individual or his/her representative, in accordance with laws and regulations. However, this does not apply to cases in which the Company is not obligated to disclose the information under the Personal Information Protection Act or other laws and regulations.
(2) Requests for correction, addition, deletion, suspension of use, elimination, etc. of personal information
Upon confirming that the request is made by the individual, the Company will correct, delete, etc. the personal information to the extent necessary for its business operations.
10. Contact point for inquiries
Please direct any comments, questions, complaints, or other inquiries regarding the handling of personal information to the following contact point.
Risk Management Team, Business Administration Department, Sinanen Holdings Co., Ltd.
11. Other
The Company will change the Privacy Policy and Announcement based on the Act as necessary. In the event of any changes, the Company will notify or publicly announce the effective date and content of the revised policy and Announcement by posting them on the Company's website or by other means.
Request for Disclosure of Personal Information
November 1, 2022
Last update: April 1,2024
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