Kitamura Holdings Co., Ltd. (hereinafter referred to as "KHD") acknowledge that the protection of
personal information is an important social responsibility of KHD and declare that KHD will handle the
personal information of KHD’s customers and business partners (hereinafter referred to as the
"Customers") appropriately and safely.
Under this declaration, KHD announce the Privacy Policy (hereinafter referred to as the "Policy")
hereunder.
1. Definition and Scope of Personal Information
"Personal Information" in the Policy shall mean information about an individual and the information
that
can identify a specific individual by certain information contained in such information (which is the
same meaning as Article 2 of the Personal Information Protection Act). However, the Policy shall not
be
applied to the Personal Information which is hyperlinked to websites included in the latest website
operated by KHD (hereinafter referred to as the "KHD Website") or which is registered in any other
websites which KHD is not directly operated Personal information registered on linked websites and
other
websites that are not directly managed by KHD.
2. Compliance with Laws and Regulations Concerning Personal Information, National Guidelines and Other
Norms
KHD, as a company to receive the important Personal Information from the Customers, shall comply with
the laws and regulations concerning the handling of Personal Information Protection, guidelines and
policies given by various competent authorities based on the Act on the Protection of Personal
Information, and other norms related to Personal Information Protection (hereinafter referred to as
"Related Laws").
3. Appropriate Acquisition of Personal Information
(1) KHD shall handle Personal Information acquired by lawful and fair means.
(2) When acquiring Personal Information directly from the Customers, KHD shall clearly indicate to the
Customers the necessary matters such as the purpose of use of Personal Information and obtain
consents.
When acquiring personal information indirectly from a third party, KHD shall confirm whether the
provider of such information has obtained Personal Information properly from the Customer, and KHD
shall
announce the necessary matters such as the purpose of use of personal information on the KHD Website.
(3) KHD will not acquire specific sensitive Personal Information that falls under the following.
Provided however, this shall not apply if the acquisition of such Personal Information is required by
the Related Laws.
- Information on ideas, beliefs or religions
- Race, ethnicity, family origin, permanent domicile (excluding information on the prefecture where
you are located), information that causes physical or mental disorders, criminal records, and other
social discrimination
- Information on workers' right to organize, collective bargaining, and other acts of collective
action
- Information related to participation in collective demonstrations, exercise of petition rights,
and
other exercise of political rights
- Information on health care or sex life
(4) KHD has introduced access analysis tools and advertising analysis tools provided by third party
companies for the purpose of improving websites and services. These tools use cookies (an industry
standard technology in which a web server identifies Customers’ browser, and it shall be the same
hereinafter.) and measure the Customer’s use of the KHD Website, the number of times showing and
clicking advertisements, the display of contents and advertisements tailored to the Customer and
provide
social media functions. In addition, the measured data is provided to third party companies in data
analysis, advertisement distribution, and social media. Cookies can identify the Customers’ browser,
but
not the Customer individually.
4. Purpose of Use of Personal Information
The acquired Personal Information will be used to the extent necessary for the execution of business
within the scope of the following purposes of use. In addition, when entrusting the handling of
Personal
Information to a third party, KHD will supervise the third party to fulfill the appropriate use of
Personal Information.
- To confirm and respond to the content of inquiries or opinions from the Customers
- To contact with, handle and manage the Customers (including business operators who may become
business partners) for the course of business and transactions
- To manage and guide shareholders stipulated in laws and regulations such as the Companies Act
- To provide information on recruitment and recruitment selection
- For other purposes incidental to the above purpose of use
5. Prohibition of the Use of Personal Information other than the Purpose
KHD will not use Personal Information beyond the scope necessary to achieve the specified purpose of
use
for any purpose. In addition, in order to prevent the use of Personal Information for purposes other
than the purpose, KHD conducts daily inspections, internal audits, etc. of the management system of
Personal Information.
6. Appropriate Provision of Personal Information to Third Parties
Except the following cases, KHD will properly manage the acquired Personal Information and will not
provide or disclose it to any third parties other than the Customers without obtaining their consent
in
advance.
- When based on laws and regulations
- When it is necessary for the protection of human life, body or property, and it is difficult to
obtain the consent of the person.
- When it is particularly necessary to improve public health or promote the sound development of
children, and it is difficult to obtain the consent of the person.
- When it is necessary for KHD to cooperate with a national organization, local public entity, or a
person entrusted thereto with carrying out the affairs prescribed by laws and regulations, and there
is a risk that obtaining the consent of the person will interfere with the execution of the affairs.
7. Ensuring the accuracy of the contents of personal information
KHD will endeavor to keep the contents of Personal Information as accurate and up to date as possible
to
the extent necessary to achieve the purpose of use.
8. Prevention of Leakage, Loss or Damage of Personal Information
In order to prevent leakage, loss or damage of Personal Information through unauthorized access, etc.,
KHD will take the following safety management measures. In the wake of any deficiencies in safety
management, KHD will promptly take corrective action.
- Store Personal Information in the information system that has been subjected to measures against
unauthorized access and acquire and monitor access logs.
- Store papers and electric media which record Personal Information in the locked space.
- Take physical safety control measures to prevent unauthorized intrusion to Offices and server
rooms
- Acknowledge that contractors who are entrusted with the processing and storage of protection of
Personal Information are done adequately and conduct necessary supervision.
9. Supervision of Employees and Contractors
(1) To properly manage Personal Information, KHD will conduct necessary education and training, etc.
for
persons engaged in the business of handling Personal Information and conduct appropriate supervision.
(2) When outsourcing to entrust the handling of Personal Information to an outside party, KHD shall
manage and supervise to handle Personal Information appropriately by the consignee by concluding
agreements including, but not limited to a confidentiality agreement.
10. Continuous Improvement of Personal Information Protection Management System
To appropriately use and thoroughly protect Personal Information, KHD will periodically verify and
continuously improve KHD’s Personal Information Protection management system in accordance with
changes
in business environment and social conditions, advances in information security technology, and the
enactment and revision of laws and regulations.
11. Inquiries about Personal Information
(1) Responding to complaints and consultations
When KHD receive complaints, consultations regarding the handling of Personal Information, KHD respond
as quickly and appropriately as possible at the following complaints and consultation desks regarding
Personal Information.
(2) Requests for Personal Information
When KHD receive requests notification, disclosure, correction, addition, deletion, suspension of use,
suspension of provision to third parties, or erasure of the purpose of use related to Personal
Information, KHD will process upon confirmation of the identity of the person.
(3) Regarding complaints, consultations and various claims set forth in Paragraph 1 and the preceding
paragraph of this Article, please contact below.
6-16-6 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023
Kitamura Holdings Co., Ltd.
Personal Information Protection Office
Email: info@kitamura-group.co.jp
(Business hours will be from 10:00 to 18:00 on weekdays.)
Established and enforced on April 1, 2019
Amended on March 23, 2022
Kitamura Holdings Co., Ltd.
SHINJUKU i-LAND WING 13F, 6-3-1 Nishishinjuku, shinjuku-ku, Tokyo 160-0023
Kazuhiro Fukumoto
