HITOWA Holdings Co., Ltd. (hereinafter referred to as the "Company," "we," or "our") considers the protection of customers' personal information as our social responsibility, and will comply with laws and regulations as well as norms established by administrative agencies regarding the protection of personal information. Our approach to privacy is as provided below. Our policy may be revised or deleted at any time due to the revision of laws and regulations or other circumstances, but our most recent policy is posted on this page.

1. Collection of Personal Information

We clearly define the purposes of collecting personal information within the scope of our business and collect personal information only to the extent necessary to achieve those purposes. We do not acquire any special care-required personal information without the consent of the principal, except in cases prescribed by laws and regulations.

【Customers】
We collect necessary personal information when customers make inquiries or applications for the Company's services or when providing the services to customers.

【Business Partners】
We collect necessary personal information when conducting transactions (including negotiations in conducting transactions).

【Job Applicants】
We collect necessary personal information in connection with procedures related to recruitment such as requests for information materials, applications for information sessions, and applications for selection.

【Employees】
We collect necessary personal information when conducting internal procedures.

2. Purposes of Use of Personal Information

The Company uses personal information for the purposes described below.

【Customers】

1. (1)To provide various types of services
2. (2)To conduct questionnaire surveys, market research, and customer usage analysis
3. (3)To provide information on various types of services
4. (4)To improve and enhance services provided to customers
5. (5)To create statistical data based on customers' purchasing histories and questionnaire surveys as well as gender, age, and other attribute information, which is prepared in such a way that individuals cannot be identified or specified, and use such data in the development and provision of new products and services.

【Business partners】

To conduct and communicate business negotiations and meetings, and to provide information to persons in charge

【Job applicants】

1. (1)To send information about the HITOWA Group and recruitment
2. (2)For recruitment selection and management of applicants who have already received job offers

【Employees】

For labor management of the Company's employees

3. Acquisition and Use of Non-personally Identifiable Attribute Information and Behavior History

The Company's website uses a program provided by an advertisement distribution company to conduct behavioral targeting advertising on specific sites (an advertising method that delivers advertisements tailored to the interests and concerns of the principal based on site browsing information, etc.). In doing so, cookies are used to gather information about the principal's sites visiting history. (However, that information does not include any information that can identify or distinguish an individual.)

The advertisement distribution company uses the cookies to distribute advertisements based on information about past access to our website. If you wish to disable this advertising, you can disable the use of cookies by visiting the advertisement distribution company's opt-out page. When you change your browser, delete cookies, or change to a new computer, etc., you will need to change your settings again.

On our advertising opt-out page, the principal can change settings not to use Google's cookies (the use of cookies from third-party distributing companies on the Network Advertising Initiative opt-out page can be disabled). If you do not opt out, cookies from Google and also other third-party distributing companies or advertising networks may be used. The Network Advertising Initiative's opt-out website allows you to disable some (but not all) cookies all at once.
The URLs of the opt-out pages are as follows.

Yahoo's opt-out page

http://btoptout.yahoo.co.jp/optout/preferences.html

Google's opt-out page

https://support.google.com/ads/answer/2662922?hl=ja

Network Advertising Initiative's opt-out page

http://www.networkadvertising.org/choices/#completed

4. Disclosure to Third Parties

The Company will not disclose or provide the principal's personal data to third parties without his or her consent. However, this does not apply to the following cases.

1. (1)When disclosure requirements or provision obligations are stipulated by laws and regulations, etc.
2. (2)When it is reasonably judged to be necessary to protect the principal's rights, life, property, or safety or those of a third party
3. (3)When entrusting the handling of retained personal data to a third party that we judge to be trustworthy within the scope necessary to achieve the legitimate purposes of use, after concluding a non-disclosure agreement with the third party (in such cases, we appropriately supervise the handling of the personal data by the third party)

When we provide personally-related information forming part of our personally-related information database, etc. to a third party, we will do so only after confirming that the principal's consent has been obtained if the third party is expected to acquire the personally-related information as personal data.

5. Joint Use

The Company may use personal data jointly with the HITOWA Group companies as set forth below.

Purposes of use Information, provision, and management concerning services and employment

6. Management of Retained Personal Data

We manage personal data properly with strict security under the supervision of the person responsible for the management of personal data. We will pursue the highest possible level of security to prevent unauthorized access, loss, destruction, falsification, leakage, etc. of personal data.

7. Retained Personal Data

The Company uses retained personal data within the scope of the purposes of use of personal information. When we receive a demand from a principal for disclosure, correction, addition, deletion, or discontinuation of use of retained personal data, we will make a disclosure, correction, addition, deletion, or discontinuation of use of the retained personal data managed by the Company as soon as possible in accordance with the following procedures, only after confirming that the request was made by the principal or his or her agent. Please make inquiries to the point of contact specified in "8. Inquiries" for application destinations and fees, etc. of specific procedures.

【Disclosure】
In principle, we will disclose retained personal data by the method desired by the principal, except in the following cases. However, in cases where the said method requires a large amount of costs or in other cases where it is difficult to disclose the retained personal data by the said method, we will disclose the retained personal data in writing, after notifying the principal to that effect.

1. (1)Cases in which there is a possibility of harming a principal or third party's life, body, fortune or other rights
2. (2)Cases in which there is a possibility of interfering seriously with the proper execution of the Company's business
3. (3)Cases of violating other laws or regulations

【Correction】
When the Company receives a demand from a principal for a correction, addition, or deletion (hereinafter referred to as "Correction, etc.") to retained personal data on the grounds that the contents of the retained personal data are not factual, after conducting the necessary investigations within the scope required to achieve the purposes of use, the Company will make a Correction, etc. to the retained personal data, based on the results of the investigations, and notify the principal.

【Utilization Cease and Deletion】
When the Company receives a demanded from a principal for a utilization cease or deletion (hereinafter comprehensively referred to as "Utilization Cease, etc.") of retained personal data for any of the following reasons, if we judge that there are grounds for such a demand, we will fulfill a Utilization Cease, etc. of the retained personal data without delay to the extent necessary to correct the violation. This, however, shall not apply in cases where a Utilization Cease, etc. of the said retained personal data requires a large amount of expenses or other cases where it is difficult to fulfil a Utilization Cease, etc. and when the Company takes necessary alternative action to protect the principal's rights and interests.

1. (1)For the reason that the retained personal data is used for unintended purposes without the consent of the principal
2. (2)For the reason that the personal information was acquired by deceit or other improper means, or that the special care-required personal information was acquired without the consent of the principal
3. (3)For the reason that the personal information was used in a manner that may encourage or induce illegal or unjust acts
4. (4)For the reason that the Company no longer needs to use the retained personal data
5. (5) For the reason that reporting obligations have arisen due to leakage, etc. of personal data in retained personal data
6. (6)For other reasons that the handling of retained personal data may harm the rights or legitimate interests of the principal

【Ceasing of Third-Party Provision】
When the Company receives a demand from a principal for a cease of third-party provision of retained personal data for any of the following reasons, if we judge that there are grounds for such demand, we will cease the third-party provision of retained personal data without delay to the extent necessary to correct the violation. This, however, shall not apply in cases where a third-party provision of the retained personal data requires a large amount of expenses or other cases where it is difficult to cease a third-party provision and when the Company takes necessary alternative action to protect the principal's rights and interests.

1. (1)For the reason that the retained personal data is provided to a third party without the consent of the principal
2. (2)For the reason that the Company no longer needs to use the retained personal data
3. (3)For the reason that reporting obligations have arisen due to leakage, etc. of personal data in retained personal data
4. (4)For other reasons that the handling of retained personal data may harm the rights or legitimate interests of the principal

8. Inquiries

Inquiries regarding the handling and management of personal information should be directed to the following point of contact. Please also feel free to contact us in relation to disclosure, correction, etc. of personal information or any other questions or complaints.

HIDAKA Hiromi, President and Representative Director
HITOWA Holdings Co., Ltd.
Shinagawa Intercity C, 2-15-3, Konan, Minato-ku, Tokyo, 108-6215, Japan
Tel: ＋81-3-6632-7700
Office Hours: 9:00 to 18:00 Monday through Friday. Closed on Saturdays, Sundays and Public Holidays.