Privacy Policy
1．Basic principles
Hakuhodo Inc. (“the Company", "We", "Us" or "Our") proposes, produces and implements client marketing activities and other measures designed to uplift lifestyle value based on Our Sei-katsu-sha Insight and Partnership philosophies. We believe that the most important consideration enabling Us to consistently provide superior proposals is having deep understanding of sei-katsu-sha Our term for the holistic person—and responding to their needs. As such, sei-katsu-sha data, which is the basis of this understanding, is crucial to Our corporate activities. For this reason, until now We have recognized the management of personal information, which is one kind of sei-katsu-sha data, as an important matter in Our corporate activities, and have acted accordingly. Given that social scrutiny of the protection of personal information has been increasing recently, We have expressly indicated Our policies regarding the handling of personal information internally and externally, and declare here that all executives and employees will adhere to these policies.
The Company will handle personal information We acquire on Our own, personal information entrusted to Us by business partners, and personal information related to Our executives and employees and those of Our affiliates appropriately and in strict accordance with all related laws, industry standards and internal regulations.
2．Strict adherence with related laws and regulations
The Company adheres to laws, regulations, guidelines set by the government, and other norms related to personal information.
3．Personal information handled by the Company
Except as prescribed by laws and regulations, the Company utilizes personal information within the scope of the utilization purposes outlined below. In cases where utilization is for purposes other than those outlined below, We will inform the individuals concerned of or disclose to the public the utilization purpose at the time of acquisition.
Moreover, in cases where a utilization purpose other than those outlined below occurs or when acquiring personal information of a type other than that outlined below, We will inform of or disclose to the public such utilization purpose in advance. In cases where necessary, We will utilize the information only after obtaining consent.
3-1．Personal information acquired by the Company itself
| Type of personal information acquired | Utilization purpose |
|---|---|
| Personal information related to participants of seminars, lectures and other events organized by the Company | · Emails regarding notification about the relevant event to invite participation and regarding sharing information, etc. after the event; communicating and responding to inquiries by telephone, etc. · Emails regarding notification about further events, etc.; communicating and responding to inquiries by telephone, etc. · Analysis work to improve events and the content of email newsletters, etc. |
| Personal information for supporting companies the Company receives a third party provision of in relation to events, etc. to which the Company is providing support | · Providing information on and responding to inquiries about the Company’s services, events, seminars, campaigns, questionnaires, etc. by email newsletter, etc. · Analysis work for selecting events to support and for improving the content of email newsletters, etc. |
| Personal information related to subscription to the Company's email newsletters | · Providing information on and responding to inquiries about the Company’s services, events, seminars, campaigns, questionnaires, etc. by email newsletter, etc. · Analysis work to improve the content of email newsletters, etc. |
| Personal information related to individuals visiting the Company | · Reception desk assistance and announcing the arrival of a guest to the relevant Company personnel · Crime prevention (including the use of security cameras) |
| Personal information related to business partners | · Communication, etc. by email, telephone, etc., related to discussing and confirming business matters · Completing shipping labels for sending voucher copies of newspapers, magazines, etc. · Completing shipping labels for sending seasonal greetings, etc. · Providing information on and responding to inquiries about the Company’s services, events, seminars, campaigns, questionnaires, etc., by email newsletter, etc. |
| Personal information related to individuals who would like to join the Company and individuals who access information provided by the Company | Communication related to recruitment activities and joining the Company; utilization in activities necessary for screening/future recruitment planning, etc. of the Company |
| Personal information related to executives and employees of the Company, and their families | Examples of utilization necessary in business operations, human resources operations and other corporate operations · Executing work related to human resources management (work management, reassignments, secondments, transfers, promotions, retirements, dismissals, evaluations, disciplinary actions, communication in emergencies, etc.) and employment management · Executing work related to wage management (salaries, bonuses, retirement benefits, corporate pensions, cost management, etc.) · Executing work related to social insurance · Executing work related to taxation (income taxes, local inhabitant taxes, etc.) · Executing work related to implementing education · Executing work related to insurance and safety management · Executing work related to welfare, occupational health and safety, health management, etc. · Executing work related to building entry control (creation of entry/exit cards, acquisition of entry/exit logs, etc.) · Work, etc. related to or peripheral to the work outlined above In cases where personal information will be utilized for purposes other than those outlined above, the utilization purpose will be indicated to executives and employees as necessary |
| Personal information related to executives and employees of Group companies, and their families | Examples of utilization necessary in business operations, human resources operations and other corporate operations · Executing work related to human resources management (work management, reassignments, secondments, transfers, promotions, retirements, dismissals, evaluations, disciplinary actions, communication in emergencies, etc.) and employment management · Executing work related to wage management (salaries, bonuses, retirement benefits, corporate pensions, cost management, etc.) · Executing work related to social insurance · Executing work related to taxation (income taxes, local inhabitant taxes, etc.) · Executing work related to implementing education · Executing work related to insurance and safety management · Executing work related to welfare, occupational health and safety, health management, etc. · Executing work related to building entry control (creation of entry/exit cards, acquisition of entry/exit logs, etc.) · Work, etc. related to or peripheral to the work outlined above In cases where personal information will be utilized for purposes other than those outlined above, the utilization purpose will be indicated to executives and employees as necessary |
| Personal information related to individuals who make inquiries to the Company | · Communicating by email, telephone, etc. regarding the inquiry · Confirming the identity of the individual making the inquiry |
| Personal information obtained from sei-katsu-sha surveys, etc. conducted by the Company | · Communicating by email, telephone, etc. regarding the relevant survey · Communicating by email, telephone, etc. regarding further survey requests, etc. · Analysis and disclosure at seminars, etc. of the Company of data that has been statistically processed and digitalized so as to be non-personally referable |
3-2．Personal information handled by the Company on commission from business partners
| Type of personal information acquired | Utilization purpose |
|---|---|
| Personal information acquired, utilized, disposed of, etc., by the Company on commission from a business partner | Utilization necessary to execute all kinds of work on commission (giveaway campaign work, event work, survey and analysis work, etc.) |
4．Provision to third parties
The Company will not provide personal information to a third party without obtaining the consent of the individuals concerned in advance, except in the following cases that meet legal requirements and descriptions:
· cases based on laws and regulations
· cases in which there is a need to protect a human life, body or fortune, and when it is difficult to obtain the consent of the individuals concerned
· cases in which there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain the consent of the individuals concerned
· cases in which there is a need to cooperate in regard to a central government organization or a local government, or an individual entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a principal’s consent would interfere with the performance of the said affairs
· cases in which the individual concerned has explicitly requested Us to disclose or provide the personal information to a third party
· cases in which a court of law, Public Prosecutor’s Office, police, or other organization invested with similar authority has requested Us to disclose personal information in accordance with appropriate procedures
· cases in which personal information is provided accompanied with business succession caused by a merger or other reason, and the information will be handled within the scope of the pre-succession utilization purpose
· cases in which personal information is provided or disclosed to a business partner within the scope necessary for achieving the utilization purpose
In cases where personal information is provided to a third party for reasons other than those outlined above, We will inform the individuals concerned of the information to be provided and the purpose of the provision, etc., and will provide such information to the third party only with consent.
5．Joint utilization
The Company will jointly utilize personal information within the scope outlined below. Moreover, when jointly utilizing personal information of a type other than those outlined below, We will utilize it only after informing of or disclosing to the public such joint utilization in advance.
| Case of joint utilization | Information to be jointly utilized | Entity that will jointly utilize it | Utilization purpose | Personal information administrator |
|---|---|---|---|---|
| Cases in which joint utilization with Hakuhodo DY Holdings Group companies is necessary to respond appropriately to an inquiry to the Company | Names, addresses, telephone numbers, email addresses, places of work, inquiry content | Hakuhodo DY Holdings Group companies https://www.hakuhodody-holdings.co.jp/english/group/about/group.html Includes Hakuhodo DY Holdings Group companies not shown on the linked website |
Communicating with the relevant individual, sending materials, etc. and other necessary procedures related to the inquiry content | Masayuki Mizushima, President & CEO, Hakuhodo Inc. Akasaka Biz Tower, 5-3-1 Akasaka, Minato-ku, Tokyo 107-6322 |
| Cases when conveying information from Hakuhodo DY Holdings Group companies | Personal information about participants in seminars, lectures and other events organized by the Company; subscribers to the Company’s email newsletters; personal information for supporting companies the Company receives a third party provision of in relation to events, etc. to which the Company is providing support (company names, division names, job titles, names, email addresses, telephone numbers, addresses) | Hakuhodo DY Holdings Group companies https://www.hakuhodody-holdings.co.jp/english/group/about/group.html Includes Hakuhodo DY Holdings Group companies not shown on the linked website |
· Providing information about the Company’s services, events, seminars, campaigns, questionnaires, etc. by email newsletter, etc. · Analysis work for improving the content of email newsletters, etc. |
Masayuki Mizushima, President & CEO, Hakuhodo Inc. Akasaka Biz Tower, 5-3-1 Akasaka, Minato-ku, Tokyo 107-6322 |
6．Handling of personal information related to minors
The Company will not acquire or utilize personal information of minors without the consent of a guardian. If by any chance you discover a minor has provided personal information to Us without the consent of a guardian, you are requested to contact Us immediately.
7．Security control actions
The Company takes the following actions for the security control of personal information entrusted to Us.
· Clarification of information handling
We have set out regulations for the secure and appropriate handling of personal information, including access, usage, storage, disposal and return of personal information, and adhere to these regulations under the supervision of an administrator.
Moreover, acquired personal information will be erased or disposed of appropriately once the legal period for its storage or the period necessary for executing work has passed.
· Confirmation of appropriateness of personal information entrusted to Us by business partners and the appropriate utilization and security control thereof
In regard to personal information entrusted to Us by business partners in the course of executing Our business, We will confirm the method of acquisition and the scope of consented utilization of such personal information and utilize it appropriately in line with the relevant business partner’s requests and Our internal regulations.
· Executive and employee education
Education and awareness activities for executives and employees to instill understanding of the importance of personal information protection, legal requirements, control systems, handling regulations and measures in case of violation of these regulations are implemented regularly (including annual implementation of e-learning on information security, including personal information for all executives and employees) to promote the appropriate handling of personal information and compliance with relevant regulations and rules.
· Establishment of information handling control systems
To protect personal information, We have clarified internal control and responsibility systems and selected an administrator responsible for personal information.
· Measures for unauthorized access
To prevent theft, loss, falsification or destruction of personal information due to unauthorized access, We have established information systems and information control systems, restrict access to information systems and areas where personal information is handled, and appropriately build mechanisms to protect against unauthorized external access and against unauthorized software.
· Ensuring information security in cases where information processing is outsourced
In cases where the processing of personal information is outsourced to an external party, We will, in accordance with Our internal regulations, select outsourcing partners that have been confirmed will ensure the security control of information, and exercise appropriate supervision.
· Establishment of immediate response systems for when a problem occurs
If by any chance a problem should occur, We will assess the situation promptly and accurately and establish an organization to make appropriate decisions and take appropriate action.
· Continuous improvement
We make ongoing efforts to improve through internal auditing of information security by the Auditing Division and otherwise monitoring the control status, and by responding to changes in the external environment.
· Assessment of the external environment
When storing, transferring, etc. personal information entrusted to Us in or to another country, We will comply with relevant laws and regulations regarding personal information and undertake security control after understanding systems regarding the protection of personal information in the relevant country.
8．Disclosure, correction, deletion, etc. of personal information
In such case as you desire any of the following related to personal information the Company has acquired from you, please inquire using the inquiry form linked in 9. Contact point for inquiries.
· Requesting disclosure, correction, addition, deletion or suspension of utilization; requesting cessation of utilization of personal information or cessation of provision to a third party due to withdrawal of consent
· Making a complaint, etc., regarding handling of personal information
Note that the Company may not fulfill a requested action for reasons set out in the Act on the Protection of Personal Information. In such cases, We will provide notice that the requested action will not be undertaken, and the reason(s) therefor.
9．Contact point for inquiries
For inquiries related to this Privacy Policy, please utilize the linked inquiry form.
10．Personal information handling company
Hakuhodo Inc.
Akasaka Biz Tower, 5-3-1 Akasaka, Minato-ku, Tokyo 107-6322
President & CEO: Masayuki Mizushima
11. Revision of this Privacy Policy
The Company may amend the content of this Privacy Policy.
Details will be published on Our website when such amendments are made.
Instituted on September 29, 2004
Revised on April 1, 2022