privacy policy

• Our company and our group companies will acquire and use personal information appropriately, but only to the extent necessary for the business and related operations conducted by our company and our group companies. Furthermore, we will not use personal information beyond the scope of the purposes of use disclosed in advance through our public announcements.
• Except as required by law, we will not provide or disclose personal information to third parties without the consent of the individual concerned.
• Our company complies with laws and regulations concerning the handling of personal information, as well as national guidelines andOtherWe will abide by the rules.
• Our company will take reasonable security measures and corrective actions to prevent risks such as unauthorized access to personal information, loss, leakage, alteration, or damage to personal information.
• Our company will promptly respond to requests from individuals regarding confirmation, disclosure, correction, deletion, suspension of use, or complaints concerning their personal information, through the contact point listed below.
• To protect personal information, our company has established a personal information protection management system and strives for its continuous improvement on a daily basis.
• Our company has established internal regulations regarding the proper acquisition, management, and provision of personal information, and we strive to build an internal system for the appropriate management and protection of personal information, as well as to provide training to our employees.

Regarding the use of personal information

To ensure the protection of personal information, our company has established and published the following "Policy on the Use of Personal Information" (hereinafter referred to as "this Policy"). Unless otherwise specified, the terms used in this Policy shall conform to the definitions of the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act").

1. [1] Purpose of use of personal information

   Our company will only disclose personal information if we have obtained prior consent from the individual concerned and in accordance with the Personal Information Protection Act.OtherExcept where permitted by law, we will use personal information only within the scope of the following purposes. Furthermore, we will use personal information we hold, such as website browsing history, behavioral history, service usage history, and survey responses, to analyze features and services that we believe may be of interest to our customers, and use the results for advertising distribution and business development.OtherWe may use your information within the scope of the purposes of use described below (including cases where we use information such as browsing history obtained from third parties such as group companies and partner businesses other than our company after cross-referencing it with personal information we hold).

   • For the purpose of managing the business operations of our group companies (sending necessary documents, contacting necessary parties, registering and managing business operations, etc.)
   • To solicit your opinions regarding the business of our company or our group companies.
   • For the purpose of responding to inquiries to our company or our group companies and ensuring smooth handling of such inquiries.
   • In order to manage contracts, exercise rights, or protect legitimate interests of our company or our group companies.
   • For the improvement of operations of our company or our group companies
   • To gather various opinions from our customers
   • Providing information and contacting job applicants for our company and our group companies,OtherFor use in selection activities.
   • Our company and our group companies' employee assignments, personnel transfers, compensation determination, career development and training, performance evaluations, attendance management, payroll calculation, tax and social insurance administration, and safety confirmation.OtherHuman resources and labor management,OtherFor the purpose of administrative management, human resource strategy planning, formulation, and implementation related to the duties performed during employment.
   • The company will contact former employees of our company and our group companies as needed for business-related matters, social gatherings, etc., and will also keep track of their internal career history, work performance, employment status, safety management status, etc. during their employment.OtherFor managing and contacting former employees
   • For the preparation, operation, and response of measures based on the BCP formulated by our company and our group companies.
   • For the exercise of rights or fulfillment of obligations of our company and shareholders as required by law.
   • For the management of shareholders of our company or our group companies
   • To the extent necessary to achieve each of the above-mentioned purposes of use, we outsource a portion of our operations (outsourcing services necessary or beneficial for the performance of our business).

   Furthermore, when we obtain personal information directly in writing in connection with the conclusion of a contract, we will clearly state the purpose of use to the individual concerned.

   Furthermore, our company collects cookies, access logs, IP addresses, device/OS/browser information, authentication information such as IDs, advertising identifiers, browsing history, and telephone numbers.OtherWe may acquire and handle information that, on its own, cannot identify a specific individual, either directly or from our group companies or partner businesses. We may use this information (including cases where, when combined with other information, it becomes information that can identify a specific individual, either within our company or at advertisers/media companies to which we report) for the purpose of providing advertising distribution services, delivering optimal advertisements, measuring and verifying advertising effectiveness, notifying customers regarding advertisement placement, improving services and convenience, business development, analyzing, editing and processing statistical information, and reporting to advertisers/media companies.

2. [2] Regarding the acquisition of personal information

   Our company will acquire personal information through appropriate and lawful means, to the extent necessary to achieve the purposes of use specified in [1].

   However, with regard to sensitive personal information (as defined in the Act on the Protection of Personal Information), we will handle it in accordance with the regulations of the Act on the Protection of Personal Information.

3. [3] Provision of personal data to third parties

   We manage the personal data we acquire appropriately and will not provide it to third parties without the prior consent of the individual concerned. However, this does not apply in the following cases:

   • In cases based on laws and regulations
   • When it is necessary to protect a person's life, body, or property, and it is difficult to obtain the person's consent.
   • When it is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children, and it is difficult to obtain the person's consent.
   • When it is necessary to cooperate with a national or local government agency or an entity entrusted by them in carrying out duties prescribed by law, and obtaining the person's consent would likely hinder the performance of those duties.
   • When the third party is an academic research institution or similar entity, and it is necessary for the third party to handle the personal data for academic research purposes (including cases where part of the purpose of handling the personal data is for academic research purposes, excluding cases where there is a risk of unduly infringing on the rights and interests of individuals).
   • When it is stipulated by law
   • When personal data is provided in connection with entrusting all or part of the handling of personal data to a third party, to the extent necessary to achieve the purpose of use.
   • When our company handles cookies, access logs, IP addresses, device/OS/browser information, authentication information such as IDs, telephone numbers, advertising delivery identifiers, behavioral history, etc., we use this information for reporting advertising effectiveness and verification results, and for calculating fees, etc.OtherWhen providing personal data to advertising media companies when necessary for advertising business.
   • When personal data to be jointly used with a specific party is provided to that specific party, and the fact of joint use, the categories of personal data to be jointly used, the scope of the parties jointly using the data, the purpose of use by those parties, and the name or title of the person responsible for managing the personal data are notified to the individual in advance, or the information is made easily accessible to the individual.

   However, when providing personal data to a third party located in a foreign country, we will do so in accordance with the provisions of the Personal Information Protection Act.

4. [4] Outsourcing of personal data

   Our company will outsource a portion of its operations to external parties (consulting contracts we have been awarded) to the extent necessary to achieve the purposes of use specified in [1].OtherWe may provide personal data to third parties in connection with outsourcing some of our operations, outsourcing services necessary or beneficial for the performance of said operations, outsourcing to advertising production companies, outsourcing database construction, etc.

   When entrusting personal data to a third party, we carefully screen them to ensure they have a sufficient system in place for protecting personal information. We then comply with laws and regulations, provide necessary and appropriate supervision through contracts and other means, and strive to prevent accidents.

5. [5] Regarding ad delivery provided by ad delivery companies

   As stated in "[1] Purpose of Use of Personal Information," in order to display more appropriate advertisements to our customers, we may use services provided by advertising distributors, such as converting some of the personal information we hold into data that does not identify the individual, and displaying advertisements and content related to our services customized for each customer. For details on how each advertising distributor collects and processes data, and for opt-out procedures, please refer to the information below.

   • Google: "About Customer Match"
     Links regarding opt-out and ad delivery cancellation procedures.
   • Facebook: "About Custom Audiences"
     Links regarding opt-out and ad delivery cancellation procedures.
   • Yahoo! JAPAN "Use of Personal Data in Yahoo! Marketing Solutions"
     Links regarding opt-out and ad delivery cancellation procedures.
   • LINE "LINE Yahoo Privacy Policy 4.d. Specific Examples of Optimizing Our Services for Our Customers"
     Links regarding opt-out and ad delivery cancellation procedures.
   • Microsoft: "What is an audience campaign?"
     Links regarding opt-out and ad delivery cancellation procedures.
   • X: "What is a custom audience?"
     Links regarding opt-out and ad delivery cancellation procedures.

6. [6] Regarding the joint use of personal data

   Our group, while maintaining management consulting as our core business, is expanding its business domain to include related services in order to sincerely respond to the diverse needs of our clients, thereby providing higher quality management consulting services.

   Therefore, in order to streamline processing operations in collaboration with each company in our group, improve operational efficiency, and also for credit assessment and post-credit management,OtherFor risk management purposes, we may share personal data of our customers, business partners, employees, and job applicants within our group to the extent necessary.

   However, notwithstanding the provisions of this section, when providing personal information to a third party located in a foreign country, we will handle it in accordance with the provisions of Article 28 of the Personal Information Protection Act.

   1. Items to be shared
      1. (1) The following attribute information relating to customers or business partners and information for managing that information Name, company name, performance, trade name, address, company location, job title, telephone number, fax number, website address, industry, email address, code indicating contact information in chat services, etc., transaction history
      2. (2) Information of employees of our company and group companies
         Name, date of joining the company, date of birth, gender, educational background, work history, emergency contact information, family information, nationality, address, department, title/position, mobile phone number, email address, code indicating contact information in chat services, etc., facial photograph, group history.
      3. (3) Information of job applicants
         Name, address, date of birth, gender, educational background, work history, telephone number, email address, contact code for chat services, etc., facial photograph, statement of purpose, results of aptitude tests, information listed on resume, place of return home, emergency contact information, nationality
   2. Companies that share the service

      The following is listed on our website:Group CompaniesThe companies listed in ""

   3. Purpose of use
      1. (1) The following attribute information relating to customers or business partners and information for managing that information
         • For market research and data analysis aimed at the research and development of new products and services.
         • For sending direct mail and other information regarding products and services.
         • Regarding the products and services offered by each company in our group, we receive inquiries and applications from customers.OtherIn order to inform and transfer the matter to the responsible company if a request is made.
         • OtherIn order to properly and smoothly carry out transactions with our customers
      2. (2) Information of employees of our company and group companies
         • For business communication
         • For personnel management and assignment (including secondment and transfer).
         • For analysis, talent assessment, and task assignment in order to formulate HR strategies.
         • To ensure a proper working environment and improve labor efficiency
         • For the preparation, implementation, and response of measures based on BCP
      3. (3) Information of job applicants

         For the purpose of reviewing and deciding on hiring decisions within our group, reviewing and deciding on hiring conditions, responding to inquiries, administrative communications, considering assignments after joining the company, and reviewing, formulating, and implementing our group's recruitment and human resources strategies.

      4. (4) Person responsible for managing shared use

         2-2-1 Yaesu, Chuo-ku, Tokyo Tokyo Midtown Yaesu, 35th Floor
         Funai Soken Holdings Inc.
         Representative DirectorTakayuki Nakatani

      5. (5) Acquisition method

         Written documents (business cards, work documents, questionnaire responses, etc.), electronic data (emails, input forms on our related websites, etc.), audio (phone calls, verbal communication, meetings, etc.)

7. [7] Security measures for retained personal data

   Our company takes the following necessary and appropriate security measures to manage personal data, including preventing leakage, loss, or damage. We also provide necessary and appropriate supervision to our employees who handle personal data.

   1. [1] Development of internal company regulations
      • We have established internal regulations regarding handling methods and the responsibilities of responsible persons and staff at each stage, including acquisition, use, storage, provision, deletion, and disposal.
   2. [2] Organizational safety management measures
      • We will appoint a person responsible for handling personal data, clarify the employees who handle personal data and the scope of personal data they handle, and comply with the Personal Information Protection Act.OtherWe have established a reporting and communication system in place to handle any instances or indications of violations of laws and internal regulations.
      • We conduct regular self-inspections and internal audits regarding the handling of personal data.
   3. [3] Personnel safety management measures
      • We conduct regular training for our employees and have provisions regarding confidentiality in our employment regulations.
   4. [4] Physical safety control measures
      • We manage employee access to the premises and restrict the devices they can use, and we have implemented measures to prevent unauthorized access to personal data. Furthermore, when such devices and electronic media are taken outside the company, we take measures such as password protection to prevent theft or loss of devices, electronic media, and documents handling personal data.
   5. [5] Technical safety control measures
      • In accordance with the categories described in [2] above, the scope of handling of personal data through access control is limited.
      • We have implemented security measures to prevent unauthorized access from external sources.
   6. [6] Understanding the external environment
      • When handling personal data in a foreign country, we will understand the laws and regulations concerning personal information in that country and implement necessary security measures.

8. [8] Security measures for anonymized information

   When using anonymized data databases and other related services for business purposes, our company will take the following measures to ensure the secure management of anonymized data.

   1. [1] Restriction of the number of handlers

      Access to anonymized data databases and similar systems is limited to employees directly involved in the relevant business, and is strictly managed and supervised by the head of the relevant business unit.

   2. [2] Understanding the handling status

      We will monitor how anonymized information is handled and periodically evaluate and review the implementation status of security management measures.

   3. [3] Prevention of unauthorized access

      We have implemented appropriate security measures to prevent unauthorized external access to our anonymized data database and other related resources.

9. [9] About cookies

   1. [1] We may send, store, and refer to cookies on the computers of people (hereinafter referred to as "users") who access our website.

      *In order to understand the visit patterns of visitors to our website (hereinafter referred to as "users"), we use Google Analytics. We use cookies issued by our company. Based on these cookies, Google collects, records, and analyzes users' visit history to our website, and we receive the results of that analysis from Google. The user information collected, recorded, and analyzed by Analytics does not include any information that identifies specific individuals. Please note that this information will be managed by Google in accordance with their privacy policy. For an explanation of the Google Analytics Terms of Service, please see below.Google Analytics siteRegarding the explanation of Google's privacy policy: The company's websitePlease see below.

   2. [2] In addition, third parties that display advertisements or provide access analysis services may send, store, and refer to cookies on the computers of people who access our website.

   In this case, the use of cookies by the third party is subject to the third party's own privacy policy and cookie policy.OtherIt will be carried out in accordance with the regulations.

10. [10] Disclosure, correction, suspension of use, etc. of personal data held

    In accordance with the law, we will respond to requests for disclosure, etc., made by the individual concerned or their representative, in accordance with the following procedures.

    1. [1] Contact information for making a request
       [12] Contact information listed below
    2. [2] Documents to be submitted when making a request, contact information, etc.
       To request disclosure, correction, or suspension of use of personal information held by our company (hereinafter collectively referred to as "requests for disclosure, etc."), you will be required to submit an "Application Form for Disclosure, Correction, or Suspension of Use of Personal Information Held by Our Company."
       The "Application Form for Disclosure, Correction, or Suspension of Use of Personal Information Held" will be sent to you when you contact our reception desk.
    3. [3] Documents for verifying the identity of the individual or their representative.
       When making a request for disclosure, etc., you will be required to submit documents to verify that the person making the request is the individual concerned or their representative.

       [Identity Verification Documents] One of the following documents

       • - Copy of driver's license
       • - Copy of passport
       • - Copies of various health insurance cards
       • - A copy of your My Number Card (Please only provide a copy of the front side; do not provide the side showing your My Number.)
       • - Copy of alien registration certificate
       • - Copy of disability certificate
       • - Certificate of seal registration (issued within the last 3 months; the seal must be stamped in the margin).

       [Documents to verify the agent's identity]

       The following two documents: "Documents proving the power of attorney" and "Documents verifying the identity of the agent"

       • Documents proving the power of attorney
         If you are a legal representative, a copy of the official document proving your legal representation authority. If you are an authorized representative, the original power of attorney in the principal's name (issued within the last three months).
       • • Identification documents for the representative
         Any of the above [identity verification documents] relating to the agent
    4. [4] Fees for requests for disclosure of retained personal data
       For requests to be notified of or to disclose the purpose of use of personal data held by us that identifies you, a fee of 500 yen (including consumption tax) will be charged for each request.
       When mailing the "Application Form for Disclosure, Correction, or Suspension of Use of Personal Information Held" and "Identity Verification Documents" (including agent verification documents if necessary), please enclose 500 yen worth of postage stamps.
       *For the disclosure of retained personal data or records provided to third parties that require special disclosure methods, a separate fee may be charged.
       *If the fee is insufficient or not included, we will contact you accordingly. If the outstanding amount is not paid within two weeks of receiving the application form mentioned in [2] above, we will treat the request as if it had not been made.
       *Please note that we cannot return any postage stamps you send us, regardless of the reason for non-disclosure or other reasons.

11. [11] Revisions to these regulations and their application

    Our company will update these regulations in accordance with legal revisions and changes in our group's policies.OtherFor the reasons stated above, changes may be made without prior notice via the methods posted on our website.

    If we separately define the purpose of use of personal information, provision to third parties, contact information, etc., for the services we provide, and if there are provisions that differ from these regulations, the provisions regarding the handling of personal information individually defined for each service shall take precedence.

12. [12] Contact information, etc.

    [Inquiries regarding the handling of personal information]

    Funai Soken Holdings Inc.Legal Department
    Email:hd_houmu@funaisoken.co.jp

    We regret to inform you that we cannot accept requests made in person at our office.