Personal Information Protection Policy

1 Company name, address, and representatives

Suncall Corporation
14, Umezunishiura-cho, Ukyo-ku, Kyoto
Tadao Otani, Representative Director
Tadashi Nara, Representative Director

2 Compliance with related laws and regulations, guidelines, etc.

The Company will handle personal data properly in compliance with laws and regulations including the Personal Information Protection Act as well as the guidelines including those of the Personal Information Protection Committee.

3 Acquisition and use of personal information

The Company will publish or give notice of the purposes of use (including publishing in accordance with this Policy) when acquiring personal information, and when acquiring personal information stated in an agreement or other document (including electromagnetic records) directly from the individual in question, the Company will expressly indicate the purposes of use in advance and acquire it by legitimate and fair means.

The Company will use personal information properly within the scope necessary for achieving the purposes of use.

4 Purposes of use of personal information

The Company will use personal information for the following purposes:

(1) Personal information of users of this website

[Purposes of use]
- To receive opinions and feedback;
- To respond to inquiries and requests for materials;
- To conduct market research and develop new products and services;
- To give notice of events, seminars, and campaigns;
- To offer an email delivery service or send publications, etc.;
- To provide information on products and services handled by the Company or its partners;
- To perform confirmation work in accounting audits;
- To analyze acquired information including browsing histories and provide information on new products and services;
- To identify and authenticate users;
- To send products and invoices;
- To respond to, confirm, and record inquiries, consultations, complaints, repairs, and provide support;
- To develop products and improve and enhance services;
- To improve and enhance user experience in digital services provided by the Company (e.g. websites and mobile applications);
- To advertise and provide information on products, services, campaigns, etc. by invitation letter, email, or similar means (*1, *2);
- To deliver behavioral targeting advertisements using advertisement delivery service providers including Google (*3, *4);
- To analyze the attribute information, behavior histories, etc. acquired by the Company to understand users' interests, preferences, etc. (*2); and
- To safely provide the Company's products and services. The above includes discovery of and notification to users violating the Terms of Use, and investigation, detection, and prevention of fraud, unauthorized access, or other dishonest acts by misusing services, etc., as well as response to the above.
- To deal with the need to contact you for some other reason
(2) Personal information on the Company’s trading partners (or in the case of a corporation, its officers and employees)

[Purposes of use]
- To make necessary business contacts, execute contracts, conduct business negotiations, etc.; and
- To manage trading partner information
(3) Personal information on the Company’s shareholders (or in the case of a corporation, its officers and employees)

[Purposes of use]
- To exercise rights and perform obligations under the Companies Act; and
- To manage shareholders, including preparation of records under various laws and regulations
(4) Personal information on job applicants collected in the recruitment and employment processes

[Purposes of use]
- For communication with and information provision to job applicants in the recruitment and employment processes, and other uses necessary for the recruitment and employment processes
(5) Personal information on the Company’s employees

[Purposes of use]
- For business communications to the Company’s employees;
- For payment of compensation (wage, bonus, allowances, etc.) to the Company’s employees, performance of personnel and labor management, and provision of benefits; and
- For healthcare of the Company’s employees

5 Joint use of personal information

The Company will jointly use the personal information of users of this website as follows:

(1) Items of personal information

Your address, name, zip code, telephone number, fax number, e-mail address, product purchase history, etc.
(2) Scope of joint users

The Company may use your personal information jointly with its subsidiaries, affiliates, etc. within the scope of the purposes of use listed in 4 above. In such case, the Company ensures the prevention of leaks by joint users by executing confidentiality agreements or other methods.

For subsidiaries and affiliates, please see the Offices page.
(3) Purposes of use

The Company will jointly use such personal information within the scope of the purposes of use listed in 4-(1) “Personal information on users of this website” above.
(4) Name, address, and representative of the company responsible for the management of personal data

The Company will be responsible for the personal data used jointly. For the address and the representatives of the Company, please see 1 above.

For inquiries about joint use, please contact the following:

[Personal Information Protection Consultation Service]　

General Affairs Department

[Contact]

Personal Information Protection Consultation Service (General Affairs Section Manager),
General Affairs Department, Suncall Corporation
14, Umezunishiura-cho, Ukyo-ku, Kyoto 615-8555 Japan
Tel.: +81(75)881-8111
Hours for acceptance of inquiries: 9:00 a.m. to 11:00 a.m. and 1:30 p.m. to 4:00 p.m.
Monday to Friday (excluding national holidays and year-end and New Year holidays)

6 Third-party provision of personal information

The Company will not provide your personal information it received to a third party except in the following cases:

(i)If your prior consent is obtained
(ii)If the Company entrusts the handling of the personal information to an outside contractor within the scope necessary for achieving the purposes of use
(iii)If the Company is requested to provide the personal information based on laws and regulations
(iv)If such provision is necessary for the protection of the life, body, or property of a person and it is difficult to obtain your consent
(v)If such provision is particularly necessary for the improvement in public health or the promotion of sound development of children, and it is difficult to obtain your consent
(vi)If it is necessary to cooperate with a national or local government in the execution of the clerical duties prescribed by laws and regulations, and obtaining your consent may affect the execution of the relevant duties
(vii)If the information is provided to a person within the scope of the joint users listed in 5 above

7 Matters regarding security control measures

The Company will undertake security control measures necessary and appropriate for the management of personal data, including leak, loss, and damage prevention measures. It will additionally exercise necessary and appropriate supervision over its employees and contractors (including subcontractors). The detailed security control measures for personal data are specified separately in the Personal Information Management Regulations, whose main contents are as follows:

(Establishment of Personal Information Protection Policy)
- To ensure the appropriate handling of personal data, the Company has established these Personal Information Protection Guidelines regarding compliance with relevant laws, regulations, and guidelines as well as the contact points for inquiries and complaint handling.
(Establishment of regulations regarding handling of personal data)
- The Company has established the Personal Information Management Regulations for the handling methods, the managers and persons in charge, and their duties, etc. for the respective stages of acquisition, use, storage, provision, and deletion or disposal.
(Organizational security control measures)
- The Company has appointed a personal data handling administrator, defined the employees who handle personal data and the scope of the personal data handled by such employees, and developed a system to report to the administrator of any fact or sign of a violation of the Personal Information Protection Act and the Personal Information Management Regulations.
- The Company implements regular self-inspections and audits of the handling of personal data by other departments or outside persons.
(Human security control measures)
- The Company implements regular training for employees on specific points of note regarding the handling of personal data.
- The Company provides matters regarding the confidentiality of personal data in the Work Rules.
(Physical security control measures)
- The Company undertakes measures for areas where personal data is handled, including access control of employees, restrictions on devices brought in, and prevention of unauthorized access to personal data.
- The Company also undertakes measures to prevent theft and loss of devices, electronic media, documents, etc. used in handling personal data, as well as measures to prevent specific individuals subject to personal data from being easily identified while such devices, electronic media, etc. are carried about, including within the office.
(Technical security control measures)
- The Company exercises access control to limit the scope of the persons in charge and the personal information database, etc. to be handled.
- The Company introduces systems for protecting the information systems used in handling personal data against unauthorized access from the outside or illegal software.
(Entrustment of handling of personal information outside Japan)
- If the Company provides personal data to a third party outside Japan, the prior consent of the individual in question to the provision to a third party in the relevant foreign country must be obtained, except in special cases.

8 Contractor entrusted with handling of personal information outside Japan

The Company does not entrust the handling of personal information to any contractor outside Japan.

9 Request for disclosure, etc. of personal information

If requested for a referral, correction, suspension of use, or deletion of personal information, the Company will respond promptly upon confirming that it is from the individual in question in accordance with the prescribed procedure. If you have any questions regarding these Personal Information Protection Guidelines or wish to exercise your rights, please contact us using the contact information listed in 10 below:

10 Contact for inquiries

For inquiries and complaints about the handling of personal data by the Company, please contact the following:

(i)Address
Personal Information Protection Consultation Service (General Affairs Section Manager),
General Affairs Department, Suncall Corporation
14, Umezunishiura-cho, Ukyo-ku, Kyoto 615-8555 Japan
(ii)Telephone number
+81(75)881-8111
(iii)Hours for acceptance of inquiries
9:00 a.m. to 11:00 a.m. and 1:30 p.m. to 4:00 p.m.
Monday to Friday (excluding national holidays and year-end and New Year holidays)