Hakuhodo DY ONE, Inc. (hereinafter, the Company) has formulated the Personal Information Protection Policy (hereinafter, the Privacy Policy) as its basic policy to protect personal information and hereby declares that it shall properly handle personal information acquired by us or entrusted to us by our business partners in strict compliance with laws, national guidelines, industry standards, internal rules and other relevant guidelines.

1．Scope of application

This Privacy Policy applies to personal information handled by the Company.

2．Acquisition and use of personal information

When acquiring personal information, the Company shall, in principle, clearly specify in advance the purpose of use to the individuals who provide the Company with their personal information and use legal and fair means to acquire such information. In addition, the Company shall use personal information only within the scope necessary to achieve the said purpose of use. If there are any changes to the purpose of use, the Company shall notify and publicly announce these changes or obtain consent from the individuals who provide the Company with their personal information.

3．Types of acquired personal information and purpose of use

The types of acquired personal information and their purpose of use are as follows:

3－1．Types of personal information acquired by the Company

Types of personal information	Purpose of use
Personal information of individuals who have participated in seminars, lectures or other events organized by the Company (including individuals who signed up)	・To invite participants to an event, share information after the event or respond to inquiries via email, telephone or other ・To provide information about the Company or Group Company’s services, events, seminars, campaigns, surveys or other information, to provide notifications, set up appointments, make proposals or respond to inquiries via email (including newsletters), telephone or other ・To conduct analytical work to improve events, newsletter content or other ・To provide content, deliver ads or other based on analytical results of browsing history and other information obtained separately (see below)
Personal information of individuals who have participated in Company-sponsored events or other, which is provided by the organizers of the said events to sponsoring companies	・To provide information about the Company or Group Company’s services, events, seminars, campaigns, surveys or other information, to provide notifications, set up appointments, make proposals or respond to inquiries via email (including newsletters), telephone or other ・To conduct analytical work to improve the selection process of sponsored events, newsletter content or other ・To provide content, deliver ads or other based on analytical results of browsing history and other information obtained separately (see below)
Personal information of individuals who have signed up for our newsletters or who have made inquiries	・To provide information about the Company or Group Company’s services, events, seminars, campaigns, surveys or other information, to provide notifications, set up appointments, make proposals or respond to inquiries via email (including newsletters), telephone or other ・To conduct analytical work to improve newsletter content or other ・To provide content, deliver ads or other based on analytical results of browsing history and other information obtained separately (see below)
Personal information (including browsing history and other behavioral information) of individuals who have registered as members, have used (browsed) or have downloaded materials from websites or services operated by the Company	・To confirm the identity of members, users or others who have downloaded materials ・To improve the operation of websites or services ・To provide notifications of new events, contact or respond to inquiries via email, telephone or other ・To provide information about the Company or Group Company’s services, events, seminars, campaigns, surveys or other information, to provide notifications, set up appointments, make proposals or respond to inquiries via email (including newsletters), telephone or other ・To conduct analytical work to improve or newly develop website content or services ・To grasp individual interests and hobbies based on analytical results of browsing history and other information from websites operated by the Company in order to provide content, deliver ads or other
Personal information obtained from the exchange of business cards or other	・To provide information about the Company or Group Company’s services, events, seminars, campaigns, surveys or other information, to provide notifications, set up appointments, make proposals or respond to inquiries via email (including newsletters), telephone or other ・To conduct analytical work to improve or newly develop website content or services ・To provide content, deliver ads or other based on analytical results of browsing history and other information obtained separately (see below)
Personal information of individuals who have visited the Company	・To facilitate the work of reception staff or the person in charge ・For security measures (use of surveillance cameras, etc.)
Personal information of business partners (including companies and individuals who are considering doing business with the Company)	・To enter into contracts, register suppliers, process payments or invoices or handle other communications and inquiries related to business transactions ・To consult, confirm transaction details or other by email, telephone or other ・To send novelty items, prizes or other ・To send seasonal greetings or other ・To provide information about the Company or Group Company’s services, events, seminars, campaigns, surveys or other information, to provide notifications, set up appointments, make proposals or respond to inquiries via email (including newsletters), telephone or other ・To provide content, deliver ads or other based on analytical results of browsing history and other information obtained separately (see below)
Personal information of individuals who wish to join the Company or who have expressed a desire to receive information about the Company’s recruitment activities	・To provide necessary information about recruitment activities, selection processes, employment, future recruitment activities or other ・To facilitate smooth and appropriate management after Company entry
Personal information of individuals who have made inquiries to the Company	・To respond to the inquiry via email, telephone or other ・To confirm the identity of the individual making the inquiry
Personal information of individuals who have responded to the Company’s surveys or other	・To contact via email, telephone or other about the survey ・To contact via email, telephone or other about new surveys ・To analyze data through statistical processing in a manner that does not identify the individual, and to publish and provide such data at Company seminars or other
Personal information of former shareholders and heirs of former shareholders	・To respond to inquiries related to shares ・To handle administrative matters related to shares

3－2．Personal information handled by the Company on behalf of our business partners

Types of personal information	Purpose of use
Personal information acquired, utilized, disposed of or other on behalf of our business partners	・To execute various tasks (handle ad deliveries, prize campaigns, events, surveys, analyses, etc.) entrusted to the Company by our business partners

4．Restrictions on provision to third parties

The Company does not, in principle, disclose or provide personal information we acquire to third parties, except in the following cases.

• When required by law
• When necessary for the protection of a person’s life, body or property and when it is difficult to obtain consent of the individual concerned
• When necessary for the improvement of public health or to promote the healthy development of a child/children and when it is difficult to obtain consent of the individual concerned
• When necessary to cooperate with a national or local government organization, or a business operator entrusted by such an organization, to execute affairs prescribed by laws and regulations and in which obtaining consent of the individual concerned would likely impede the execution of such affairs
• When the third party is a university or other academic research institution or organization or an individual belonging to such an institution or organization, and that third party requires the relevant personal information for the purpose of academic research
• When the individual in question expressly requests disclosure or provision of his or her personal information to a third party
• When a court, public prosecutor’s office, police department, or other agency with equivalent authority requests disclosure of personal information in accordance with proper procedures
• When personal information is provided in connection with a business succession, such as a merger or other, and is handled within the scope of the purpose of use stated before the succession
• When providing or disclosing information to subcontractors to the extent necessary to implement the purpose of use

In the event that we provide personal information to a third party in the future for reasons other than those listed above, we shall notify the individual concerned of the information to be provided and the purpose for which it will be provided and then provide the information to the third party only after obtaining consent from the individual concerned.

5．Shared use

The Company may share personal information within the scope outlined below. In the event that personal information other than those listed below is to be shared, the Company shall notify or publicly announce to that effect (and obtain consent of the individual when necessary) prior to such use.

【Situations of shared use】

①When shared use with a Hakuhodo DY Holdings Group company is necessary
②When a Hakuhodo DY Holdings Group company provides the information

【Information that may be shared】

Situations of shared use	①When shared use with a Hakuhodo DY Holdings Group company is necessary	②When a Hakuhodo DY Holdings Group company provides the information
Information that will be shared	・Name, address, telephone number, email address, employer, nature of inquiry ・Personal information (name, title, division, company, email address, telephone number, address) of individuals who have participated in seminars, lectures or other events organized by the Company, who have subscribed to the Company newsletter, as well as personal information that third parties provide the Company for our role as a sponsor of an event or other ・Personal information (including browsing history and other behavioral information) of individuals who have registered as members, have used (browsed) or have downloaded materials from websites or services operated by the Company	Personal information (name, title, division, company, email address, telephone number, address) of individuals who have participated in seminars, lectures or other events organized by the Company, who have subscribed to the Company newsletter, as well as personal information that third parties provide the Company for our role as a sponsor of an event or other
Party who will jointly use the information	Hakuhodo DY Holdings Group companies https://www.hakuhodody-holdings.co.jp/english/group/about/group_overview.html	Hakuhodo DY Holdings Group companies https://www.hakuhodody-holdings.co.jp/english/group/about/group_overview.html
Purpose of use	・To respond to inquiries, such as contact the person, send materials or other necessary action ・To provide information about services, events, seminars, campaigns, surveys or other of companies with whom we share information, to provide notifications, set up appointments, make proposals or respond to inquiries via email (including newsletters), telephone or other ・To analyze, survey or research the use of services of companies with whom we share information and to conduct analytical work to improve new products, services, newsletter content or other	・To provide information about services, events, seminars, campaigns, surveys or other of Group companies, to provide notifications, set up appointments, make proposals or respond to inquiries via email (including newsletters), telephone or other ・To analyze, survey or research the use of services and to conduct analytical work to improve new products, services, newsletter content or other
Person in charge of managing personal information	Hiroto Kosaka, President and Representative Director Hakuhodo DY ONE Inc. Ebisu Garden Place Tower 4-20-3 Ebisu, Shibuya-ku Tokyo, Japan 150-6021	Hiroto Kosaka, President and Representative Director Hakuhodo DY ONE Inc. Ebisu Garden Place Tower 4-20-3 Ebisu, Shibuya-ku Tokyo, Japan 150-6021

6．Handling of personal information of minors

We shall not acquire or use the personal information of a minor under 15 years of age without the consent of a parental authority except in cases where the information is handled on a consignment from our business partners (see 3-2 above). In the event that it is discovered that a minor has provided personal information to us without the consent of a parental authority, please contact us immediately.

7．Security measures

The Company shall take the following necessary and appropriate security measures to manage personal data, including the prevention of leakage, loss or damage.

7－1．Formulation of a basic policy

To ensure the proper handling of personal data, the Company has formulated a policy (this Privacy Policy) regarding the strict compliance with the Personal Information Protection Law and other related laws and regulations (including guidelines) and the establishment of a contact point for complaints and other.

7－2．Development of rules for handling personal data

The Company has established rules for the safe and proper handling of personal data, including its access, use, storage, disposal and return, and shall strictly comply with these rules under the supervision of the person in charge of the management of personal data.
Furthermore, acquired personal data will be properly erased or disposed of to comply with laws and regulations or after the storage period required to perform the business operation has elapsed.

7－3．Confirming the appropriateness, appropriate use and security measures of personal information entrusted to us

In regard to personal information that we receive from our business partners in the course of conducting business, the Company shall confirm the method of obtaining this information and the permitted scope of use and appropriately use such information in accordance with the business partner’s request and our own internal rules.

7－4．Organizational security measures

(1) To protect personal data, the Company shall clarify its internal management and responsibility structure and select a person responsible for the management of personal data.
(2)The Company shall clearly establish which employees are authorized to handle personal data and the scope of personal data they are authorized to handle. The Company shall also create an internal reporting and communication system in the event that there is a real or suspected violation of the Personal Information Protection Law or internal regulations. Furthermore, the Company shall set up an organizational structure that enables speedy and accurate awareness as well as appropriate judgment and response in the event of a problem.
(3) The department manager shall supervise the handling of personal data as necessary and appropriate, and audits shall be conducted by other departments and outside parties.
(4)Improvements to various aspects of our operations will be made on an ongoing basis in response to changes in the external environment.

7－5．Human security measures

(1)To promote the proper handling of personal information and compliance with various regulations and rules, the Company shall regularly conduct educational programs (e.g., annual e-learning sessions for all employees on information security, including personal information) to ensure that our officers and employees understand the importance of personal information protection, legal requirements, management systems, handling rules and measures to be taken in the event of a breach.
(2)We shall obtain non-disclosure agreements regarding personal data.

7－6．Physical security measures

(1)In addition to managing the entry and exit of employees and restricting the use of equipment in the office, we shall implement measures to prevent unauthorized persons from accessing personal data.
(2)We shall take measures to prevent the theft, loss or other incidents of equipment, electronic media and documents that handle personal data.

7－7．Technical security measures

To prevent the theft, loss, falsification or destruction of personal data due to unauthorized access, we shall appropriately establish mechanisms to control access to information systems, information management systems and areas where information systems and personal data are handled. We shall also implement measures to protect against unauthorized external access and to safeguard against malicious software.

7－8．Ensuring security when outsourcing information processing

When outsourcing the processing of personal data to external parties, we shall select vendors who have been confirmed to ensure the safe management of information in accordance with the Company’s internal rules. We shall conduct appropriate supervision to ensure compliance.

7－9．Understanding the external environment

When storing, transferring or other personal information entrusted to us to a foreign country, the Company shall comply with relevant laws regarding personal information and implement security measures with an understanding of that country’s personal information protection systems.

(1)Box, Inc./Box

①Country

Headquarters location: California, United States of America

②Personal information protection systems

Survey of systems and other related to the protection of personal information overseas (link to the Personal Information Protection Commission website*Japanese).

③Personal information protection measures being taken by the relevant third party

Box, Inc. has acquired APEC-CBRP and PRP certification.

④Country location of server where personal data is stored: Nevada, United States of America

(2)Google LLC/Google Workspace

①Country

Headquarters location: California, United States of America

②Personal information protection systems

Because the country where the data is stored cannot specified, the personal information protection systems being used cannot be detailed.

③Personal information protection measures being taken by the relevant third party

Google Workspace has been audited by SOC1TM, SOC2TM, and SOC3TM, and has received ISO/IEC 27001, 27017 and 27018 certifications.

④Country location of server where personal data is stored: Unspecified. As a system failure countermeasure, Google Workspace stores data in a decentralized manner in numerous countries around the world.

8．Use of personal information for online advertising

8－1．Personal information acquired by the Company may be used for the purpose of delivering advertising using the Internet. In addition, personal data may be provided to third parties to the extent necessary to achieve the stated purpose.

8－2．Regarding third parties located in foreign countries to whom information is provided

Personal data that is acquired for the above-stated purpose may be stored overseas utilizing cloud services provided by outside third parties or may be provided to overseas business operators. For personal data that is currently stored or will be stored, the company names, service names, countries where the companies are located, personal information protection systems and personal information protection measures being taken by the relevant third parties are as follows.

LiveRamp Japan K. K. / LiveRamp

①Headquarters location
WeWork, KDX Toranomon 1-Chome Building, 11th floor, 1-10-5 Toranomon, Minato-ku, Tokyo
②Personal information protection systems
Survey of systems and other related to the protection of personal information overseas (link to the Personal Information Protection Commission website*Japanese).
③Personal information protection measures being taken by the relevant third party
Measures being taken regarding the handling of personal data are at the same level as those required of business operators handling personal information in Japan.
For details, please refer to the following:https://liveramp.com/data-ethics-and-privacy/
④Country location of server where personal data is stored：United States of America

There may be cases where personal data will be stored or provided to overseas entities or services other than those indicated above. However, these cases are still undecided and the foreign countries to which personal data will be transferred cannot be specified. Additional information will be added to this page when it becomes available.

9．Management of personal information

In accordance with the purpose of use, we strive to ensure that the personal information we own is accurate and up to date. The personal information will be stored for no longer than is necessary and afterwards, will be deleted or discarded in a secure manner.

10．Disclosure, revision or deletion of personal information

If an individual wishes to make any of the following requests regarding personal information obtained from that individual, please contact the person listed in item 12.

・Request for disclosure, correction, addition, deletion, suspension of use, deletion, termination of use of personal information due to withdrawal of consent, termination of provision to third parties, disclosure of records provided to a third party, disclosure of records provided by a third party (a Company-designated fee will be required. In addition, we shall confirm the identity of the individual or proxy authorization in a manner prescribed by the Company).
・ Complaints regarding the handling of personal information, etc.

Please note that there may be cases where we are not able to proceed with such measures due to reasons stipulated by laws regarding the protection of personal information. In such cases, we shall notify the individual of the measures that cannot be taken and the reasons.

11．Handling of leakage and other such incidents

In the event of an incident, such as leakage or loss of personal information, the Company shall notify the relevant individuals without delay and shall publicize the facts and measures to prevent reoccurrence.

12．Contact for inquiries

For inquiries regarding this matter, please contact the following.

13．Business handling personal information

Hiroto Kosaka, President and Representative Director
Hakuhodo DY ONE Inc.
Ebisu Garden Place Tower
4-20-3 Ebisu, Shibuya-ku
Tokyo, Japan 150-6021

14．Revisions to this Privacy Policy

The Company may change the content of this Privacy Policy in response to changes in laws and regulations or as necessary. In the event of any changes, the latest version of this Privacy Policy will be posted on the Company’s website in lieu of notification to users. We kindly ask you to periodically check this Privacy Policy to ensure your understanding of how we handle your personal information.

15．Social plug-ins

Social plug-ins are buttons and other features that social networking services (SNS) provide for placement on website pages.
Example: The “Tweet” button on X (formerly Twitter), the “Share” button on Facebook, etc.

When a user logs in to visit a website that contains SNS buttons, some websites automatically send user ID, accessed site and other information to the SNS even if the user did not press any buttons. For details, please refer to “Points to Note Regarding the Installation of SNS Buttons and Other” (Personal Information Protection Commission of Japan website).

For the privacy policies, etc., of other social media services used on this website, please check their respective websites.

How information is gathered

Websites operated or managed by the Company utilize a variety of tools to collect website browsing information and other data. Acquired data is managed and utilized in accordance with the privacy policies of each of the companies that provide the tools. The following is a list of tools the Company uses, the purpose of use, the websites being used and the privacy policies of the data that is gathered. Users who wish to stop the usage of data should follow the opt-out procedures outlined by each of the tool provider companies. However, please understand that disabling cookies through opt-out or other procedures may affect some of the functions on this site and other services provided.

Acquired information

Please refer to the following for details about the tools we use, the privacy policies of the data collected by these tools and how to stop their use (opt-out procedures, etc.).
Please click here for a list of external services that use cookie information.

Purpose of use

①To improve the website

To improve and optimize the website, we measure the time it takes for a page to load and gauge user behavior within a website, such as which pages the user browses, what page order the user views the website, and what part of the page the user clicks.

②Tag management

Websites that use tools imbed programs called tags to ensure that the tools work properly. We use tools to comprehensively manage multiple tags.

③Ad delivery

We deliver ads related to Company products and services to users who visit websites managed by the Company.

④Ad effect measurement and improvement

We measure the effect of the ads we deliver and implement improvements and other to maximize ad effect.

Revisions

The Company reevaluates and improves its information management system on an ongoing basis. With this process, revisions to the content of this section may be made. Notifications of such revisions will be made in a timely manner through this website, through a website the Company manages or in a manner deemed appropriate by the Company. Revisions to the content of this page will take effect on a date that the Company specifies separately.

Comments, questions, complaints and other

Please direct any comments, questions, complaints or other about the handling of information stipulated above to the following.