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Privacy Policy

Privacy Policy

Hakuto Group Company manages any and all personal Information which is acquired in relation to our business implementation in accordance with the following policy.
1.Compliance with Legal Acts/Codes
We comply with legal acts and codes related to protection of personal information within Japan and abroad such as the Act on the Protection of Personal Information and related guidelines and others upon handling personal information.

2.Acquisition and Using Personal Information
We acquire the personal information by appropriate means and by clearly specifying the purpose of use in advance, and use such personal information within the scope necessary to achieve such purpose of use.

3.Prohibition to Provide to a Third Party
We do not provide the personal information to any third party, except when we have obtained such person’s consent in advance or when it is permitted under legal acts.

4.Management of an Outsourcing Company
We may outsource the handling of personal information to a third party within the scope necessary to achieve the purpose of use. In such case, we will appropriately supervise such outsourcing company as required so that they can handle the personal information securely and appropriately.

5.Measures for Security Management
We maintain personal information accurate and up to date, and take proper and reasonable measures to prevent personal information from, including but not limited to, unauthorized access, loss, damage, and alteration or leakage.

6.Response to Request for Disclosure/Rectification
In case the person requests for disclosure, rectification of its personal information, we will respect such person’s right regarding its personal information and faithfully respond to such request.

7.Continuous Review and Improvement
We continuously review this policy and related internal rules, and seek for continuous improvement of the personal information protection, in compliance with the change of social environment regarding the handling of personal information.

Handling of Personal Information

Hakuto Group Company handles all personal information which we have acquired in relation to our business implementation in accordance with the following manners.

1.Purpose for Use of the Personal Information

We acquire the following personal information and use such personal information for the following purpose.
(1)Personal information regarding officers, or employees of our business partners, and public employees, civil service workers of public offices
We acquire their contact information, such as their name, business address, department, title, telephone number and e-mail address.
We use such personal information for business activities such as making correspondence, conducting negotiation, having meetings, placing and receiving orders, making payment and introducing our products or services.

(2)Personal information of customers using our products or services
We acquire their contact information, such as their name, telephone number, e-mail address and address of the customers who contacted us.
We use these information for responding to inquiry from the customers or for promotional activities of our products.

(3)Personal information regarding shareholders
We acquire contact information such as the name, telephone number, address, e-mail address and others of shareholders.
We use these personal information for the following purpose.
    ・To exercise our rights and fulfil our obligation under the Companies Act such as sending the notice for calling
     shareholder meetings.
    ・To manage shareholders such as making shareholder registry and others in accordance with legal acts.
    ・To provide convenience to the shareholders.
    ・To implement our policy towards shareholders.

(4)Personal information regarding the job applicant
We acquire contact information regarding the job applicant such as its name, telephone number, address, e-mail address, as well as its background and others. We use these information for the following purposes.
    ・To provide information regarding hiring, to make contacts, to consider and decide on its hiring
    ・To provide offer letter and any other documents necessary for enrolment

2.Joint Use of Personal Information

We jointly use the personal information held by our company (address, name, name of the place of work, name of the department, title, telephone number, fax number, e-mail address and others) with our group companies listed below within the scope necessary to achieve the purpose of use stated in Section 1 above. Hakuto Co. Ltd. will be responsible for the management of personal information upon such joint use.

3.Request for Disclosure

As to acquired personal information, we are ready to 1) disclose, 2) modify, add or delete, 3) stop its use or eliminate, 4) stop to disclose to any third parties, if so requested by the discloser of the personal information, as far as it does not unreasonably interrupt our appropriate business activities. Contact information for this purpose is stated as follows.
When we receive any of the above requests, we will identify that such request is truly raised by the discloser of the personal information, in accordance with our own procedure.

Please refer here for procedure regarding request for disclosure and others.

     Contact Information
     1-13, Shinjuku 1-chome, Shinjuku-ku, Tokyo 160-8910
     Hakuto Co. Ltd.
     Legal Department, Contact Person in charge of Personal Data
     Tel: 81-3-3355-7617 office hours from 9:00 to 17:30 (excluding Saturdays, Sundays and holidays)
     Fax: 81-3-3225-9001 contact by e-mail

Processing of Personal Data subject to GDPR

Hakuto Group Company handle the personal data subject to application of “EU General Data Protection Regulation (2016/679)” (hereinafter as “GDPR”) in accordance with the following terms, in addition to “Privacy Policy” and “Handling of Personal Information.”

1.Types of Personal Data to be Collected and its Processing Purpose

We collect the personal information/data stated in Clause 1 of “Handling of Personal Information”, and use it for the purpose specifically stated in Clause 1 of the same. In case we intend to process the collected personal data in order to achieve other purpose, we will certainly inform our intention to such person (“Data Subject”).

2.Transfer of Personal Data

In case we jointly use the collected personal data in accordance with Clause 2 of “Handling of Personal Information” above, in order to achieve the purpose of use stated in Clause 1 of “Handling of Personal Information”, we may transfer and process such data in a country outside of the EEA where EU Committee has not ensured an adequate level of protection. In such case, we will appropriately protect the personal data to be transferred in accordance with GDPR.

3.Grounds for the Legality of Personal Data Processing

We process the personal data in accordance with one or more of the following grounds in accordance with GDPR.

(1)Consent
  We may collect and process the personal data based on the consent of Data Subject. Data Subject may withdraw such
  consent at any time. However, such withdrawal will not affect the lawfulness of personal data processing conducted based
  on the consent before withdrawal.

(2)The processing is necessary to contact Data Subject
  We may collect and process the personal data, in case we provide information to Data Subject required in implementing
  business, or in case there is any other legitimate interest.

4.Rights

Data Subject have the following rights regarding our collected personal data.

(1)Access
  Data Subject has a right to request explanation regarding our collected personal data of Data Subject, and explanation
  regarding our method of use of such data.
  In addition, Data Subject has a right to receive a copy of our collected personal data of Data Subject, in case we collected
  Data Subject’s personal data based on its consent, or in case we collected the personal data in order to provide services
  requested by Data Subject.

(2)Delete
  Data Subject may request us, at any time, to delete our collected personal data of Data Subject. We will delete such
  personal data in accordance with such request in principle. However, we may continue to retain such personal data, in case
  we can retain such personal data in accordance with applicable law, including GDPR.

(3)Correction
  In case Data Subject determines that our collected personal data regarding Data Subject is inaccurate, Data Subject may
  request us to correct its personal data.

(4)Suspension
  In case Data Subject recognizes that our processing of the personal data is illegal, Data Subject may request to restrict the
  processing of such personal data in accordance with Article 18 of GDPR. In case we receive such request, we will not
  process such personal data other than store it.

(5)Objections and Complaint
  Data Subject has a right to object to our processing of personal data.
  However, we may continue to process such data notwithstanding the objection to the extent permitted under GDPR.

⇒Please refer here for procedure regarding these requests.

5.Complaint to Authority

Data Subject may file a complaint regarding our processing of personal data with the data protection authority of each country that has jurisdiction over the handling of personal data.

6.Retention of Personal Data

We retain collected personal data during the period of time necessary to implement the purpose of use stated in Clause 1 of “Handling of Personal Information”, or a period of time required by law, and promptly delete the data if it is no longer necessary.