Note: The following document is an English translation of the Japanese-language original.

 

Formalized November 8, 2021

 

Asahi Broadcasting Group Holdings Corporation and Company subsidiaries (collectively, “the Group”) gives the utmost attention to the handling of personal information received from customers and other individuals. The Group has established the following Basic Policy for the Handling Personal Information.

 

1. The Group shall appoint an individual in charge of the protection of personal information for the Group, and establish an organization to oversee the protection of personal information for the Group under the supervision of said individual. In addition, each company within the Group will designate a department and individual to be in charge of personal information protection to clarify responsibilities, establishing an organization and system to maintain, manage, and use personal information protection while cooperating as appropriate with other companies within the Group.

 

2. The Group shall comply with the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003) and other laws, regulations, and related guidelines.

 

3. In handling personal information, the Group shall specify as clearly as possible the purpose for which said personal information shall be used.

 

4. The Group shall acquire personal information to the extent necessary in an appropriate and fair manner.

 

5. The Group shall strive to keep the content of the personal information obtained accurate and up-to-date to avoid errors.

 

6. The Group shall appoint an individual to be in charge of handling personal information to ensure leakage, loss, or damage does not occur, and to ensure information is managed in a safe and appropriate manner. Personal information no longer needed will be promptly disposed of.

 

7. In principle, the Group shall not provide personal information to third parties without the prior consent of the individual in question. However, this affirmation does not apply to statistical data which cannot be used to identify individuals.

 

8. When consigning the handling of personal information to a third party, the Group shall only select third party capable of protecting personal information adequately, and the Group shall only do so after concluding an agreement with said third party regarding the handling of personal information. In addition, the Group shall implement necessary and appropriate supervision of the third party in question to ensure appropriate security management at said third party.

 

9. If the Group receives any inquiries or requests for disclosure of personal information, the Group shall respond promptly and appropriately in accordance with procedures established by the Group.

 

10. In the event that the law requires the Group to handle personal information in a different manner than described herein, the Group shall do so in respect of the purpose of said law.

This policy explains how Asahi Broadcasting Group Holdings Corporation (“the Company”) handles the personal information or information regarded as personal information (“Personal Information”) belonging to customers and other individuals involved with the Company as the Company engages in various businesses and services.

In this policy, the term “Group” refers to Asahi Broadcasting Group Holdings Corporation and Group companies (https://corp.asahi.co.jp/en/company/group.html).

This policy applies to the handling of personal information encountered through the business activities of the Company (excluding information the purposes of news reporting and writing). However, in the event that the handling of personal information is stipulated separately under a notice concerning the handling of personal information by a service or in individual terms of use, etc. (“Individual Terms”), the provisions of such notice shall also be applicable. In the event of any inconsistencies between this policy and Individual Terms, Individual Terms shall take precedence.

 

The Company shall strive to handle personal information used in news reporting and writing in an appropriate manner, including appropriate safety management measures in accordance with the Group Information Security Policy, based on the purpose and provisions of the Act on the Protection of Personal Information.

 

*The Act on the Protection of Personal Information stipulates that the obligations of a business operator handling personal information do not apply to personal information handled by a broadcasting institution or literary writer for the purpose of news reporting or writing.

The Company shall acquire personal information, for the following purposes, except in cases where exceptions are permitted by law.

Personal information to be used

(1) Personal information of participants in seminars, webinars, and other events hosted by the Company

Purpose of use

・To operate events smoothly

・To communicate and provide information regarding events

・To publish photos and videos taken at events (publication on TV or in newspapers, magazines, posters, websites, etc.)

・To provide information about the business and services of Group companies via e-mail distribution, etc.

・To distribute advertisements

 

Personal information to be used

(2) Personal information of persons who request materials, etc.

Purpose of use

・To send materials

・To contact and follow-up services after delivery

 

Personal information to be used

(3) Personal information obtained from public sources of information, lists distributed at events, etc.

Purpose of use

・To provide information about the business and services of Group companies

 

Personal information to be used

(4) Personal information disclosed on the internet, such as through social media

Purpose of use

・To analyze optimal communications with customers

・To improve Company services

・To confirm opinions about the Company

 

Personal information to be used

(5) Personal information of persons who contact the Company with inquiries, consultations, or suggestions

Purpose of use

・To respond to inquiries and consultations

・To contact customers

・To investigate and confirm with contractors and other companies within the Group companies as necessary to respond to inquiries, consultations, and suggestions.

 

Personal information to be used

(6) Personal information of persons who have given the Company opinions or feedback about services

Purpose of use

・To optimize websites and services

・To respond to comments about the Company

 

Personal information to be used

(7) Personal information of persons who have cooperated in questionnaires and surveys, etc.

Purpose of use

・To optimize websites and services

・To provide information about the business and services of Group companies via e-mail distribution, etc.

・To distribute advertisements

 

Personal information to be used

(8) Personal information obtained from business partners and through sales activities

Purpose of use

・To contact and follow-up with individuals in the course of business activities

・To provide information about the business and services of Group companies

 

Personal information to be used

(9) Personal information of persons visiting the Company

Purpose of use

・To confirm visitors to the Company and manage facility access

・To ensure the security of the Company facilities

 

Personal information to be used

(10) Personal information handled in the course of contracted services

Purpose of use

・To conduct operations within the scope of the contracted services

 

Personal information to be used

(11) Personal information of shareholders

Purpose of use

・To fulfill obligations under the Companies Act and other related laws and regulations, and to respond to the exercise of shareholder rights

・To distribute business reports and other materials

Personal information to be used

(1) Personal information of applicants for employment

Purpose of use

・To make necessary contacts for interviews, etc.

・To consider and determine whether to hire individual (period between application to employment)

 

Personal information to be used

(2) Personal information of retired employees

Purpose of use

・To make necessary contacts from the company for business, socializing, etc.

・To understand the employee career, work, employment, safety management status, etc., during the period of employment

・To include information in employee records and lists

・To make external announcements and public relations activities related to Company businesses

・To perform obligations and conduct communications under labor-related laws and regulations

Personal information to be used

Personal information as described above

Purpose of use

・To optimize websites and services

・To provide information for use in analysis and public disclosure supporting optimal communications with customers

In accordance with the Group Basic Policy for the Handling Personal Information, the Company shall take measures necessary and appropriate for safety management in accordance with each matter described below to prevent leakage, loss, or damage of personal information (including the personal information that the Company has acquired, or is trying to acquire, and plans to handle as personal data).

1. Establish privacy protection rules for the specific handling of personal information
2. Establish an organizational structure for implementing safety management measures specified in privacy protection rules, a means for confirming the status of said structure in accordance with rules, a system for responding appropriately and promptly when a leak or other incident occurs or signs of a leak are detected, and the ongoing evaluation, review, and improvement of these measures
3. Inform and educate employees consistently on the appropriate handling of personal information
4. Manage areas where personal information is handled, engage in appropriate management to prevent theft, etc., of equipment and electronic media, prevent leaks, etc., when electronic media, etc., are physically relocated, provide appropriate deletion of personal information, and disposal of equipment and electronic media, etc.
5. Institute access control when using information systems to handle personal information, identify and authenticate accessors, prevent unauthorized external access, and prevent of leaks, etc., associated with the use of information systems
6. Take necessary and appropriate measures when handling personal information in a foreign country based on an understanding of the systems for personal information protection within said foreign country

As a general rule, the Company shall not provide personal information to a third party without first providing the individual in question with the necessary information and obtaining said individual's consent. However, such shall not apply under any of the following circumstances.

1. When required by law
2. When necessary to protect the life, body, or property of an individual and obtaining consent of said individual is difficult
3. When particularly necessary to improve public health or promote the sound growth of children and obtaining consent of said individual is difficult
4. When providing personal information is necessary for cooperating with a national agency, a local government, or an individual or entity entrusted by either of the foregoing in executing affairs prescribed by laws and regulations, and obtaining the consent of said individual is likely to impede the execution of such affairs

As a general rule, the Company shall not provide personal information to a third party in a foreign country without first providing the individual in question with the necessary information and obtaining said individual's consent. However, such shall not apply under any of the following circumstances.

1. When required by law
2. When necessary to protect the life, body, or property of an individual and obtaining consent of said individual is difficult
3. When particularly necessary to improve public health or promote the sound growth of children and obtaining consent of said individual is difficult
4. When providing personal information is necessary for cooperating with a national agency, a local government, or an individual or entity entrusted by either of the foregoing in executing affairs prescribed by laws and regulations, and obtaining the consent of said individual is likely to impede the execution of such affairs

The Company shall share personal information as follows.

[Sharing among companies within the Group]

1. Personal information to be used jointly

Area of residence, telephone number, e-mail address, date of birth, gender, occupation, service usage history, product purchase history, usage of websites and web services collected through device identifiers such as advertising IDs and cookies, and information indicating interest and concern obtained through contact with customers who have registered for web services operated by Group companies.

 

2. Scope of parties included for joint use

Asahi Broadcasting Group Holdings Corporation and Group companies of Asahi Broadcasting Group Holdings Corporation 
(https://corp.asahi.co.jp/en/company/group.html)

 

3. Purpose of use

(1) To provide web services
(2) To provide information and communications regarding web services
(3) To optimize web services
(4) To analyze optimal communications with customers
(5) To provide information about Group business and services via e-mail distribution, etc.
(6) To distribute advertisement

 

4. Party responsible for joint use of personal information

Asahi Broadcasting Group Holdings Corporation

(https://corp.asahi.co.jp/en/company/profile.html)

 

The Company shall, with the individual’s consent, link personal information used by the Company with personal information obtained from third parties (such as usage status of websites and web services collected through device identifiers such as advertising IDs and cookies), and use such information to the extent necessary to achieve the said purpose of use.

Further, in the event that personal information is expected to be acquired as personal data by the party to which it is provided, the Company shall not provide personal information to a third party without confirmation, etc., that the individual in question has provided consent.

At the time of publication of this policy, the Company has not created anonymously processed information or pseudonymized processed information.

In the future, if the Company creates anonymously processed information, the Company shall disclose such, as well as what details of information about individuals are included in anonymously processed information. If the Company creates pseudonymized processed information, the Company shall disclose such and the purpose of use of the pseudonymized processed information in question.

Complaints and requests for disclosure regarding the Company’s handling of personal information are accepted via the following contact methods.

Follow the procedures below to request notifications of the purpose of use, disclosures, corrections, additions, deletions, suspension of use, or deletion of personal information. In principle, the Company shall respond to such requests in writing (by physical mail). Such is not the case when the request is made by the individual themselves.

1. Contact the desk for complaints and requests for disclosure in writing or via web form. Details regarding subsequent steps will be announced separately.
2. To confirm the individual’s identity, the Company may ask the individual to provide a copy of a driver's license, passport, or other official document with photo.
3. In some cases, the Company may not be able to respond to requests for disclosure, etc., due to legal requirements. The Company will provide notification for the reason in this case.
4. A handling fee of 300 yen (including consumption tax) and the actual cost of shipping will be charged for each request for disclosure and notification of the purpose of use.

The Company may change the content of this policy to comply with laws and regulations or to meet business needs. In the event of any changes, the date of publication will be updated and the updated policy will be posted.

Shinya Yamamoto

Representative Director

Asahi Broadcasting Group Holdings Corporation

1-1-30 Fukushima, Fukushima-ku, Osaka 553-8503

Last updated: October 1, 2024