Policy for handling personal information (Privacy Policy)

Policy for handling personal information (Privacy Policy)

NIKI GOLF Co., Ltd. (hereinafter referred to as "our company") recognizes the importance of personal information entrusted to us by our customers (including business partners, their personnel, and applicants for our employee recruitment efforts; hereinafter referred to as "Customers, etc."), and believes that it is our social responsibility to strive to protect such information. To ensure that our Customers, etc. can use our services with peace of mind, we will comply with the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as "the Act") and other laws and regulations, and will handle personal information appropriately in accordance with the following privacy policy (hereinafter referred to as "these Guidelines").

The meaning of any terms not defined below shall be governed by law.

1. Definition of Personal Information

In these guidelines, personal information refers to information about a living individual that falls under any of the following items.

Information about customers, etc. that can identify a specific individual based on the name, date of birth, and other descriptions contained in the information (meaning all matters (excluding personal identification codes) written or recorded in documents, drawings, or electromagnetic records (meaning records made in electromagnetic form (meaning electronic, magnetic, or other forms that cannot be recognized by human perception); the same applies hereinafter) or expressed using voice, action, or other methods); the same applies hereinafter) (including information that can be easily collated with other information, thereby making it possible to identify a specific individual).

Any personal identification code such as passport number, driver's license number, facial recognition data, or fingerprint recognition data

2. Purpose of Acquisition and Use of Personal Information

We will acquire personal information of our customers, etc. by lawful and fair means within the scope of the following purposes of use (hereinafter referred to as the "Purposes of Use").

Personal information of customers, etc.

1. To provide the products and services provided by our company (including NIKI GOLF Online Site, hereinafter referred to as "the Services"), including accepting applications, shipping, and after-sales service.
2. To verify the identity and user qualifications when using this service and to manage customers
3. To bill for the use of this service
4. To advertise, advertise, and promote the Service, respond to inquiries, etc., and to contact customers regarding changes to the various terms and conditions applicable to the Service, etc.
5. To maintain and improve the Service, and to plan and develop new Products and Services
6. To fulfill obligations under the Secondhand Goods Business Act and other laws and regulations
7. To conduct campaigns, prize draws, and surveys regarding products or services handled by our company
8. To research and analyze marketing data, and to consider and implement marketing measures
9. To prevent or respond to fraudulent activities, etc.
10. To provide to third parties in the manner described in these guidelines

Personal information of business partners

1. For business-related contact and contract fulfillment
2. To manage business partner information

Applicant's personal information

1. To contact those who have applied for our employee recruitment (hereinafter referred to as "applicants").
2. For recruitment selection
3. For employment procedures after hiring decisions are made

3. Provision of personal information to third parties

Except in the following cases, we will not provide personal information handled by our company to third parties without the consent of our customers.

1. When there is consent from the customer, etc.
2. When it is necessary to protect a person's life, body, or property, and it is difficult to obtain the individual's consent.
3. When it is particularly necessary for the improvement of public health or the promotion of healthy child development, and it is difficult to obtain the consent of the individual.
4. When it is necessary to cooperate with a national government agency, local government, or a person commissioned by them in carrying out duties prescribed by law, and obtaining the individual's consent is likely to impede the performance of said duties.
5. Other cases permitted by law.

Notwithstanding (1) above, the Company may provide personal information handled by the Company to a third party in the following cases:

1. When providing information that cannot be used to identify a specific individual to an advertising distributor affiliated with our company in order to deliver advertisements tailored to the interests of customers, etc., check the results of such advertisements, and provide services.
2. Third parties located abroad

In order to achieve the above purposes of use, when we outsource all or part of our business to a third party, we may provide the outsourced party with the necessary personal information of our customers, etc. In such cases, we will enter into a contract with the outsourced party regarding the protection of personal information and will provide appropriate supervision.

4. Joint use

We will jointly use personal information as follows:

Items of personal information to be jointly used

Section 2 (1) and (2) of this Guideline

Purpose of use of jointly used personal information

Purpose of use

Scope of joint users

Our group companies

Person in charge of managing joint use

Our company (Address: 2nd floor, Asahi Building, 1-80-1 Takashimadaira, Itabashi-ku, Tokyo; Representative Director and President: Kazunari Futatsugi)

5. Safety Management Measures

We will take necessary and appropriate measures to prevent the loss, damage, falsification, leakage, etc. of personal information we handle, and to manage the personal information safely. The safety management measures we will take include the following:

Establishment of basic policies

To ensure the proper handling of personal information, we comply with relevant laws and regulations and have established basic policies regarding contact points for inquiries.

Organizational security control measures

We have appointed a person responsible for handling personal information, established internal rules regarding the safe handling of personal data, and established a system for reporting to the person responsible in the event that we become aware of any facts or signs of violations of laws or internal rules.

In addition, we regularly conduct self-inspections regarding the handling of personal information, and also have audits conducted by other departments and external parties.

Personnel safety management measures

We provide training on important points to note regarding the handling of personal information.
In addition, matters regarding confidentiality of personal information are stipulated in the work regulations.

Physical safety control measures

In areas where personal information is handled, we manage employee entry and exit, and take measures to prevent unauthorized persons from viewing personal information.
In addition, we take measures to prevent theft or loss of devices, electronic media, documents, etc. that handle personal information, and we also take measures to prevent personal information from being easily discovered when carrying such devices, electronic media, etc., including when moving within the office.

Technical safety control measures

We have introduced mechanisms to restrict access to personal information, restrict the means of taking it out, and protect information systems that handle personal data from unauthorized external access or malicious software.

6. Revision of this policy (privacy policy)

To protect personal information, we may revise these guidelines as necessary.
The contents of these guidelines may be changed, except for matters otherwise specified by laws and regulations or other provisions of these guidelines. The changed guidelines will take effect when they are posted on our website.

7. Notification, disclosure, correction, etc. of purpose of use and suspension of use

In accordance with the procedures set out in Section 9 below, we will respond without delay to requests from customers, etc. for disclosure, etc. (requests for notification of purpose of use, disclosure of personal information or records of provision to third parties, correction, addition, deletion, and suspension of use or suspension of provision to third parties) except in cases where we are not obligated to do so under the Personal Information Protection Act or other laws and regulations. Please note that we do not issue "certificates" for correction, addition, deletion, or suspension of use.

8. NIKI GOLF Online Site (hereinafter referred to as "this site")

About access logs

This website records information about those who access it in the form of an access log. The access log includes the accessing person's IP address, browser type, domain name, access time, number of accesses, etc. The access log will be used for the maintenance and management of this website, statistical analysis of usage status, and user support (identifying and resolving the causes of problems, etc.), but will not be used for any other purposes.

Cookies Information

This website uses cookies. Cookies are data files used to record information on users' devices (computers, smartphones, tablets, or other devices that can connect to the Internet) when they visit this website, and are used to make it easier for users to use this website. Please note that users' personal information cannot be identified from cookie information.

Security

On this site, user registration information is password protected for privacy and security reasons. This site uses SSL (Secure Socket Layer) encryption technology on all screens, and has a complete system in place to prevent information such as personal information and credit card numbers from being transmitted unprotected. You can check encrypted messages in real time, so you can send your personal information safely.

Links to websites operated by other companies

We cannot be held responsible for the handling of personal information on websites operated by third parties other than our company that have links to this website (hereinafter referred to as "other websites"). If you move from this website to another website, we recommend that you check the privacy policy of the website you are moving to regarding the handling of personal information.

9. Inquiries and procedures regarding disclosure of personal information

If you (hereinafter referred to as the "person") or your representative requests to inquire about, change, or suspend the use of personal information, we will respond after confirming your "documents to verify your identity." If the request is made by a representative, we will respond after confirming your "documents to verify your identity" and "documents to verify your power of attorney." We will respond by email or in writing, depending on the request. Please note that if we respond by mail, we will charge you the actual cost of registered mail, etc. For procedures and contact information, please refer to 10. Contact Information Regarding Personal Information.

Please note that we may not be able to comply with your request if any of the following applies.

• If we cannot verify your identity or that you are a representative
• When a request is made for disclosure, correction, addition, deletion, suspension of use, etc. of personal information that does not fall under the personal data held by our company
• When disclosure of personal data held by our company is likely to harm the life, property, body, or other rights and interests of the individual or a third party.
• When there is a risk of causing significant disruption to the proper execution of business
• If disclosing personal data held by the Company would violate other laws and regulations
• When you request correction or addition of personal data held by our company, if the correction is not necessary or the request is not true
• When a request is made to delete or suspend use of personal data held by our company (hereinafter referred to as "suspension of use, etc."), and no violation of our procedures is found
• When a request is made to suspend use of personal data held by our company, it is difficult to suspend use, etc., and the rights and interests of the individual can be protected by alternative means.

10. Contact for inquiries regarding personal information

For inquiries regarding the handling of customer information on NIKI GOLF online site, please contact the following office.