1. Handling of Pseudonymously Processed Information
- (1) Production of pseudonymously processed information
If the Company produces pseudonymously processed information (information of individuals that is obtained after their personal information is processed into a form that they are not identifiable unless it is cross-checked with another information by taking measures specified by the laws and regulations), it will appropriately process the information in accordance with the standards specified by the laws and regulations.
- (2) Safety control measures for pseudonymously processed information, etc.
With respect to pseudonymously processed information and deleted information, etc. thereof (the description, etc. and individual identification code that are deleted from the personal information used to produce the pseudonymously processed information and information on the method of processing (limited to information that allows the restoration of the personal information used to produce the pseudonymously processed information)), the Company takes safety control measures in accordance with the laws and regulations in addition to the provisions in Clause 9 “Safety Control Measures” of the Privacy Policy.
- (3) Handling of pseudonymously processed information that is personal information
If the Company handles pseudonymously processed information that is personal information, it will do in the following manner.
- It will use pseudonymously processed information that is personal information to the extent necessary for any of the purposes of use stated in Clause 2 “Purposes of Use of Personal Information” and Clause 5 “Joint Use with the Company’s Group Companies and Business Partners” of the Privacy Policy, and if it changes the purposes to use such information for another purpose, it will publicly announce the changed purposes of use.
- It will make efforts to delete without delay personal data that is pseudonymously processed information and relevant deleted information, etc. if it no longer needs to use them.
- It will not provide any third party with personal data that is pseudonymously processed information, unless: it is permitted under laws or ordinances; provided to a consignee within the scope necessary for carrying out the Company’s business; provided along with business transfer for a merger or any other reason; and used jointly with a group company or a business partner of the Company.
- It will not cross-check with any other information for the purpose of identifying the principals of the original personal information of pseudonymously processed information that is personal information.
- It will not use contact information or any other information contained in pseudonymously processed information for the purpose of communicating with or otherwise contacting the principals of the original personal information of the pseudonymously processed information that is personal information.
- It will otherwise handle pseudonymously processed information that is personal information and personal data that is pseudonymously processed information in the same way as normal personal information and personal data unless permitted by a law or regulation.
- (4) Handling of pseudonymously processed information that is not personal information
If the Company handles pseudonymously processed information that is not personal information, it will do in the following manner.
- It will not provide any third party with pseudonymously processed information that is not personal information, unless: it is permitted under laws or ordinances; provided to a consignee within the scope necessary for carrying out the Company’s business; provided along with business transfer for a merger or any other reason; and used jointly with a group company or a business partner of the Company.
- It will exercise necessary and appropriate supervision over the employees who handle pseudonymously processed information that is not personal information in accordance with the standards specified by the laws and regulations.
- If it consigns the handling of pseudonymously processed information that is not personal information to an external entity, it will exercise necessary and appropriate supervision over the external entity in accordance with the standards specified by the laws and regulations.
- It will not cross-check with any other information for the purpose of identifying the principals of the original personal information of pseudonymously processed information that is not personal information.
- It will not use the contact information or any other information contained in the pseudonymously processed information for the purpose of communicating with or otherwise contacting the principals of the original personal information of the pseudonymously processed information that is not personal information.
- (5) Changed purposes of use
NA
2. Handling of Anonymously Processed Information
- (1) Production, etc. of anonymously processed information
If the Company produces or otherwise uses anonymously processed information (information of individuals that is obtained after their personal information is processed into a form that they are not identifiable by taking measures specified by the laws and regulations and that does not allow the restoration of the personal information), it will do in the following manner.
- It will appropriately process personal information in accordance with the standards specified by the laws and regulations.
- It will take safety control measures to prevent leakage or the like of deleted information and information on the method of processing in accordance with the standards specified by the laws and regulations.
- It will publicly announce the categories of information contained in produced anonymously processed information.
- It will not attempt to identify the principals of the original personal information of produced anonymously processed information.
- If it obtains anonymously processed information from a third party, it will not obtain relevant deleted information or information on the method of processing or cross-check with any other information for the purpose of identifying the principals of the original personal information.
- (2) Provision of anonymously processed information
If the Company provides a third party with anonymously processed information, it will publicly announce the categories of information of the individuals contained in the anonymously processed information to be provided and the method of provision and clearly notify the receiving third party of the fact that the information to be provided is anonymously processed information.
3. Contact Information
The Company will appropriately and promptly respond to complaints and consultations regarding the handling of anonymously processed information and pseudonymously processed information. The contact point is stated in Clause 4 “Contact Information” of the Procedures to Request for Disclosure, etc.
