DOWA HOLDINGS CO., LTD. (“DOWA”, “we”, “us” or “our”), in recognition of the importance of securing your personal information, has implemented the following policy to appropriately manage and use personal information in compliance with the provisions of the Act on the Protection of Personal Information (the “Act”) and other laws and regulations and guidelines related thereto, striving to meet your expectations.

1. Purposes of Use of Personal Information

We use personal information within the scope of the purposes listed below. If any personal information is used for any other purpose, we will, at the time of acquisition of such information, separately specify the purpose of use and announce or notify the person concerned of it, and we will handle the personal information within the scope of the specified purpose of use.


(Personal information of customers contacting us for inquiry)

  • To reply to customers contacting us for inquiry, verify their identities, confirm the details of their inquiry and respond to them


(Personal information of business partners (including prospective business partners)

  • To provide information regarding proper use, quality, safety and effectiveness, etc. of services and products
  • To exercise and perform the rights and obligations related to transactions
  • For the collection of information necessary for business operations or for business contact purpose, etc.


(Personal information of shareholders)

  • To exercise and perform the rights and obligations under the Companies Act
  • To send a year-end report and other distributions and communication
  • For the management of shareholders, including preparation of shareholders data pursuant to the specified criteria based on various laws and regulations
  • For administration work in relation to the preparation and submission of payment records


(Personal information of researcher and academics who are working on our research and development)

  • To develop better products and services in each business field and conduct research and study for the development
  • For the collection of information necessary for business operations or for business contact purpose, etc.


(Personal information of civil servant such as a contact person of concerned public office)

  • To obtain required permits and licenses
  • To report an incident or recall when it occurs
  • For the collection of information necessary for business operations or for business contact purpose


(Personal information of participants/members of the association which we are a member of)

  • For the collection of information necessary for business operations or for business contact purpose


(Personal information of reporters, analysts, and institutional investors relating to PR/IR activities)

  • To send a year-end report and other distributions and communication
  • For the collection of information necessary for business operations or for business contact purpose


(Personal information of users and guests of training or resort facilities)

  • To create a hotel register pursuant to the Hotel Business Act
  • For the confirmation of users and guests
  • For business contact purpose


(Personal information of neighborhood of our facilities)

  • To contact in case of emergency or necessity


(Personal information of job applicants)

  • For employee screening
  • For the management of prospective employees
  • To provide information for publicizing employment opportunities information
  • For the enhancement of recruitment activities


(Personal information of retirees)

  • For the payment of company retirement pension, etc.
  • For business contact, including sending of an invitation to alumni association
  • To provide any information regarding company’s circumstances
  • To send a year-end report and other distributions and communication

2. Security Measures

With respect to personal information, we have implemented the measures for the prevention of leakage, loss or damage and for other proper control of the personal data.


(Establishment of basic policy)

  • This policy has been established in order to ensure the appropriate handling of personal information and inform the contact point for inquiries and complaints.


(Establishment of rules for handling of personal data)

  • We establish rules for the controlling of personal information with regard to handling methods, persons responsible or in charge as well as their duties, etc. for each stage of acquisition, use, storing, provision, deletion and destruction of personal data.


(Organizational Security Measures)

  • We assign an officer who is responsible for the handling of personal data (Chief Privacy Officer).
  • We clarify which employees handle personal data and the scope of personal data to be handled by such employees.
  • We establish a system to ensure that any breach or possible breach of laws or any internal rules is reported to Chief Privacy Officer when it is noticed.
  • We perform a regular self-check on the handling of personal information, along with an audit by other departments or external auditors.


(Human Security Measures)

  • We provide our employees with training on a regular basis on the matters concerning the handling of personal information.
  • We specify the matters concerning confidentiality of personal information in the rules of employment.


(Physical Security Measures)

  • In areas where personal information is handled, we control the entry and exit of employees, restrict the devices brought into those areas, and take the measures to prevent an unauthorized person from viewing personal information.
  • We take the measures for securing devices, electric medium and documents, etc. containing personal information from theft or loss.
  • We take the measures to protect devices and electronic medium containing personal information so that the personal information is not easily revealed when they are carried around, including being moved within the office.


(Technical Security Measures)

  • We implement access control to limit the persons in charge and the scope of personal information being handled.
  • We introduce a system to protect the information system for handling personal information from being externally accessed by someone who is not authorized or malware.


(Understanding of external environment)

  • We take these security measures with the understanding of the personal information security system introduced in foreign countries where our group companies keeping personal information are located (please see the “Group Companies List” available in our website)

3. Provision of Personal Information to a Third Party

Unless otherwise permitted by laws and regulations, we shall not provide your personal information to any third party without your prior consent. When we outsource the handling of your personal information to a third party, we will only disclose the personal information after the conclusion of an agreement imposing on such third party obligations to take adequate security measures.

4. Outsourcing

We may outsource the processing of information such as analysis of browsing history of websites, etc. to a third party. In such case, we will provide necessary and adequate supervision to the outsourcing company in accordance with the Act.

5. Joint Use of Personal Information

We may share your personal data within our group companies only when necessary. When jointly using your personal information, we will handle it in compliance with the Act and any other related laws and regulations.

 

  1. Personal data items that may be jointly used
    Name (if you are a company, name of an officer/employee and its title and affiliation), address, date of birth, sex, phone number, fax number, email address, and contents of inquiry
     
  2. Scope of joint users
    The following companies may jointly use it:
  1. Purposes of use by joint users
    Same as ones listed in Articles 1 and 2 hereof.
     
  1. Party responsible for management of personal information
    DOWA HOLDINGS CO., LTD.
    Please refer to the following URL for the address and representative’s name:
    https://hd.dowa.co.jp/en/company/summary.html

6. Acquisition, Use and Provision of Information Associated with Identifiers Like Cookie

A cookie is information that the websites send to your web browser and is stored in your device. A web beacon is a mechanism that uses a small image file embedded into a web page or email to transmit information when you browse or open the web page or email. This website uses cookies, web beacons or other similar technology to analyze information such as your browsing history of the website and use it for the following purposes.

  • To enhance information and services provided through this website
  • To inspect and eliminate any malfunction in order to ensure the technical operation on this website

7. Request for Disclosure of Retained Personal Data

When a person or his/her agent requests the disclosure of his/her personal data retained by us, we will respond without delay, except for the cases below. If we decide not to disclose or there exists no such data, we will notify to that effect.

  • When the disclosure is likely to harm the life, body, property or other rights and interests of the person concerned or any third party
  • When the disclosure is likely to cause significant hindrance to the performance of our business activities
  • When the disclosure results in the violation of laws and regulations

Furthermore, when a person or his/her agent requests rectification, addition or deletion, or cessation of use, or suspension of provision to a third party, of his/her personal data retained by us, we will conduct investigation and respond to such request accordingly in accordance with laws and regulations.

Please note that we may request submission of documents required for disclosure request, how to request and a form of identification to verify the requester’s identity.

If you have any questions on the above, please contact us at the following email address:

 

 DOWA HOLDINGS CO., LTD.

 General Affairs & Legal Department

 E-mail: privacy@dowa.co.jp

8. Contact for inquiries and complaints

If you have any questions or complaints about our handling of personal information, please contact the following email address:
 

 DOWA HOLDINGS CO., LTD.

 General Affairs & Legal Department

 E-mail: privacy@dowa.co.jp

April 1, 2022
amended on November 24, 2022


SEKIGUCHI Akira
President and Representative Director
DOWA HOLDINGS CO., LTD.
Akihabara UDX 22F, 14-1, Sotokanda 4-chome, Chiyoda-ku, Tokyo 101-0021, Japan