Privacy Policy
Handling of Personal Information
Established as of May 1, 2008
Revised as of August 30, 2024
POLA ORBIS HOLDINGS INC. (hereinafter "the Company") strongly recognizes the importance of protecting personal information and appropriately manages, uses and otherwise handles personal information as stipulated in the following, which comply with the Act on the Protection of Personal Information of Japan (hereinafter "the Personal Information Protection Act"), relevant laws, regulations, guidelines and other requirements of Japan.
1. Safety Management Structure
The Company, for the entrusted personal information (hereinafter "personal information"), will take measures to prevent personal information from being leaked, lost or damaged and take other measures to appropriately manage personal information, and will make efforts to ensure that the personal information is kept accurate and up-to-date.
In handling personal information, the Company will take necessary and appropriate measures, as detailed below, to thoroughly ensure the safety management of personal information, including the prevention of unauthorized access from third parties, manipulation, leakage, loss or damage.
(1) Formulation of Basic Policy
- This policy on the handling of personal information has been established to ensure the proper handling of personal information and provide information about points of contact for inquiries and complaints handling.
(2) Development of Rules on the Handling of Personal Information
- The Company has formulated internal rules on the handling of personal information, setting out matters such as handling methods and the persons responsible/in charge and their responsibilities, at every stage of the process, from collection, use, storage and provision to deletion and destruction.
(3) Systematic Security Measures
- The Company designates a person responsible for the handling of personal information
- The Company clarifies the employees who handle personal information and the scope of their handling of personal information
- The Company has established a system of reporting to and contacting the person responsible for personal information management in the event that a violation or suspected violation of the Personal Information Protection Act or internal regulations has been identified
- The Company conducts periodic voluntary inspections on the status of personal information handling, and conduct audits by the auditing department or other sections as appropriate
(4) Human Security Measures
- The Company conducts regular training for employees on matters to be considered when handling personal information
- The Company describes matters related to the confidentiality of personal information in the Company's employment regulations
(5) Physical Security Measures
- In areas where personal information is handled, the Company restricts employee access and the equipment which can be brought in and also takes measures to prevent unauthorized persons from viewing personal information
- The Company takes measures to prevent the theft or loss of devices, electronic media, documents and other materials that handle personal information
- When transporting devices, electronic media and other materials that handle personal information, including transportation within business sites, the Company takes measures to prevent the personal information from being easily leaked or otherwise compromised
(6) Technological Security Measures
- The Company performs access control and limits the personnel who are able to handle personal information and the scope of the personal information that is handled
- The Company has adopted various defenses to protect information systems containing personal information from being hacked or infected by malware.
(7) Assessment of External Environment
- When personal information is stored in foreign countries outside of Japan, the Company implements security measures, while first grasping applicable legislation concerning the protection of personal information in such foreign countries (as a reference, see the following link).
https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku
Link destination: The website of Japan's Personal Information Protection Commission, showing its “Survey Result on Legislations (including relevant regulations) Regarding the Protection of Personal Information in Foreign Countries”
2. Collection
The Company obtains personal information through fair and legal means. When an individual purchases Company's goods, uses various services of Company, website or other offerings, cooperates with various survey activities, takes part in various Company events or otherwise interacts with the Company, the Company may directly collect personal information as needed. This information may include an individual's name, address, telephone number, age, date of birth, gender, email address, occupation, family composition, information on goods purchased, status of the use of various services, preferences regarding cosmetics and fashion, etc., size, skin condition, opinions, details of consultations and other such information.
3. Purpose of Use
Personal information may be used for the following purposes in order to ensure the safety and accuracy of transactions between the Company and an individual, and to provide better goods, services or information.
(1) To deliver the goods of or provide the services of the Company or its group companies
(2) To provide various information, display advertising or conduct surveys by telephone or direct mail with regard to the goods, services, campaigns or other activities of the Company or its group companies
(3) To provide information about, display advertising or conduct surveys with regard to various events, contests and other activities organized, co-hosted, supported or attended by the Company or its group companies
(4) For personal analysis during marketing, sales and similar activities, to make improvements to goods, services and campaigns, etc., and to conduct research, development and similar activities
(5) To prepare various statistical materials, media, and so on
(6) To respond to, record and organize feedback, consultations and similar communications
(7) To manage shareholders in accordance with law
(8) For the exercising of shareholder rights or fulfillment of obligations under law
(9) To provide information and services to shareholders, and to conduct surveys and similar activities
(10) To promote or improve PR activities, IR activities or cultural activities, and to conduct the necessary research for these activities
(11) In addition to the above items, information collected from an individual (including but not limited to information on viewing, usage, transaction or purchase history for websites or services, etc., preferences, skin condition, opinions and the details of consultations) may be analyzed and used for the following purposes
- To conduct research and development on the goods, services, events, campaigns or other activities of the Company or its group companies based on the interests, preferences or other information about individuals
- To provide various information about the goods, services, events, campaigns or other activities of the Company or its group companies based on the interests, preferences or other information about individuals
4. Provision of Personal Information to Third Parties
Except when permitted by laws and regulations, the Company will not provide any personal information to a third party without the prior consent of the individual involved.
Although this may not apply to persons accessing this site from outside of Japan, the Company may provide the following personal information to a third party.
Provision to credit card issuers
(1) In the event the customer purchases goods or services using a credit card, the Company will provide the following personal information collected from such customer to the card issuing company, settlement agent, research company, industry association, etc. in order to detect and prevent unauthorized use by the card issuing company.
・Name
・Billing Address
・Destination address
・E-mail address
・Telephone Number
・Information on the Internet usage environment
・Trading History, etc.
(2) In the event the issuer of a card is in a foreign country, such information may be transferred to the country to which the issuer belongs. The Company unable to identify the issuer of the card or the country where the company is located based on information collected from the customer, and therefore the Company is unable to obtain and provide information on the following measures to protect personal information.
・The name of the foreign country where the recipient is located
・Information on the protection of personal information of the country concerned
・Measures to Protect Personal Information of the Issuer
The Personal Information Protection Committee's website (https://www.ppc.go.jp/) provides information on personal information protection systems in various countries.
5. Entrustment
The Company may outsource certain operations such as the dispatch of notices to an individual, the running of events and campaigns, and the analysis of information such as purchase history and service usage history to a third party. In this case, the Company will conduct necessary and appropriate supervision over contractors according to the Personal Information Protection Act.
6. Shared Use of Personal Information
The Company may engage in the shared use of the personal information of customers as detailed below.
(1) Scope of joint users
POLA ORBIS HOLDINGS INC., its domestic consolidated subsidiaries and domestic affiliate companies
(2) Purpose of use of the joint users
1) For the Company or a company engaged in joint use with the Company to ensure the appropriate and smooth performance of transactions with customers or services provided to customers
2) For personal analysis during marketing, sales and similar activities, to make improvements to goods, services and campaigns, etc., and to conduct research, development and similar activities, on the part of the Company or a company engaged in joint use with the Company
3) When inquiries, usage applications or other applications concerning the goods, services, campaigns or other activities handled by the Company or a company engaged in joint use with the Company arise, to transfer or hand over those inquiries or applications to the company responsible
4) To provide information or conduct surveys, etc. related to advertising, goods, services, campaigns or similar matters conducted by the Company or a company engaged in joint use with the Company
5) In addition to the above items, to analyze the information listed in paragraph (3) of this section and use it for the following purposes
- To conduct research and development on the goods, services, campaigns or other activities of the Company a company engaged in joint use with the Company based on the interests, preferences or other information about customers
- To prove various information about goods, services, campaigns or other activities based on the interests, preferences or other information about customers
6) For the business management and internal management of the POLA ORBIS Group
(3) Items of personal information subject to shared use
Name, date of birth, residential and shipping address information, telephone number, email address, gender, history of transactions related to and usage of products and services, etc., questionnaire results, information on interests and preferences, details of feedback and consultations, information related to customer service, information concerning skin analysis, etc., information concerning activities on the Internet or other electronic networks, etc.
(4) Party responsible for managing personal information subject to shared use:
The company that originally acquired each item of personal information The party that originally acquired the personal information is the Company, the address and representative are as listed at the end of this document.
For information about the party responsible for management when a party other than the Company has originally acquired the personal information, please refer to the published matters concerning personal information on the official website of the company concerned.
7. Use of Pseudonymized Information
The Company creates pseudonymized information processed in such a way, in accordance with laws and regulations, so that a specific individual cannot be identified unless the information is cross-checked with other information, and such pseudonymized information is analyzed and used for such purposes as improvement, research and development of Company’s goods, services and other offerings.
In addition, the Company engages in the shared use of the pseudonymized information as below.
(1) Scope of joint users
Same as section 6, paragraph (1) above
(2) Purpose of use of the joint users
Analysis to improve, research or develop the goods, services, campaigns or other activities of each company engaged in shared use.
(3) Items of information related to individuals used on a shared basis
Of the items listed in section 6, paragraph (3) above, information other than the names of individuals (even for information other than the names of individuals, when it is necessary to delete, replace or otherwise process that information in accordance with the Personal Information Protection Act, that processing will be carried out appropriately)
(4) Party responsible for managing personal data that is pseudonymized information used on a share basis
Same as section 6, paragraph (4) above
8. Acquisition, Use and Provision of Information Linked with Identifiers Such as Cookies
(1) A cookie is a piece of text-based information that is sent from a website when it is viewed, and stored by the web browser. Additionally, a web beacon is a system to send information when an individual views a page or email message by embedding a small image inside a webpage or email message. This website uses cookies, beacons or similar technologies (hereinafter "cookies, etc.") to save and use information about individuals.
The Company may provide cookies, etc. and the information stored in conjunction with cookies, etc. to advertising distribution service providers and other companies to be used for the delivery of advertising (the companies to which the information is provided include but are not limited to the following).
・Yahoo! JAPAN (LY Corporation)
Yahoo! JAPAN Privacy Policy [ https://www.lycorp.co.jp/ja/company/privacypolicy/ ］Opt-out from Yahoo! JAPAN advertisements [ https://btoptout.yahoo.co.jp/optout/index.html ］
・Google（Google LLC )
Google Privacy Policy [ https://policies.google.com/privacy? hl=ja ］
Opt-out from Google advertisements [ https://support.google.com/ads/answer/2662922? h149l=ja ］
・Facebook（Meta Platforms, Inc.）
Facebook Privacy Policy [ https://ja-jp.facebook.com/policy.php ］
Opt-out from Facebook advertisements [ https://ja-jp.facebook.com/policies/cookies/ ］
(2) The Company may acquire information including information collected through identifiers such as cookies from a data management platform (DMP) operated by a third party with the consent of individuals (including but not limited to web viewing history) and the analysis results of such information, and may use this information after linking it with the personal data of individuals for the purposes of ad delivery, the planning and operation of goods, services, campaigns and other events, marketing activities and so on.
9. Disclosure, Correction, Suspension of Use, etc. of Personal Information
When an individual requests that personal information that relates to them be disclosed to them, the Company will respond promptly in accordance with laws and regulations after confirming the identity of the individual, except in the following cases. When the Company does not disclose the information in question or the personal information in question does not exist, it will reply to that effect.
- If disclosure could harm the life, body, property, or other interests of the user him/herself or a third party
- If disclosure could cause significant hindrance to the proper performance of our business
- If disclosure would violate laws or regulations
In addition, when an individual requests the disclosure, correction, addition, deletion, suspension of use, erasure or suspension of provision to third parties, the Company will respond promptly in accordance with laws and regulations after confirming the identity of the individual.
For inquiries regarding disclosure, etc., or questions or complaints regarding the handling of personal information, please contact the Company at the following email address, to the attention of “Personal Information Inquiries Desk, POLA ORBIS HOLDINGS INC.”
E-mail：webmaster@po-holdings.co.jp
10. Personal Information Retention Period and Erasure
Personal information will be appropriately retained and managed for the period deemed necessary by the Company, and after that period has ended, the information will be securely erased in a manner that renders it irrecoverable.
11. Legal Compliance and Efforts to Improve and Refine Handling
In handling personal information, the Company will observe the Personal Information Protection Act and other applicable laws and regulations of Japan, continually revise its handling procedures, and strive to improve and refine its security measures.
POLA ORBIS HOLDINGS INC.
1-7-7, Ginza, Chuo-ku, Tokyo
Yoshikazu Yokote, Representative Director and President
For details on the handling of personal information specific to each product or service, please refer to provisions on the handling of personal information for each product or service.