PONY CANYON INC. (Address: 1-5-17 Roppongi, Minato-ku, Tokyo, CEO: Takashi Yoshimura; hereinafter referred to as the “Company” or “we”) considers that the Company, a personal information handling business, is socially responsible for and owes the obligation of protecting personal information in its business operation, with full recognition of the importance thereof. Accordingly, we hereby establish the following privacy policy of the Company and will cause it fully known and understood by all our employees and surely comply with it.

1. Definition of Personal Information

The term “personal information” used herein means any and all information enabling the identification or discernment of individuals which we collect from customers, including the following:

1. Names, addresses, birth dates, ages, occupations, telephone numbers and credit card numbers of individuals;
2. Any other information enabling to identify individuals;

3. Processed pseudonym names: This means information concerning individuals processed taking the following measures (corresponding to each type of such information) in the manner that no specific individual cannot be identified unless collating to other information. When producing any processed pseudonym information, we will take the following measures:

   ・ To appropriately process in accordance with the relevant standards set by applicable laws and regulations;

・ To take security measure for prevention of leakage of information concerning deleted information or manner of processing as in accordance with the relevant standards set by applicable laws and regulations.

4. Information concerning individuals: This means any and all information showing facts, judgments and/or assessments concerning individuals such as names, addresses, sexes, birth dates, face images and information of their bodies, property, occupations, titles, etc., including information published by assessing bodies or printed works and information by visuals and/or sounds, regardless of whether or not such information is kept confidential by encryption, etc.

2. Collection, Use and Provision of Personal Information

(1) Principle concerning collection:

Personal information shall be collected on the precedent condition of the clarification of purpose and obtainment of the consent by the person to which the personal information belongs.

(2) Information to be Collected and Manner of Collection:

User information which the Company will collect shall be as stated below corresponding to manners of collection.

(a) Information acquired directly from users:

The Company will acquire the following information from users in relation to the Services:

• Names, addresses, birth dates, sexes, e-mail addresses, service use histories, and other information which the Company indicates will be collected through relevant web-sites or applications;

(b) Acquisition of technical information:

The Company will acquire the following technical information at occasions of users accessing to the Services:

• Types of browsers, referrers, IP addresses, Cookies and other advertisement-related identifiers

(c) Information acquired based on individual consents by users:

The Company will acquire the following information on condition of the approval of users concerned:

• Information of location

(3) Principles concerning use and provision:

The Company shall not use personal information in any manner threatening to prompt or trigger illegal or unjust conduct, in principle and, even if able to legally or justly use or provide personal information, we will perform such use or provision of personal information only within the scope clarified in advance.

(a) Purpose of use of personal information:

The Company will not use personal information collected from customers for any purpose other than the following purposes:

• ・ To provide customers with our services;
• ・ To seek opinions and suggestions concerning our services from customers;
• ・ To prepare statistical data by attributes (age, address, etc.) of customers;
• ・ To answer to customers’ inquires, etc.; and
• ・ To, in relation to settlement of prices, etc., conform the validity of customers’ credit cards or account numbers with financial institutions.

* When we are to use personal information of a customer for any purpose other than the afore-mentioned purposes, we shall in advance notify the customer of such use and acquire the customer’s approval thereof.

(b) Provision of personal information to third party:

Personal information that the Company has collected from customers shall not be provided or disclosed to any third party without the prior approval of the customers, except for the following cases:

• ・ Case where the Company entrusts the sending of goods, mail and/or catalogues, etc. to a company with which the Company has entered into a confidentiality agreement concerning business operation;
• ・ Case where the Company entrusts business operation to an IT service company operating servers (in such a case, we will select an appropriate company and properly supervise it by clarifying the entrusted company’s relevant obligations and responsibilities in an agreement executed with it, etc. so that the entrusted company will safely manage personal information disclosed to it in such entrustment);
• ・ Case where the Company entrusts an entity with the processing of such personal information;
• ・ Case where the Company is required to provide or disclose such personal information to a third party based on an applicable law or regulations;
• ・ Case where there is an emergent need to provide or disclose such personal information for protecting human lives, bodies, property or other material interests;

In addition, when the Company provides to or receives from any third party any personal information or individual-related information, it shall take necessary and appropriate measures for security management thereof and make relevant confirmation of approval, recording, preservation, etc., in compliance with the Personal Information Protection Act and other applicable laws and regulations.

3. Disclosure, Correction and Deletion of Personal Information

The Company shall respect each customer’s rights on his or her personal information and, if a request for the disclosure of a customer’s personal information or data provided by a third party is made to the Company on the basis of the Personal Information Protection Act, confirm that the request has been made by the customer himself or herself and, without undue delay, perform such disclosure of personal information or data in the manner of delivery of a document or any other manner designated by the customer (even in the case where any such other manner of delivery is designated by a customer, if the manner requires a large amount of expense or is difficult to take, the disclosure will be made by delivery of a document) (if requested information does not exist, we will notify the requesting customer thereof); except for cases where the Company is not obligated to perform such disclosure under the Personal Information Protection Act and other applicable laws and regulations.

If there is any error in a customer’s personal information and the correction, deletion or stop of use of the personal information is requested, the Company shall respond to such request without undue delay within a reasonable period, on condition that it is confirmed that the request has been made by the customer himself or herself for a reason allowed by the Personal Information Protection Act.

4. Appropriate Management of Personal Information

The Company shall implement appropriate security measures covering the personal information collected by the Company and take reasonable steps for prevention of unauthorized access to and alteration, destruction, leakage and loss of such personal information.

5. Compliance with Applicable Laws, Regulations and Rules

The Company shall comply with all applicable laws, regulations and rules concerning personal information.

6. Continuing Improvement of Personal Information

The Company shall appoint the personal information protection manager and perform the appropriate protection and management of personal information.

In addition, the Company shall regularly implement the relevant audit and, as necessary, make review and improvement of the protection and management of personal information.

7. Entrustment of Processing of Personal Information

The Company may entrust all or part of its business-related processing of personal information to a service provider(s) with which has entered into a relevant agreement with the Company.

In such a case, the Company shall select a service provider(s) considered to have been appropriately handled personal information, agree on matters necessary for prevention of the leakage of personal information by proper management and keeping of confidentiality and cause the service provider(s) to perform appropriate management of personal information.

8. Voluntary Provision of Personal Information and Result of Non-provision

Whether or not to provide his or her personal information to the Company shall fully depend on the will of a customer.

However, if a customer does not provide necessary information of his or her to the Company, we may be unable to supply our services to the customer.

9. Use of Cookie

The Company uses Cookies in order to improve the conveniences of its websites and optimize advertisements. “Cookie” means a small text file sent through each customer’s browser which makes the customer’s use of websites easier and more convenient.

Each customer may disable a Cookie sent to his or her device on a below-specified page, but if having so disabled, the customer may be unable to use part of our services.

Google Japan G.K.

□ Privacy Policy

https://policies.google.com/privacy?hl=ja

□ Opt-out

■ Advertisement

https://adssettings.google.com/authenticated?hl=ja

■ Google Analytics

https://tools.google.com/dlpage/gaoptout

10. Use of Google Analytics

The Company uses through Cookies the access analytic services named “Google Analytics” as provided by Google Japan G.K. for the purpose of planning, improvement, etc. of services. For Google Analytics, please refer to the following websites:

https://www.google.com/analytics/terms/jp.html

https://policies.google.com/technologies/partner-sites?hl=ja

11. Protection of Personal Information of Customers under 13 Years Old

We think that the handling of personal information of customers under 13 years old requires special consideration. When a customer under 13 years old provides his or her personal information to the Company, please do so with the consent of the statutory representative such as a person having the parental authority.

12. Contact for Inquiry

With respect to inquiries, complaints, etc. concerning the Company’s handling of personal information, please contact the following in writing:

Personal Information Inquiry Section, Internal Audit Office, PONY CANYON INC.

1-5-17 Roppongi, Minato-ku, Tokyo 106-8487

* We do not respond to inquiries other than in writing (by fax, telephone, e-mail, etc.).

After receiving a written inquiry, we will respond to the inquiry at the appropriate time.

13. Dates of Establishment and Revision of This Privacy Policy

Date of establishment: October 16, 2010

Date of revision: April 25, 2022