1. Name and address, and name of representative of JINS
JINS HOLDINGS Inc.
2-26-4 Kawaramachi, Maebashi-shi, Gunma 371-0046
Representative Director and CEO, Hitoshi Tanaka
2. Compliance with relevant laws, regulations, guidelines, etc.
JINS conducts the appropriate handling of personal information in compliance with the Personal Information Protection Act and other laws, as well as the Personal Information Protection Commission’s guidelines and other guidelines.
3. Acquisition and use of personal information
JINS uses personal information in an appropriate manner to the extent necessary to achieve the purposes of use.
4. Purposes of use of personal information
JINS uses personal information for the following purposes:
(1) Personal information pertaining to customers
[Purposes of use]
For the purposes of planning, R&D and quality improvement of our products, services, etc., including:
- Collection (including provision by a third party), recording (including keeping records) and analysis of attribute information, records of behavior, etc., in order to grasp customers’ interests, tastes, etc., and planning, R&D and quality improvement of the products and services based thereon; and
- Improvement and enhancement of customers’ experience in the digital services provided by JINS (website, mobile applications, etc.).
For the purposes of providing our products, services, etc., including:
- Verification of identity and personal authentication of customers;
- Sale of products, sending bills, etc., provision of related services, bill collection and reimbursement as well as diverse communications;
- Collection (including provision by a third party), recording (including keeping records) and analysis of purchase records, attribute information, records of behavior, etc., of customers and optimum provision of the products and services based thereon; and
- Communication with and sending prizes to prize winners in connection with campaigns in which customers have participated.
For the purposes of providing information pertaining to our products, services, etc., including:
- Advertisement and provision of information concerning our products, services, campaigns, etc., by means of invitation letters, emails, etc.; - Collection (including provision by a third party), recording (including keeping records) and analysis of information such as records of viewing websites, purchase records, attribute information, etc., of customers, as well as information provision and advertisement distribution pertaining to the products and services based thereon (including the cases of using advertisement distributors); and - Collection, recording (including keeping records) and analysis of images of customers’ behavior by means of cameras or applications installed in stores, as well as marketing activities based thereon such as presenting recommendations and providing other information.
For the purposes of responding to various inquiries, complaints, etc., and engaging in diverse communication, including:
- Responding to, confirming and recording (including keeping records) of inquiries, consultations, and complaints from customers and requests for repair services and customer support.
For the purposes of safely providing JINS’ products and services and measures to prevent wrongdoing, including:
- Investigation, detection and prevention of and response to wrongdoing such as fraud, illegal access, etc., by means of misuse of the services, etc.; and
- Use for prevention of crimes, such as images and sounds recorded by surveillance cameras.
(2) Personal information pertaining to business partners (in the case of a corporation, the officers and employees thereof)
[Purposes of use]
For the purposes of managing business, diverse communication, etc., including:
- Communication required for business, negotiation, execution and performance of agreements, business negotiations, claims and payment, etc.;
- Management of business partners’ information;
- Provision of information pertaining to our products, services, campaigns, seminars, etc.; and
- Controlling entrance into and departure from premises, and management of facilities and equipment.
(3) Personal information pertaining to shareholders (in the case of a corporate shareholder, the officers and employees thereof)
[Purposes of use]
For the purpose of administration of shareholders, diverse communication, etc., including:
- Exercising rights and performing obligations in accordance with the Companies Act; and
- Administration for shareholders such as preparation of records based on various laws and regulations.
(4) Personal Information pertaining to applicants for recruiting and invitation activities
[Purposes of use]
For the purpose of administration of applicants for recruiting and invitation activities, diverse communication, etc., including:
- Communication with and provision of information to applicants for recruiting and invitation activities and other uses required for recruiting and invitation activities.
* In the event of employment, the personal information of the applicants will be used for personnel and labor management purposes.
(5) Personal Information pertaining to employees
[Purposes of use]
For the purpose of personnel and labor management, including:
- Business communication with employees;
- Payment of remuneration (salaries, bonuses, various allowances, etc.) to employees, performance of personnel and labor management and provision of welfare services; and
- Health management for employees.
*Provision to third parties
JINS may provide the acquired personal information to a third party in accordance with Item 7 below.
5. Handling of Special care-required personal information
JINS may acquire Special care-required personal information after obtaining the data subject’s prior consent for the purposes of use set forth in Items 4 (1) through (5) above.
6. Joint use of personal information
JINS is engaged in its business together with our subsidiaries such as JINS Inc. as one group. Therefore, JINS jointly uses the personal information that it has acquired, as follows:
(1) Personal information to be jointly used
All personal information that JINS has acquired, including:
name, gender, date of birth, age, address (including postal code), contact information (telephone number, fax number, email address, etc.), member ID and password, company and department to which the person belongs and job title, audio and video that can identify the data subject, records of purchasing the products, and level of eyesight
(2) Scope of joint users
JINS HOLDINGS Inc., and its subsidiaries
(3) Purposes of use
The purposes of use listed in Items 4 (1) through (5) above.
(4) Name, address, representative, etc., of the company responsible for managing personal information
JINS is responsible for the personal information that is to be jointly used. The name, address, and representative of JINS are as provided in Item 1 above.
For more information concerning the joint use, please contact the person in charge as specified in Item 10 below.
7. Provision of personal information to third parties
JINS may provide personal information to a third party after obtaining the prior consent of the data subject.
Moreover, JINS may provide personal information to a third party without obtaining the prior consent of the data subject, in the event of any of the following cases permitted by the laws and regulations:
- when outsourcing the handling of personal information to the extent necessary to achieve the purposes of use;
- when providing personal information to the persons within the scope of the joint users defined in Item 6 (2) above;
- when the provision of personal information is required based on the laws;
- when the provision of personal information is necessary for the protection of the life, health or property of an individual and it is difficult to obtain the consent of the data subject;
- when the provision of personal information is especially necessary for improving public health or promoting the sound development of children and it is difficult to obtain the consent of the data subject;
- when the provision of personal information is necessary for cooperating with a national government agency or local government organization in performing the required duties by the laws and obtaining the consent of the data subject is likely to hinder the performance of the said duties;
- when any academic research institution, etc., needs to handle the personal information for academic research purposes; or
- when due to any succession of business for amalgamation or any other reason.
8. Matters pertaining to security control measures
JINS takes necessary and appropriate security control measures to prevent, etc., the leakage, loss or damage of personal information and for the control thereof. Further, JINS exercises necessary and appropriate supervision over the employees and trustees (including sub-trustees, etc.) who are handling personal information. The main details thereof are as follows:
(Development of rules pertaining to handling of personal information)
- JINS has established “Personal Information Protection Rules” with regard to the method of handling, responsible person, person in charge, duties thereof, etc., in each phase of acquisition, use, storage, provision, deletion and disposal, etc. of personal information.
(Organizational security control measures)
- JINS has established a responsible person for personal information protection with regard to the handling of personal information, specified the scope of employees handling personal information and the scope of the personal information handled by such employees, and developed a reporting and communication system to the responsible person for personal information protection in the event of becoming aware of the fact or likeliness of a violation of the Personal Information Protection Act or Personal Information Protection Rules.
- JINS regularly conducts self-inspection and audits by other departments or by persons outside JINS regarding the personal information handling situation.
(Personal security control measures)
- JINS provides employees with regular training on the matters that require attention with respect to the handling of personal information.
- JINS has included the matters related to confidentiality concerning personal information in our work rules.
(Physical security control measures)
- In the areas where personal information is handled, JINS controls employees’ entrance and exit and restricts the equipment, etc., that can be brought therein, and also takes measures to prevent access to personal information by any unauthorized person.
- JINS takes measures to prevent theft or loss, etc., of equipment, electronic media, documents, etc., with which personal information is handled, and also takes measures to prevent personal information from being easily identified when carrying such equipment, electronic media, etc., including moving within the premises.
(Technical security control measures)
- JINS limits the scope of the personnel in charge and the scope of the personal information database, etc., to be handled by conducting access control.
- JINS has introduced a mechanism to protect the information system within which personal information is handled from unauthorized access or illicit software from outside.
(Understanding of outside environment)
JINS may provide personal information to a third party located in a foreign country (i.e., a country or region outside of Japan) (including outsourcing and joint use).
In such a case, JINS understands the system, etc., pertaining to protection of personal information in the said country and, in the agreement with the said third party, sets forth that: (1) the personal information is handled within the scope of the specified purposes of use; (2) inappropriate use is prohibited; (3) necessary and appropriate security control measures are taken; (4) necessary and appropriate supervision is conducted over the employees; (5) sub-entrustment is prohibited; and (6) the provision of personal data to any other third party is prohibited, etc.
9. Claims for disclosure, etc., of personal information
10. Inquiries pertaining to personal information
Please make contact as set forth below with respect to any question, inquiry, claim for disclosure, etc., in connection with the handling of personal information within JINS:
JINS HOLDINGS Inc. Personal Information Protection Help Desk
11. Collection of access information
12. Personal information of underage persons
Please only provide any personal information of underage persons based on the consent of their legal guardian.
13. Changes and notification