1. Commitment to Ensuring the Security of Personal Information
- Komaden Corporation (“the Company”) only collects, uses, and discloses personal information for the specific purposes it has explicitly declared.
- The Company has designated Confidential Information Protection Administrators under the leadership of a Representative Director to oversee the handling of personal information and has established a system under which every employee is responsible for protecting personal information.
- The Company exercises the utmost care in managing any personal information it has obtained during the course of business and complies with all legal and regulatory mandates, including the Personal Information Protection Law and JISQ15001 (requirements for protecting personal information). The Company’s system has been established in accordance with security directives issued by related ministries and authorities in Japan.
- The Company has taken steps to prevent unauthorized access to personal information as well as the loss, destruction, falsification, or leakage of such data and is prepared to respond to any such occurrences.
- The Company defines personal information, in principle, as any information that includes an individual’s name and at least one other piece of additional data that identifies the individual, that is, any personally identifying information included with the individual’s name is treated as personal information.
- The Company continues to improve the effectiveness of its compliance program and to enhance its information management system to ensure the security of personal information.
2. Personal Information Collected and Used by the Company
- Personal information associated with the Company’s customers or any third party that the Company has obtained in the course of doing business.
- Personal information that the Company has obtained or collected from customers in connection with the Company’s business operations, including outsourced services provided by event management agencies.
- Personal information associated with the employees of the Company and its affiliates.
3. Personal Information Management Training
- The Company provides training at least once a year to ensure that employees are fully aware of and comply with the Company’s personal information management system.
- Contractual agreements between the Company and business partners incorporate provisions requiring the protection of personal information. The Company ensures that business partners provide training in personal information management at Safety and Health Cooperation Meetings or other appropriate occasions.
4. Handling of Personal Information
- The Company uses or discloses personal information only as agreed upon by the customer and does not share or disclose such information to any third party for any other purpose.
- The Company exercises the utmost care in handling personal information.
- The Company obtains the explicit cooperation from all parties handling the Company’s personal information through appropriate memoranda, agreements or other documentation that provide for the handling of personal information.
- The Company appoints employees to oversee the management of personal information and designates a clear line of authority in the corporate organizational chart for any entity required to ensure the effective management of personal information.
- If the Company has agreed in advance to return personal information to a customer, it will also destroy any other copies or reproductions of such data upon returning the original information.
- Individuals who wish to ensure the complete removal of personal information should contact the related staff in charge prior to providing such information.
- The Company makes every effort to implement appropriate adjustments to ensure its personal information management system effectively aligns with any personal information policy designed and implemented by specific customers.
- In principle, the Company responds promptly to customer requests to disclose, correct, delete, use, or refuse the provision of personal information as well as to provide information on the use of the information by the Company.
5. Response to Potential Violations of This Policy
- The Company uses and shares personal information solely for the purposes agreed upon by the customer. The Company does not provide or disclose any personal information to any third party for any other purpose.
- The Investigation Committee discloses the results of any investigations into potential violations of this policy.
- Upon request, the Investigation Committee discloses documents and information required by customers.
6. Personal Information Management System Access
- The Company maintains public access to its Privacy Policy.
- The Company promptly and without delay discloses any change in its organizational structural related to protecting personal information as well as any changes in the provisions of this Privacy Policy, including information on the differences between previous and current provisions.
