These Policy Guidelines shall apply to all personal information handled by the Group.
2. Legal compliance
The Group shall comply with laws, governmental ordinances, national guidelines and other regulations regarding the handling of personal information.
The Group shall process personal information based on one of the following legal bases:
The Group has obtained the consent of the information subject or has communicated required matters to the information subject in accordance with applicable laws and regulations.
The processing is necessary to perform the obligations under the contract with the information subject.
The processing is necessary for the group to fulfil its legal obligations.
The processing is necessary to secure legitimate interests pursued by the Group.
3. Internal structures
The Group has put in place internal structures to facilitate the management of personal information, including by forming a department to oversee the protection of personal information and by assigning supervisors responsible for managing personal information in each of its departments.
4. Use of personal information
Whenever using personal information, the Group shall define the purpose of use of personal information and restrict the use of information to the scope necessary to achieve that purpose.
The Group may provide personal information to a website design company in accordance with the GDPR for the purposes separately defined.
In such a case, The Group will transfer personal data based on EU-Japan adequacy decisions (Article 45 of GDPR) .
The Group shall store personal information for the period necessary for achieving the purposes.
5. Acquisition of personal information
The Group shall acquire personal information using lawful and appropriate means.
The Group shall take appropriate measures to ensure that the personal information in its possession is accurate and up-to-date.
The Group shall take necessary and appropriate measures to ensure the integrity of the personal information in its possession so as to prevent unauthorized access, loss, destruction, alteration, improper disclosure, or other misuse.
8. Supervision of subcontractors
When outsourcing the handling of personal information, the Group shall implement the necessary and appropriate supervision to ensure contractors manage personal information safely.
9. Taking actions on the rights of individuals
The Group shall take appropriate actions on the information subject’s requests on the processing of personal information concerning him or her in accordance with applicable laws and regulations. The requests of the information subject shall include:
Access to the personal information
Rectification or erasure of the personal information
Restriction on the processing of the personal information
Lodging a complaint against the processing of the personal information
The information subject may lodge a complaint with the supervisory authority.
Data portability of the personal information
Withdrawal of consent on the processing of the personal information
Contest against the processing of the personal information
10. Inquiries concerning personal information
Inquiries concerning personal information shall be accepted and processed by the following contact point.
<Contact（EEA and UK residents）>
As the Group is based outside of the EU/UK, Article 27 GDPR/UK GDPR required that the Group appoints an EU representative/UK representative to handle certain data subject requests and queries. In compliance with this, the Group has appointed DataRep to act as its representative. Any queries requiring the input of its representative, should please be directed to them as follows:
contacting us on its online webform at https://www.datarep.com/data-request, or mailing your inquiry to this address:
DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom
PLEASE NOTE: when mailing inquiries, it is ESSENTIAL that you mark your letters for ′DataRep′ and not ′Hankyu Hanshin Holdings′, or your inquiry may not reach us. Please refer clearly to Hankyu Hanshin Holdings in your correspondence.
<Contact Point of Data Controller（Non EEA and UK residents）>
Group Planning Division, Public Relations Dept. Hankyu Hanshin Holdings, Inc.
Phone : +81-6-6373-5004
Office hours: 9:00 to 17:50, Japan Standard Time (closed on Saturday, Sunday, New Year holidays, Golden Week, and other public holidays)
11. Ongoing improvements
The Group shall conduct periodic audits and review and improve its internal guidelines and structures on an ongoing basis to ensure that personal information is appropriately protected.
A cookie is a small text file that the website sends to your device for the purpose of keeping records. It identifies your device, typically your web browser, but it cannot directly identify you.
Some cookies are necessary to operate our website (e.g. for establishing and keeping sessions), while other cookies may be used for the following purposes:
-Improving website functionality;
-Collecting analytical data to improve website performance;
-Delivering advertisements that may be of interest to you from us or our advertising partners based on information collected by tracking users across the internet;
Where the Group is required by applicable privacy/data protection laws, you can choose whether to allow us or third-parties (e.g. its analytics, advertising and social media partners) to set cookies which are not strictly necessary for the functioning of the website via the cookie banner or cookie settings interface provided on the website.
About Google Analytics
In order to improve the website, the Group uses “Google Analytics” to collect browsing information on its websites .When a user accesses a website using a browser, these services collect and process information(the software, the device, and the country of citizenship of users) by using cookies.
The legal ground to process user’s data for the use of Google Analytics is user’s consent.
* Please refer to the following websites for explanations on the terms of service for each service.
Google Analytics Terms of Service
Platforms program policies