Privacy Policy

Chapter 1. Information defined in this Privacy Policy

Out of the information you provide to the Company, this Privacy Policy provides for the handling of "Specific Personal Information" as defined in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of May 31, 2013) (the "the Numbers Act"), "Personal Information" defined in the Act on the Protection of Personal Information (Act No. 57 of May 30, 2013) (the "Personal Information Protection Act") (excluding any information that falls under Specific Personal Information), and any information which does not fall under Personal Information but could have an effect on your privacy depending on the manner of handling (the "Informative Data").
Handling of "Specific Personal Information" is provided for in "Chapter 2. Handling of Specific Personal Information" Since "Specific Personal Information" can also fall under "Personal Information", the provisions of Chapter 3 will apply to the extent that those provisions are not inconsistent nor in conflict with the provisions of Chapter 2.
Handling of "Personal Information" is provided in "Chapter 3. Handling of Personal Information".
Handling of "Informative Data" is provided for in "Chapter 4. Handling of Informative Data".

Chapter 2. Handling of Specific Personal Information

1. Compliance regarding handling of Specific Personal Information
   When handling Specific Personal Information, the Company will comply with the laws and regulations, guidelines and other rules regarding the handling of Specific Personal Information established by the government.
2. The purposes for which Specific Personal Information is used
   The Company will use any Specific Personal Information it acquires solely for the purpose of Handles Related to Individual Numbers stipulated in the Numbers Act, which includes handles related to withholding, individual inhabitants tax (jumin zei), workers' compensation and unemployment insurance, social insurance, national pension (kokumin nenkin) Class III insured, and preparation of report of payment (shiharai chosho).
3. Provide to and jointly utilizing with third parties
   Except as stipulated in the Numbers Act, the Company will not disclose Specific Personal Information to, nor jointly utilize Specific Personal Information with, any third party.
   Further, if the Company outsources the handling of Specific Personal Information to a third party, the Company will make efforts to properly manage such outsourced service provider, such as by entering into a contract with such outsourced service provider relating to the handling of Specific Personal Information.
4. Security measures for Specific Personal Information
   The Company will take due security measures so as to prevent Specific Personal Information from being divulged, lost or damaged (including loss, destruction, manipulation and so forth). The Company will also make efforts to review the security measures on an ongoing basis, and correct and improve them.
5. Contact point for complaints and consultations
   For any complaints or consultations regarding Specific Personal Information handled by the Company, please make inquiries to "9. Contact point for Disclosure, Complaints and consultation on Personal Information" of Chapter 3.

Chapter 3. Handling of Personal Information

1. Compliance with laws and regulations regarding handling of Personal Information
   When handling Personal Information, the Company will comply with the laws and regulations, guidelines and other rules regarding the handling of Personal Information established by the government.
   When handling Personal Information, the Company will establish and comply with a Personal Information Protection Management System conforming to Japanese Industrial Standards (JIS Q 15001 "Personal information protection management systems – Requirements").
2. Personal Information to be acquired and the purposes for which it is used
   The Company will acquire Personal Information specified in Schedule and use the same within the respective purposes for which it should be used. Any other Personal Information will be acquired respectively upon specifying or providing notification of the purposes for which it is used or making a public announcement thereof. The Company will make efforts to acquire Personal Information to the minimum extent necessary by selecting Personal Information to be acquired in each case.
3. Policy on the use of Personal Information and provide to and jointly utilizing with third parties
   • (1) Use within the scope of the purposes for which it should be used
     The Company, when handling Personal Information, will specify the purpose for which it is used as explicitly as possible, and will not handle the same beyond the scope necessary for achieving the specified purposes for which it is used (nor use the same for any other purpose other than the specified purposes for which it should be used). In the case of use for any other purpose other than the specified purposes for which it should be used, the Company will notify you in advance, and obtain your consent.
     The Company will not alter the purposes for which it is used so that they exceed the scope which is considered reasonably as relevant to the specified purposes for which it should be used. Further, if the Company alters the specified purposes for which it is used, the Company will notify you or make a public announcement of the purposes so altered for which it is used.
   • (2) Provide to and jointly utilizing with third parties
     If the Company discloses Personal Information to a third party or jointly utilizes the same with a third party, it will do so duly in accordance with the laws and regulations, guidelines and other rules regarding the handling of Personal Information established by the government, after evaluating the degree of effect to the privacy of the individuals concerned in light of the type of such Personal Information, the method of obtaining consent, how such Personal Information is used and so on. Additionally, if the Company outsources the handling of the Personal Information to a third party, the Company will make efforts to properly manage the third party, such as by entering into a contract with such outsourced service provider relating to the handling of Personal Information.
     DIGITAL HOLDINGS Group including the Company (meaning DIGITAL HOLDINGS, INC. and its affiliates (kankei gaisha) (as defined in Article 8, paragraph 8 of the Regulation on Terminology, Forms, and Preparation Methods of Financial Statements) (Collectively "DIGITAL HOLDINGS Group") may jointly utilize Personal Information as set out in Schedule to the extent necessary to achieve the purposes for which it is used.
4. Voluntary provide
   Your provide of Personal Information to the Company is voluntary. However, if you choose not to disclose Personal Information, some of the services of the Company may not be provided to you (in the case of Personal Information regarding employees and so forth as described in Schedule, including cases where the employment management and other aspects of employment are constrained).
5. Security of Personal Information
   As part of the security measures for Personal Information, the Company shall provide education to all the directors and officers as well as employees (as defined in Schedule), and strictly manage Personal Information in order to keep the same accurate and up-to-date, and to prevent unauthorized access to Personal Information and prevent Personal Information from being divulged, lost or damage (including loss, destruction and manipulation and so forth). The Company will also make efforts to review the security measures on an ongoing basis, and correct and improve them.
6. Provide related to Personal Information
   To the extent protected under the Personal Information Protection Act, you may request that we (i) notify you of the purposes for which your Personal Information is used, (ii) disclose your Personal Information, (iii) correct your Personal Information, (iv) add to your Personal Information, (v) remove your Personal Information, (vi) cease the use of your Personal Information, or (vii) erase your Personal Information (those actions, Collectively "Provide") The procedures for Provide are as follows:
   • (1) You need to fill in the prescribed sections of the notification form prescribed by the Company and submit it in writing.
   • (2) The Company may ask for your identity in the manner determined by it.
   • (3) Any expenses of submitting that notification form shall be borne by you.
   • (4) The Company may impose charges prescribed by it in certain cases.
   • (5) The Company will respond to your request via e-mail at your designated e-mail address
   • (6) For the details of how we accept requests for Provides, please make inquiries to the Contact Point for Provide, Complaints and Consultations specified at the end of this Chapter.
7. On-going Improvement of Personal Information Protection Management System
   The Company will make efforts to maintain proper protection of Personal Information by improving the Personal Information Protection Management System on an on-going basis in accordance with the needs of the time, taking into account the audit reports and reports on operation, opinions from outside such as complaints and consultations and so forth, changes in laws and regulations, guidelines and any other rules regarding handling of Personal Information established by the government, changes in social conditions and public awareness, changes in various environments including, changes in the business domain and management of the Company, and proposals for improvement from inside and outside.
8. Personal Information Protection Manager
   DIGITAL HOLDINGS, INC. Representative Director, Atsushi Nouchi
9. Contact point for Disclosure, Complaints and consultation on Personal Information
   For requests for Disclosure, complaints and consultations on Personal Information handled by the Company, please direct your inquiries to the following contact point.

Contact Point for Disclosure, Complaints and Consultations

DIGITAL HOLDINGS, INC.
Location: Tokyu Bancho Bldg., 6 Yonbancho, Chiyoda-ku, Tokyo, Japan, 102-0081
E-mail address: privacy@digital-holdings.co.jp
(Open hours: 10:00 to 17:00 excluding Saturdays, Sundays, national holidays and year-end and New Year holidays)

Chapter 4. Handling of Informative Data

1. Informative Data to be acquired and the purposes for which it is used
   In certain cases, the Company may acquire Informative Data as listed in (1) through (4) below for the purpose of operation, provision and improvement of each of the services, and development of new services when you use each of the services through the website and applications operated by the Company or the products, tools and other services offered by the Company. When providing each of the services, the Company will make efforts to acquire information to the minimum extent necessary by choosing which Informative Data to be acquired.
   • (1) Terminal Identifying Information*;
   • (2) Information on the terminal, OS, browser and so forth you use for browsing the Internet or using applications;
   • (3) History of your activities through the Internet or on applications;
   • (4) Any other information to be acquired together with (1) through (3) above.
     * Any reference in this Privacy Policy to "Terminal Identifying Information" is a reference to "Cookie ID", "IDFA", "Advertising ID" and so forth which are normally and generally used for providing each of the services.
2. Policy on the use of Informative Data and provide to and jointly utilizing with third parties
   • (1) Use within the scope of the purposes for which it should be used
     The Company, when handling Informative Data, will specify the purposes for which it is used as explicitly as possible, and will not handle Informative Data beyond the scope necessary for achieving the specified purposes for which it is used.
     The Company will not alter the purposes for which Informative Data should be used so that they exceed the scope recognized as reasonably relevant to the specified purposes for which it should be used. Further, if the Company alters the specified purposes for which it is used, it will notify you or make a public announcement of the purposes so altered for which it is used.
   • (2) Provide to and jointly utilizing with third parties
     If the Company discloses Informative Data to or jointly utilizes the same with any third party, it will do so properly in accordance with the laws and regulations, guidelines and other rules established by the government regarding the handling of Informative Data, after evaluating the degree of effect to the privacy of the individuals concerned in light of the type of such information, the method of obtaining consent, how such information is used and so forth.
3. Security of Informative Data
   The Company will take due security measures in light of the importance of Informative Data.

Chapter 5. Other Matters

1. If the Company establishes terms of use, a privacy policy and so forth for each of the services it provides, such terms of use or privacy policy for each of the services shall prevail.
2. This Privacy Policy is interpreted in accordance with its Japanese version. If this Privacy Policy is translated into any other language, and there is any inconsistency between the Japanese version of this Privacy Policy and the version of such other language, then the Japanese version shall prevail in all respects.
3. Some of the websites operated by the Company use cookies, and the Company also uses the services provided by the third party specified below for analyzing access to and use of such websites, and for posting information, including advertisements, suitable for you. If you want, you may cease or disable the functions related to cookies in your browser, but as a result of such suspension or disabling, some parts of such websites may not function normally. Regarding the setting of your browser, please make inquiries to the provider of the relevant browser. For explanations regarding the use of cookies, information to be acquired by cookies and the procedures for opt-out with respect to the service specified below, please visit the URL specified below.
   ・Google Analytics
   https://support.google.com/analytics/answer/6004245
4. The Company may amend this Privacy Policy as necessary. This Privacy Policy so amended will apply at the time the Company posts the same on its website.

Established November 14, 2003
Amended July 1, 2020

Schedule

1. Handling of Personal Information of customers
   The Company will use the Personal Information relating to customers and so forth within the scope necessary to achieve the purposes below:

   [Personal Information to be acquired and the purposes for which it is used]

   Item	Specific description	Purposes for which it is used
   Information relating to customers	Names, addresses, telephone numbers, employers, email addresses, positions at employers, information stated in each identity verification documents, account information, information relating to payments and invoices, other information required for the applicable transactions.	For entering into contracts for the applicable transactions, registering customers, processing of payments and invoices, and other communications. For providing information related to other services, seminars, events and so forth.
   Information acquired from members, users and so forth through the websites and services which the Company operates	Names, addresses, email addresses, telephone numbers, sex, dates of birth, occupations, employers (schools), addresses of employers (schools), positions at employers, photographs of faces and other images, account information, information stated in each identity verification documents, information stated on health insurance cards, IP addresses, account IDs, location information, nicknames, information enabling individual identification, Terminal Identifying Information, purchase data and so forth.	For operation and improvement of [the Company’s] websites and services. For providing information related to other services, seminars, events and so forth.
   Information acquired from inquiries and so forth you make to the Company	Names, addresses, email addresses, telephone numbers, sex, dates of birth, occupations, employers (schools), addresses of employers (schools), positions at employers, details and history of your inquiries and so forth.	For responding to inquiries.
   Information acquired at seminars, events, surveys and so forth sponsored by or conducted by the Company	Names, addresses, occupations, employers (schools), email addresses, telephone numbers, positions at employers, information related to application for attending events, and survey responses and so forth.	For operating and improving seminars, events and so forth. For improvement of products and services through collection and analysis of responses to surveys. For providing information related to other services, seminars, events and so forth.
   Information acquired from third parties	Names, addresses, email addresses, telephone numbers, sex, dates of birth, employers (schools), addresses of employers (schools), positions at employers, IP addresses, account IDs, location information, nicknames, photographs of faces and other images, information enabling individual identification, customer IDs held by customers, purchase data and so forth.	For carrying out operations such as providing information and so forth generated based on investigation, analysis, user attributes and behavior history.

   [Jointly utilizing]
   In certain cases, the Company may jointly utilize Personal Information described in this paragraph as follows:

   • (1)Parties with which the Company jointly utilizes Personal Information
     DIGITAL HOLDINGS Group companies
   • (2)Purposes of jointly utilizing
     Same as the purposes for which it is used as stated above.
   • (3)Subject Personal Information
     Information produced by combining the above-stated Subject Personal Information and Informative Data relating to the relevant individuals.
   • (4)Personal Information protection manager for the combined data to be jointly utilized
     Personal Information protection manager for DIGITAL HOLDINGS, INC.
2. Handling of Shareholders’ Personal Information
   The Company, in order for shareholders to exercise their rights under the Companies Act, for the Company to perform its obligations under the Companies Act and other related laws and regulations, and for the Company to smoothly carry out its business, will use the personal information of its shareholders to the extent necessary to achieve the following purposes for which it is used.

   [Personal Information to be acquired and the purposes for which it is used]

   Item	Specific description	Purposes for which it is used
   Shareholders' information	Names, addresses, dates of birth, sex, telephone numbers, occupations, employers, email addresses, account numbers, details and history of proposals and inquiries, the number of shares held, and other information acquired in the course of the operation relating to the shares held by relevant shareholders.	For the operation related to the exercise of the rights and performance of the obligations of the shareholders under law, disclosure of information disclosure and implementation of various measures related to investor relations, preparation of shareholders' data in accordance with laws and regulations and other matters relating to management of shareholders.

3. Handling of Personal Information of Employees
   The Company handles the Personal Information of its directors and officers, and employees (meaning permanent employees, contract employees, employees seconded to the Company, part-time employees and temporary employees) (hereinafter, collectively "employees"), persons who seek or sought to become directors, officers or employees of the Company (“Applicants for Employment”), and the retired (collectively, “Personal Information of Employees”) as follows.

   [Personal Information to be acquired and the purposes for which it is used]
   (1) Personal Information of the Company's directors and officers, and employees

   Item	Specific description	Purposes for which it is used
   Information disclosed internally	Information on names, employee numbers, departments, positions, forms of employment, photographs of faces, employment start dates, positions held, employee email addresses, and mobile terminals used for work (including telephone numbers) and so forth.	For work-related communications.
   Basic information	Names, addresses, ages, dates of birth, employment start dates, sex, telephone numbers, photographs of faces and so forth.	For employment and personnel management, assignments (including secondments and transfers), preparation of company directories, payment of salaries and so forth, provision of employee benefits, procedures related to social insurance, various legally required procedures, and other employment management.
   Wage-related information	Annual income, monthly income, bonus and so forth, salary determination method and so forth, retirement allowances, account numbers, pensions, information related to social insurance and so forth.	For determining and paying salary and so forth, procedures for withholding taxes, procedures related to social insurance, retirement allowances and employee benefits, employees’ savings scheme, and other employment management.
   Information acquired at seminars, events, surveys and so forth sponsored by or conducted by the Company	Names, addresses, occupations, employers (schools), email addresses, telephone numbers, positions at employers, information related to application for attending events, and survey responses and so forth.	For operating and improving seminars, events and so forth. For improvement of products and services through collection and analysis of responses to surveys. For providing information related to other services, seminars, events and so forth.
   Personnel information	Job evaluation, educational backgrounds, qualifications, licenses, positions, work experience, training received and provided, disciplinary history and awards, and so forth.	For understanding human resources, determining departments and jobs, and secondments and transfers, training and human resources development, promotions and demotions, and other employment management.
   Information related to family members and relatives	Family structures, whether living together or apart, presence or absence of dependents, health status and so forth.	For determining salary and so forth, procedures for withholding taxes, procedures related to social insurance, parental leave, family-care leave and other leave, employee benefits, and other employment management.
   Information related to bodies and health	Health status, medical history, physical and mental disorders, results of medical checkups and so forth.	For health management, ensuring a proper work environment, leave of absence and so forth, determining departments, managing working hours, and other employment management.
   Information related to work	Attendance information, records of entering and leaving the workplaces, records of PC operations, records of operations on mobile phones used for work, records of use of network within the Company, records of location within the Company, records of security cameras and so forth.	For managing working hours, work-related communications, for ensuring a proper work environment, improvement of labor efficiency, and other employment management.

   (2) Personal Information of Applicants for Employment

   Item	Specific description	Purposes for which it is used
   Basic information	Names, addresses, ages, dates of birth, sex, telephone numbers, photographs of faces and so forth.	For Pre-hire assessment and determination of employment, assessment and decisions of the conditions of employment, responding to inquiries, and administrative communications.
   Wage-related information	Annual income, monthly income, bonus and so forth, salary determination method and so forth.
   Personnel information	Educational backgrounds, qualifications, licenses, positions, work experience and so forth.
   Information related to family members and relatives	Presence or absence of dependents and so forth.

   (3) Personal Information of the Retired

   Item	Specific description	Purposes for which it is used
   Basic information	Names, addresses, ages, dates of birth, sex, telephone numbers, photographs of faces and so forth.	For procedures for withholding taxes, procedures related to social insurance, retirement allowances and employee benefits, employee savings scheme, and other matters relating to employment management, administrative communications and so on.
   Wage-related information	Annual income, monthly income, bonus and so forth, salary determination method and so forth, retirement allowances, account numbers, pensions, information related to social insurance and so forth.
   Personnel information	Performance ratings, educational backgrounds, qualifications, licenses, positions, work experience, disciplinary history and awards, and so forth.
   Information related to family members and relatives	Family structures, whether living together or apart, and so forth.
   Information related to bodies and health	Health status, medical history, physical and mental disorders, results of medical checkups and so forth.

   [Jointly utilizing]
   The Company will jointly utilize Personal Information in this paragraph in accordance with the purposes of use stated below.

   1. Jointly utilizing for work-related communications
      • (1)Parties with which the Company jointly utilizes Personal Information
        DIGITAL HOLDINGS Group companies
      • (2)Purposes of jointly utilizing
        For work-related communications
      • (3)Subject Personal Information
        Information disclosed internally as listed in paragraph (1) of “Personal Information to be acquired and the purposes for which it is used” above.
      • (4)Personal Information protection manager for the combined data to be jointly utilized
        The head of the personnel department of DIGITAL HOLDINGS, INC.
        Provided, however, that the Personal Information protection manager for the Personal Information of Employees held by SoldOut, Inc and its subsidiaries is the head of the personnel department of SoldOut, Inc.
   2. Jointly utilizing for business operations
      • (1) Parties with which the Company jointly utilizes Personal Information
        DIGITAL HOLDINGS Group companies, companies that have executed secondment contracts with the Company, society-managed health insurance (kenko hoken kumiai), and companies handling employee benefits.
      • (2) Purposes of jointly utilizing
        For employment management, employee benefits, and supporting services necessary for business.
      • (3) Subject Personal Information
        Among Personal Information of Employees listed in paragraphs (1) through (3) of "Information to be acquired and purposes for which it is used" above, those items necessary for achieving the purposes of jointly utilizing.
      • (4) Personal Information protection manager for the combined data to be jointly utilized
        The head of the personnel department of DIGITAL HOLDINGS, INC.
        Provided, however, that the Personal Information protection manager for the Personal Information of Employees held by SoldOut, Inc and its subsidiaries is the head of the personnel department of SoldOut, Inc.

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