Personal Information Protection Policy

Personal Information Protection Policy

• A　Personal Information Protection Policy


• B　Utilization Purpose of Personal Information


• C　Joint Utilization with NITORI Group Companies and Capital and Business Alliance Companies


• D　Personal Information Inquires


• E　Cookie Policy

A　Personal Information Protection Policy

1．Compliance with Relevant Laws and Guidelines

We pledge to comply with the Act on the Protection of Personal Information in Japan (herein referred to as “Law”) and relevant cabinet or ministerial orders regarding the acquisition or utilization of personal information and other handling of personal information defined by the Law.
A "Principal" in relation to personal information in this Privacy Policy (including relevant rules or procedure referred hereto) means a specific individual identifiable by personal information.

2．Utilization Purpose

We specify the purpose of utilizing personal information (herein referred to as “utilization purpose”) and handle personal information within the necessary scope to achieve the specified purpose. More information on the utilization purpose is referable at 【 Utilization Purpose of Personal Information 】.

3．Altering of Utilization Purpose

We may alter the utilization purpose in the preceding article within the reasonable scope relevant to the pre-altered utilization purpose. In this case, we shall disclose to the public the post-altered utilization purpose on our website and other platforms.

4．Utilizing within the scope of utilization purpose

We handle personal information within the necessary scope to achieve the utilization purpose. In cases beyond the said scope herein, we shall obtain Principal’s consent in advance, except in the following cases;

• (ⅰ)　based on laws and regulations;
• (ⅱ)　there is a need to protect a human life, body or fortune, and when it is difficult to obtain Principal's consent;
• (ⅲ)　there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain Principal's consent; and
• (ⅳ)　there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining Principal's consent would interfere with the performance of said affairs.

5．Proper Acquisition

We shall not acquire personal information by improper means.

6．Special Care-Required Personal Information

If we acquire special care-required personal information, requiring special care as not to cause unfair discrimination, prejudice or other disadvantages to a principal defined in Article 2, paragraph (3) of the Law, we obtain Principal’s consent in advance. However, we may acquire special care-required personal information without prior consent in the following cases:

• (ⅰ)　based on laws and regulations;
• (ⅱ)　there is a need to protect a human life, body or fortune, and when it is difficult to obtain a principal's consent;
• (ⅲ)　there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain a principal's consent;
• (ⅳ)　there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a principal's consent would interfere with the performance of the said affairs;
• (ⅴ)　the said special care-required personal information is opened to the public by an individual, a government organization, a local government, a person set forth in each item of Article 76, paragraph (1), or other persons prescribed by rules of the Law; and
• (ⅵ)　other cases prescribed by cabinet order as equivalent to those cases set forth in each preceding item.

7．Data Accuracy

We keep personal data accurate and up to date within the necessary scope to achieve a utilization purpose. We set a storage period of personal information within the necessary scope to achieve a utilization purpose and pursuant to regulations including, but not limited to, relevant laws or guidelines, and will delete personal information after the storage period has concluded.

8．Security Control

We will take necessary and appropriate security control measures to protect personal data from unauthorized access, falsification, leakage, loss, or damage, including the following.

• (ⅰ)　Organizational safety control measures
  Organizational structure for safety management and reporting, communication system in case of leakage, etc.
  Maintenance of internal rules for the handling of personal data
  Grasping the status of personal data handling through a personal information management ledger
• (ⅱ)　Physical safety control measures
  Control of areas where personal data is handled
  Prevention of leakage when carrying electronic media, etc.
• (ⅲ)　Personnel security control measures
  Regular employee training on the handling of personal data
• (ⅳ)　Technical security control measures
  Access restrictions including identification and authentication of accessors
  Mechanisms to protect against unauthorized external access
• (ⅴ)　Understanding the external environment
  Regularly check foreign personal information protection systems, etc., and implement security control measures.

The names of countries and regions in which we store personal information and their systems for the protection of personal information are as follows．

• United States of America
  systems: https://www.ppc.go.jp/files/pdf/USA_report.pdf
• Canada
  systems: https://www.ppc.go.jp/files/pdf/canada_report.pdf
• Republic of Singapore
  systems: https://www.ppc.go.jp/files/pdf/singapore_report.pdf
• Malaysia
  systems: https://www.ppc.go.jp/files/pdf/malaysia_report.pdf
• Hong Kong
  systems: https://www.ppc.go.jp/files/pdf/hongkong_report.pdf
• Republic of Korea
  systems: https://www.ppc.go.jp/files/pdf/korea_report.pdf

9．Supervision over and auditing employees

We exercise necessary and appropriate supervision over our employees and conduct regular audits to validate security controls of the personal data.

10．Supervision over third parties

We entrust whole or part of the handling of personal data to a third party in regards to delivery, maintenance, or repair services in the scope of the utilization purpose. In this case, we select a third party who can: handle personal information properly, set proper security control, maintains the confidentiality of data, include terms, conditions and other matters regarding handling personal data in an entrust contract, comprehend the situation of said third party and exercise necessary and appropriate supervision over said third party.

11．Provision to Third Parties

In accordance with the law, we may provide personal data to third parties or acquire personal information from third parties as personal data in the following cases and other cases separately stipulated in this Personal Information Protection Policy.
Except in cases where exceptions are provided by law, we will not provide personal data to third parties without the prior consent of the individual.

• (ⅰ)　Based on legal requirements
• (ⅱ)　When it is necessary to protect human life, body, or property, and obtaining the consent of the individual is difficult
• (ⅲ)　When it is particularly necessary for the improvement of public health or the promotion of the healthy upbringing of children, and obtaining the consent of the individual is difficult
• (ⅳ)　When it is necessary to cooperate with a national agency, local public entity, or a person entrusted by them to perform duties stipulated by law, and obtaining the consent of the individual may hinder the performance of such duties
• (ⅴ)　When the third party is an academic research institution, etc., and the third party needs to handle the personal data for academic research purposes (including cases where some of the purposes of handling such personal data are for academic research purposes .excluding cases where there is a risk of unjustly infringing on the rights and interests of individuals).
• (vi)　When it is necessary to prevent unauthorized use, and the entered customer information is provided to third parties, or when analyzing customer information together with information received from third parties regarding unauthorized use
• (vii)　When engaging in joint use as stipulated in the following article

12. Joint Utilization

Each company of NITORI group jointly utilizes personal information within the companies and business alliances of the group. More information on said joint utilization is referable at 【 Joint Utilization with NITORI Group Companies and Business Alliance Companies 】.

13. Provision to a Third Party in a Foreign Country

We, notwithstanding any other provision herein regarding third party provision, will obtain an individual's consent in advance when providing personal information to a third party in a foreign country except in the following cases;

• (ⅰ)　providing to a person establishing a system conforming to standards prescribed by rules of the Personal Information Protection Commission as necessary for continuously taking action equivalent to the one that a personal information handling business operator shall take concerning the handling of personal data;
• (ⅱ)　providing to a person establishing a system conforming to standards, as necessary measure to take equivalent measures continuously that a personal information handling business operator shall take, prescribed by the rule of Personal Information Protection Commission;
• (ⅲ)　based on laws and regulations;
• (ⅳ)　there is a need to protect a human life, body or fortune, and when it is difficult to obtain Principal's consent;
• (ⅴ)　there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain an individual's consent; and
• (ⅵ)　there is a need to cooperate with a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining an individual's consent would interfere with the performance of the said affairs.

14. Use pseudonym information

We create pseudonymized information that is processed in such a way that customers cannot be identified unless it is matched with other information, further analyze and use this information for the purpose of developing new products.

15. Provision of anonymously processed information

When producing anonymously processed information, formulate processing standards pursuant to the standards of the Personal Information Protection Commission and the processing method of accredited personal information protection organization, take security control action of the information of processing methods, and fulfill the obligation to publish anonymously processed information.

【Preparation and Provision of Anonymous Processing Information】

16. Confirmation and keeping record

We confirm and keep records appropriately pursuant to relevant laws and guidelines when exchanging personal data with a third party.

17. Notification, disclosure, correction etc. matters concerning acquired personal data

We respond properly to requests of notification, disclosure, correction etc. for matters concerning acquired personal data under Personal Information Protection Act.
Please see【consultation desk for personal information】for more details on demands above mentioned.

18. Amendment

This Privacy Policy may be altered in the extent to not be contrary to laws and guidelines.

B　Utilization Purpose of Personal Information

1．Utilization purpose

• (1) Utilization purpose:
  • Execution of contracts on our products, management after contract period, and after-sale service implementation
  • To ship products ordered by Nitori Group companies
  • Registration or withdrawal from membership;
  • Inquiries, correspondence to consultation
  • Communication about recall or defective products;
  • Announcement of products, service, campaign;
  • Conducting questionnaire or monitor survey
  • To research and analyze customer preferences using information held by the Nitori Group companies, such as purchase history, website browsing history, footage from security cameras installed in a facility, and location information
  • To distribute advertisements regarding our products and services, investigating or improving product research and development, marketing, sales promotion and various services in accordance with the above results
  • Contacting for business or other meetings;
  • Preventing crime or disaster by security cameras installed in a facility or sound recording machine
  
  
• (2) Shareholder’s Information:
• Exercise rights or fulfillment of obligations;
• Providing benefits from our company to the position as a shareholder;
• Taking measures to facilitate the relationship with shareholders;
• Shareholder administration such as keeping shareholder data pursuant to rules of applicable laws;


• (3) Business Partners Information:
• Execution of contracts
• Contacting for business meetings


• (4) Information on Employees, Recruitment Applicants, Retirees and their families:
  • Business communication, business control, facility management
  • Personnel management such as hiring or assignment decision,other notifications and attendance management, etc.
  • Sending recruitment information and activities
  • Payment of salaries,bonus, welfare benefits, offer, etc.
  • Health management
  • Administer tax or social insurance

2．Exceptions for publication of utilization purpose

We shall not disclose nor state a utilization purpose in the case of the following;

• (1) there is a possibility of harming the life, body, property or other rights and interests of the individual or a third party;
• (2) there is a possibility of harming our rights or legitimate interests;
• (3) it is necessary for a national agency or local public entity to cooperate in carrying out the affairs prescribed by laws and regulations and there is a possibility of interfering with the performance of the affairs; and
• (4) the utilization purpose is obvious from the situation of acquiring personal information.

C　Joint Utilization with NITORI Group Companies and Capital and Business Alliance Companies

1．Joint utilization of personal data

Nitori group jointly utilizes personal data handled in each of the companies of NITORI group and capital and business alliances in order to provide high value services for parties concerned. Nevertheless, in case of a change in the scope of joint users or the responsible official for controlling joint utilization, the individual will be informed in advance or we will create a method so that the individual could easily access said information.

(1) Joint Utilization Items

Name, address, date of birth, telephone number, fax number, e-mail address, purchase (cancellation) history, usage history of member cards, coupon usage history, footage from security cameras installed in a facility, and provision or inquiry contents.
※Excluding special care-required personal information provided to NITORI Facility Co., Ltd. in purchasing insurance products.

(2) Scope of joint users

＜Nitori Group Companies＞
＜Capital and Business Alliance Companies＞
※A capital and business alliance company is a company in which the Company has made a certain amount of investment and has started a business alliance. The capital and business alliance companies may change.

• KATITAS Co., Ltd.
• REPRICE Co.,Ltd.

(3) Utilization Purpose

• Shipments provided by Nitori group
• Taking over after-sales service etc.
• Notice of new products information
• Market research or data analysis for product development, etc.
• Notice about events of Nitori group or business partners
• To research and analyze customer preferences (including cases conducted through footage from cameras installed in the facility.), etc.
• To distribute advertisements, information, and suggestions regarding the products and services of Nitori Group companies and business partners, and to conduct research and improvement regarding products, marketing, sales promotion, and various services in accordance with the above results

(4) Responsible Official for Joint Utilization

Nitori Holdings Co., Ltd.
1-2-39, Shinkotoni 7jo, Kita-ku, Sapporo, Hokkaido
Representative Director & President
Toshiyuki Shirai

(5) Contact us

Nitori Holdings Co., Ltd., Nitori Co., Ltd., Ltd., Home Logistics Co., Ltd., NITORI FURNITURE Co., Ltd., HOME DECO CO., LTD.:
Customer Service Office 【Personal Information Inquiry Desk】

Nitori Facility Co., Ltd.:
03-6741-1411

Nitori Public Co., Ltd.:
General Affairs & Accounting Division 011-717-5020

KATITAS Co., Ltd. :
General Affairs 0277-20-7400

REPRICE Co.,Ltd. :
General Affairs 052-228-8205

2．Joint utilization of pseudonym information

Nitori Group joint utilization pseudonymized information as follows

(1) Joint Utilization Items

• Address
• Purchase (cancellation) history

(2) Scope of Joint Users

Same as 1.(2) Scope of joint users above

(3) Utilization Purpose

Analysis for the development of new products and services at Nitori Group companies

(4) Responsible Official for Joint Utilization of Pseudonym Information

Same as 1.(4) Responsible Official for Joint Utilization

D　Personal Information Inquires

1．Opinions and Consultation

If you have any opinions or require consultation about our handling of personal information, please contact the Personal Information Inquiry Desk below.

2．How to Demand Disclosure of Personal Data

(1) Demand

Please contact the inquiry desk, and we will provide the necessary documents (identity verification documents, documents that can be confirmed as an proxy in case demanded, etc.) .

(2) Response to Demand

We will respond in writing to the individual or proxy regarding the disclosure demand after we conduct confirmation and/or investigation of the contents. Nevertheless, we may refrain to disclose the information in cases which there is the possibility of harming a life, body, property, rights or interests of the individual of a third party by disclosure.

3．Personal Information Inquiry Desk

NITORI Customer Service (business hours: 10:00-20:00)
Fixed-line phone: 0120-014-210 (toll-free)
Mobile phone: 0570-064-210 (navigation dial)

• Note: If you call from a mobile phone, you will be charged around 10 yen per 20 seconds.
• Note: You are able to use the toll-free number from certain IP phones.

E　Cookie Policy

1．Use of Cookie

Cookie is information that is saved in the browser when you visit a site. The website and services managed by NITORI Group use Cookie to make the website more convenient for customers and to improve the website continuously. (Personal information is not included in Cookie.) In addition, NITORI Group uses cookies and other device identifiers to collect information about you (user information) and transmit it to external entities. If you agree to this Personal Information Protection Policy, we may obtain the browsing history of websites collected by cookies from data management platforms operated by third parties and the results of their analysis, and use them in conjunction with your personal data.

2．Purpose of use

• To improve customer convenience by simplifying entry
• For displaying information of interest to customers
• To improve NITORI Group's website and services

3．List of external recipients

Please see below for details regarding the names of external entities and services, the contents of user information sent to external entities, and the purpose of use of the information sent.

4．How to disable Cookies

1. How to Disable All Cookies
   You can disable Cookie by changing the browser settings. In this case, some of the features of some websites may be unavailable, some pages may not be displayed correctly, and or some of our services may not be available. If you want to change the browser settings, check with the manufacturer of each browser.
2. How to disable a particular Cookie
   By disabling (opt-out) Cookie from each company's opt-out page, customers can stop using the identifiers and customer attributes we grant to this site by NITORI Group. In this case, the products and services provided by each company may not be accessible.

5．About Google Analytics

The website managed by NITORI Group uses Google Analytics, an Google access analysis tool, to continuously improve this site. Google Analytics uses Cookie to collect data. This data is collected anonymously and does not identify individuals. This feature can be rejected by disabling Cookie. To disable Cookies check your browser settings. For information about how data is collected and processed by Google Analytics, see "GOOGLE use of information collected from sites and applications using GOOGLE services".

The forecasts and projected operating results contained in this report are based on information available at the time of preparation, and thus involve inherent risks and uncertainties.
Accordingly, readers are cautioned that actual results may differ materially from those projected as a result of a variety of factors.