Japanet Holdings Co., Ltd.
Akito Takata President & CEO

Basic Policy on Protection of Personal Information

Japanet Holdings Co., Ltd. and its group companies (“we”, “us” or “our”) are aiming to satisfy our customers through our mail-order service.
In order to achieve our foregoing objective, your personal information is absolutely essential and corresponds to our important information assets.
We are positioning the protection of personal information as a top priority issue in our business operation so our customers can enjoy our mail-order service with a sense of security, and are constantly aware of our responsibility and taking measures to protect your personal information. We have therefore established this Basic Policy on Protection of Personal Information (hereinafter referred to as “this Basic Policy”), and all of our employees (officers, executive officers, regular employees, contract employees, part-time employees, temporary employees, dispatched employees), employees permanently stationed in our business partners, and our other related persons will observe this Basic Policy and endeavor to protect your personal information.

1. We will securely handle your personal information under the supervision of our personal information protection administrator.
2. We will ask you to provide your personal information only after you have understood our purpose and intent of acquiring your personal information, and will appropriately manage and protect the provided personal information.
3. We will not use your personal information for any purpose other than the purposes for which you have understood.
4. We will implement appropriate measures against any unauthorized access, leakage, loss, destruction or falsification of your personal information, and take preventive and corrective action.
5. We will strictly and promptly respond to your inquiries concerning your personal information and your request for changing or deleting your personal information.
6. We will conduct enlightenment activities and offer internal training to all employees for observing personal information-related laws and regulations and other rules.
7. We will make this Basic Policy available to you at all times by posting it on our website, catalogue and corporate brochure.
8. We will observe personal information protection-related laws and other social norms, and endeavor to continuously maintain and improve our personal information protection measures.
9. We will review this Basic Policy as needed when any relevant laws are formulated or revised or when there are any changes to our management environment or business description, and thereby endeavor to maintain and improve this Basic Policy.

○ For information on the handling of personal data within the EEA, please see “Basic Policy on Handling of Personal Data within EEA”.

Handling of Personal Information

We will handle your personal information in the following manner.

1.　What is “personal information”?

We define “personal information” as follows.
“Information relating to an individual which can identify the individual by name, date of birth, address, phone number, occupation or other description or a number, code or other symbol linked to each individual, or image or voice (including any information that can be easily collated with other information thereby used to identify that specific individual).”
Specifically, the following information:

1. Personal information collected from toll-free calls, FAX, postcards, Internet, email, etc.
2. Personal information collected from various campaign applications and survey answers
3. Personal information collected from official records acquired by the company and public/private certificates that you submitted
4. Personal information which became known in the course of conducting transactions with you or offering after-sales services to you, such as your purchase history and status of use of products
5. Personal information collected from entry sheets and resumes collected in the recruitment process

2.　Purpose of use of personal information

We will notify or publicly announced your personal information according to the manner of acquisition and use. Specifically, we will use your personal information for the following purposes.

1. To deliver or install ordered products, provide requested services, and send direct mails and catalogs of provided products and services
2. To provide explanations on how to use products in response to inquiries before purchase of products and in after-sales services after purchase of products, and provide information related to returns, exchanges, repairs and products
3. For member registration, email magazines and auctions offered on our website and mobile site
4. To collect surveys, notify campaigns and sweepstakes and their winners, and send prizes
5. For credit judgment for shopping credit payment or credit card payment, payment of product prices and shipping costs for returns at your request, credit management (reminder work) and prevention of unauthorized use
6. To create statistical data, which is processed so that individuals cannot be recognized or identified, based on your purchase history, survey, gender, age and other attribute information, and use such data for developing and providing new products and services
7. To confirm the caller based on the caller’s phone number notified based on the caller information notification service (Number Display or other phone number display service), and use it as a part of the identity verification process
8. To record phone conversations with you and confirm the purchased product or the details of your inquiry, and thereby enhance or improve our phone services to you
9. To provide information related to recruitment and make hiring decisions (personal information related to recruitment will not be used for sending direct mails of products and services)
10. To provide information for monitor participation and explanation of the relevant product, and contact you to confirm your intent upon participating as a monitor
11. To verify your identity upon accepting your order
12. If you have applied for the hometown tax donation program, to confirm the details of your application, respond to your inquiries, send pamphlets and documents on how to utilize the hometown tax donation program, and send thank-you gifts
13. If you have applied to participate in or view TV programs, to notify whether you have been selected and send information concerning the program

3.　Disclosure and provision of personal information

We will not disclose or provide your personal information, excluding the following cases:

1. When we have obtained your prior consent (including cases of performing administrative work incidental to the provision of products or services that you have requested, upon obtaining your consent, such as when providing a list of participants to the accommodation or transportation company for your travel arrangement or collecting hometown donation tax on your behalf)
2. In cases where we introduce another company’s product or service to you and you contact us because you are interested in such product or service, when we provide your information to such other company so that such other company can contact you and accept your order of such product or service, and otherwise provide customer services
3. In cases where we accept orders based on services using the special functions of digital TV (T commerce), when we provide your product purchase history to the T commerce service provider required for you to use the service
4. When we make a credit inquiry to a credit company or a credit card company for shopping credit payment or credit card payment
5. When we receive an inquiry from a credit card company for investigation of unauthorized use of credit cards or impersonation, or when we make an inquiry to a credit card company
6. When our business partner, such as a manufacturer, is to contact you regarding product defects or recall
7. When we receive a disclosure request from a police agency or a legal institution such as a court, or when we disclose your personal information pursuant to laws

4.　Entrustment of personal information

Excluding cases where we entrust the handling of your personal information to a subcontractor with whom we have concluded a non-disclosure agreement on the protection of personal information to the extent required for achieving the purposes of use that we have notified to you, we will not deposit your personal information with a third party. The following are some examples where we may entrust the handling of your personal information to a subcontractor.

1. When entrusting the handling of your personal information to a delivery company for the shipment of your ordered product or the shipment of repair parts or replacements
2. When entrusting the handling of your personal information to a printing company of address labels for sending catalogs and direct mails
3. When entrusting the handling of your personal information to a manufacturer or construction company for repair services or installation services
4. When entrusting the handling of your personal information to a management company for credit judgment for shopping credit payment or credit card payment, payment of product prices and shipping costs for returns at your request, credit management (reminder work) and prevention of unauthorized use

5.　Transfer of personal information to a foreign country

We may provide your personal information to a third party in a foreign country. For details of such a case, please see “Information concerning Protection of Personal Information of Third Parties in Foreign Countries”.

6.　Joint Use of personal information

We may jointly use your personal information that we acquired from your various applications made via the Internet, phone calls, postcards or FAX, and website emails, with our group companies.

1. The purpose of use of your personal information to be jointly used is the same as in “1. What is “personal information”?” and “2. Purpose of use of personal information”.
2. The scope of joint use of your personal information is our group companies.
3. We are responsible for the joint use of your personal information.
4. We will jointly use your name, address, phone number, contact information, transaction history and other personal information indicated in “1. What is “personal information”?” only to the extent required for achieving the purposes of use indicated in 1 above.

*Our group companies with which we will jointly use your personal information can be found here.

7.　Registration of personal information with a personal credit data institution, and use of personal information by such personal credit data institution

If you wish to use a shopping credit, you need to agree to your credit information being registered with a personal credit data institution, and being referred to and used by that personal credit data institution.
For details concerning the registration of personal information with a personal credit data institution and use of personal information by such personal credit data institution, see Customers who wish to make payment in installments.

8.　Disclosure, correction, suspension of use of personal information

Please call the toll-free number of the following personal information inquiry desk for any request that you have concerning the disclosure, correction and suspension of use of your personal information (cancellation of reception of catalogs and direct mails) and disclosure of records on the third-party provision of your personal information. We will respond to your request to the extent permitted under applicable laws by taking prescribed procedures.
In the foregoing case, please note that we may need to verify your identity by calling you at the contact information that you have registered with us.

Disclosure items: Specific items to be disclosed are as follows.

• Address
• Name
• Phone number
• Date of birth
• Purchase history

*We will disclose your date of birth only if it is in our possession.
*We will update the postal code if it is changed due to a municipality merger.

*When using a shopping credit, you will need to provide information concerning the “name of your workplace” and “phone number of your workplace”.
When disclosing information, we will also disclose the “name of your workplace” and “phone number of your workplace”.

*The fee for disclosure is 404 yen (including 10% tax). For details regarding the procedures of disclosure, please contact the following personal information inquiry desk.
*As a general rule, please note that it will take about 2 weeks to respond to your request.

9.　Deletion of personal information

If we receive your request for deleting your personal information, we will delete your personal information from our personal information database to the extent permitted under applicable laws by taking prescribed procedures. Nevertheless, since your information will be deleted, please note that we will no longer be able to offer after-sales services, such as product warranties or contacting you regarding recalls by manufacturers.

10.　Complaints concerning personal information

Any complaints that you may have concerning our handling of your personal information should also be directed to the following personal information inquiry desk. If you receive any suspicious direct mail or phone call assuming our company name, please report it to the following personal information inquiry desk.

○ For procedures related to personal information, please see Inquiries concerning personal information.