Protection and Handling of Personal Information

Japanese

Protection of Personal Information

Cross Marketing Inc. ("CM") is striving to contribute to the business activities of its clients by offering high-quality marketing and market research solutions.

CM understands that obtaining personal information from general consumers, customers and employees is essential for CM's business operations and publicly announces that CM has established and is currently implementing and maintaining the following Basic Policy for Protecting Personal Information in light of the need to protect such information.

1. CM strictly observes laws and regulations, guidelines, and other rules established by the Government regarding handling of personal information when CM handles personal information obtained or used in the course of business activities and personal information of employees. In addition, CM has established and strictly observes the private information protection management system in compliance with Japan Industrial Standards (JIS Q 15001 [Personal Information Protection Management System-Requirements]) and will protect personal information.
2. CM specifies the purpose(s) of use and notifies the purpose(s) of use as well as contact details in advance when asking for or using personal information and obtains or uses personal information solely within the scope of the stated purpose(s) of use. Also, CM will take appropriate control measures to protect personal information from handling beyond the necessary scope (using to the extent that goes beyond the stated purpose(s) of use).
3. CM takes appropriate control measures of obtained personal information and does not disclose or provide such personal information except with the consent of the individual from whom the personal information was obtained or when complying with laws and regulations. CM manages personal information obtained when accepting applications for questionnaires and events in a format that does not include an individual's identity and uses such information in the course of business activities. CM also uses such personal information for the purposes of responding, notification and sending gifts to applicants.
4. CM will endeavor to protect obtained information from unauthorized access, leakage, modification, loss or destruction and will implement corrective actions. CM will collect and manage personal information under strict security control measures.
5. When any third party subcontracts and entrusts personal information with CM, CM will use such personal information under strict security control and solely within the scope necessary for the purpose of the subcontract agreement.
6. CM will respond to any and all comment(s) and request(s) regarding handling of personal information after due review of such comment(s) and request(s) within a reasonable timeframe. Moreover, CM shall handle any request for disclosure or correction submitted by the individual from whom the personal information was obtained within a prompt and reasonable timeframe.
7. CM will continuously endeavor to improve the private information protection management system in light of change in social affairs and circumstances.

Established: December 1, 2003
Last Revised: February 1, 2008

Miki Igarashi
President & Representative Director
Cross Marketing Inc.

RULES AND PROCEDURE FOR HANDLING OF PERSONAL INFORMATION(For residents in the European Economic Area (EEA), which includes all EU member states, Iceland, Liechtenstein, and Norway)

1. PURPOSE OF USE OF PERSONAL INFORMATION THAT WILL BE HANDLED BY CROSS MARKETING INC. (“CM”)

CM shall use the personal information of each individual (hereinafter referred to as the “Individual(s)”) that CM directly acquires the personal information from in writing (including acquisition of information through a website, email, etc.) pursuant to the following rules and procedure.

Category	Purpose of use
Information pertaining to the subjects of surveys, etc.	Marketing research activities including selection and sampling of survey subjects, request to participate in surveys, transmission of survey forms, checking and analysis of survey results, provision of survey results to clients, and other activities that are necessary for conducting marketing research. Visits and other activities of survey staff members in surveys that involve interviewing and visiting survey subjects. Granting and exchanging of points to and with survey subjects, payment of gratuity money, shipment of gifts and product samples used in surveys, etc. Handling of inquiries, etc. from survey subjects, provision of support to survey subjects, communication with survey subjects to check and verify their registered information. Execution of campaigns and prize programs, distribution of email newsletters, etc. that concern marketing research activities. Any other activities, etc. that are ancillary or related to any of the foregoing.
Information pertaining to the shareholders	Exercising of the rights and fulfilment of the obligations of the shareholders pursuant to the applicable laws. Provision of benefits, etc. from CM to the shareholders for their status. Implementation of various measures that are intended to facilitate the relationship between the shareholders and CM. Preparation of shareholder data and other shareholder management activities based on the standards as specified by the applicable laws and regulations. Communication from CM to the shareholders.
Information pertaining to business partners	Negotiation, coordination, communication, consultation, and examination concerning business transaction, placement and acceptance of orders, settlement of payments, and other types of business interaction. Provision and reception of service, etc. based on business arrangements. Provision, gathering, and communication of information concerning the service, etc. of CM.
Information pertaining to employees	Human resource and labor management, work management, health management, and security management concerning employees.
Personal information pertaining to job applicants	Provision of recruiting information to job applicants. Review of job applicants to determine whether to hire or reject them, making of hiring decisions, notification of decisions, and communication with job applications. Review of data on past job applicants.

Before acquiring any personal information, CM shall clearly indicate to the Individuals what types of personal information CM intends to acquire from them as well as the purpose of use of their personal information in writing (including through a website, email, etc.).

2. OBTAINMENT OF CONSENT IN ADVANCE, AND THE RIGHT TO REVOKE CONSENT

Before acquiring any personal information from the Individuals, CM shall clearly indicate the purpose of use of their personal information that will be handled by CM, and obtain the Individuals’ consent to CM obtaining or using their personal information. For this purpose, the Individuals shall be entitled to revoke their consent that they previously gave to CM at any time.
As for the Individuals that are below the age of 16, the consent must be given either by their parents or other statutory guardians, or by themselves after obtaining the permission of their parents or other statutory guardians.

3. TRANSFER OF PERSONAL INFORMATION TO OUTSIDE THE REGION

As necessitated due to the purpose of use as specified in 1. PURPOSE OF USE OF PERSONAL INFORMATION THAT WILL BE HANDLED BY CROSS MARKETING INC. above, CM may handle the personal information of any Individuals in Japan or any other country being located outside the EU region. In such case, the same rights of the Individuals that are granted under the EU’s General Data Protection Regulation (GDPR) may not be available to the Individuals in the countries outside the EU region.

4. INFORMATION STORAGE PERIOD

CM shall store the personal information of Individuals for a time period that will be necessary to fulfill its purpose of use as specified in 1. PURPOSE OF USE OF PERSONAL INFORMATION THAT WILL BE HANDLED BY CROSS MARKETING INC. above, and shall swiftly delete it once it is no longer needed.

5. NECESSITY TO PROVIDE PERSONAL INFORMATION

As it is necessary that the Individuals provide their personal information to CM for the purpose of use as specified in 1. PURPOSE OF USE OF PERSONAL INFORMATION THAT WILL BE HANDLED BY CROSS MARKETING INC. above, those Individuals that refuse to provide their personal information to CM may not be allowed to participate in the marketing research that CM will be conducting, or use the service, etc. that will be provided by CM.

6. INDIVIDUALS’ RIGHTS CONCERNING ITS PERSONAL INFORMATION (RIGHTS TO ACCESS IT, CORRECT IT, DELETE IT, RESTRICT IT, DATA PORTABILITY RIGHT, RIGHT TO FILE OBJECTIONS)

In regard to the personal information that they provide to CM, the Individuals shall be entitled to contact CM to (1) review their personal, (2) exercise their right to correct, add, and delete any part of their personal information or exercise their data portability right, (3) request to stop the use of their personal information, and (4) request to stop providing their personal information to any business partner of CM.
In addition, the Individuals shall be entitled to file objections against CM, etc. with the government agencies of various countries that are in charge of supervising the handling of personal information pertaining to users.

Information Desk: Matters related to personal information
Cross Marketing Inc.
Personal Information Handling Desk
Tokyo Opera City Tower. 24 Fl., 3-20-2 Nishi-Shinjuku, Shinjuku-ku, Tokyo 163-1424 Japan
E-MAIL: privacy_info@cross-m.co.jp

Handling of Personal Information

1. Purpose of using personal information

Cross Marketing Inc. ("CM") provides market research service as its core business. The objectives of CM's business are to research and acquire opinions and reactions on products or services from general consumers, to manage such information in a statistical data, and to provide such information to companies or entities. As a general rule, CM manages obtained personal information in a statistical format and does not use such information in a format that includes the identities of individuals.

In addition, CM uses personal information obtained in the course of research for the purposes of notifying of questionnaire, sending materials or gifts, and keeping a record of participation in questionnaires. CM specifies the purpose(s) of use when asking for personal information, and obtains and uses such within the scope necessary for the stated purpose(s) of use.

Furthermore, such personal information as the contact address of a person in charge of any of CM's clientele, and any and all personal information that CM handles in the course of hiring activities and for the purpose of personnel management will be obtained only to the extent necessary and used by appropriate methods.

2. Disclosure

"Target personal information" means such personal information over which CM has the authority to disclose, to collect, add or delete the content, to suspend its use, to erase, and to suspend its provision to third parties. Any individual specifically identified by target personal information may request CM to disclose, to collect, and/or to add to or delete the content of target personal information retained by CM by the following procedures.

(1) Where to request for disclosures, etc.

Personal Information Handling Desk
When making requests by surface mail, please complete the prescribed request form, enclose the necessary documents, and post such form and documents to the postal address indicated below.
- Cross Marketing Inc.
  Personal Information Handling Desk
  Tokyo Opera City Tower. 24 Fl., 3-20-2 Nishi-Shinjuku, Shinjuku-ku, Tokyo 163-1424 Japan

(2) Documents to be submitted

Request Form for Disclosure and/or Notification of the Purpose(s) of Use of Personal Information;
Request Form for Amendment of Personal Information;
Request Form for Cessation of Use of Personal Information;
Identify confirmation document (a copy of driver's license, passport, or other photo ID);
When your legal representative is making a Request on your behalf, documents showing qualifications of the representative in addition to 4 above.

(Documents listed in 1, 2, 3, and 5 above are available from the Personal Information Handling Desk.)

(3) Handling charges

No fee is charged for Requests.

An individual who wishes to make the above requests should contact the Personal Information Handling Desk. Depending on the circumstances, even if such a request is made, CM may not disclose, collect, add or delete the content of target personal information, as per provisions in the Personal Information Protection Law.

3. Provision to third parties

CM will not, except in the following cases, provide any personal information to any third party without obtaining the prior consent of the individual from whom personal information was obtained:

When the provision is in compliance with laws and regulations;
When the provision is necessary for the protection of the life, body, or property of such individual and it is difficult to obtain the consent of the individual;
When the provision is deemed particularly necessary for improving public hygiene or promoting the sound growth of children and it is difficult to obtain to the consent of the individual; and
When the provision is necessary for cooperating with a state institution, a local public body, or an individual or entity entrusted by one in executing the operations prescribed by laws and obtaining the consent of the individual might impede the execution of the operations concerned.

4. Inquiries concerning personal information

CM understands the importance of protecting personal information and will take as strict security control measures as possible to protect personal information. Complaints, questions and other inquiries regarding protection and control of personal information should be directed to the Personal Information Handling Desk.

Cross Marketing Inc.
Personal Information Protection Section