PRIVACY POLICY

1.

Basic Policy

As a member of the Hakuhodo Group, and based on the approaches of ‘consumer conception’ and ‘partner-ism’, TBWA\HAKUHODO (Hereinafter “TH”) proposes, produces and implements marketing activities and measures for its clients conducive to enriching consumer lifestyles. The most important thing for us to consistently produce quality proposals is to have a deep understanding of consumers and to respond to their needs. To this end, consumer information is an essential part of our business activities. In view of the increasing social focus on the protection of personal data in recent years, we hereby declare that our policy on the handling of personal data is clearly stated both internally and externally and that all officers and employees are required to strictly adhere to this policy. TH will handle personal information collected by itself, personal information received from business partners and personal information of officers and employees of TH and its affiliated companies in an appropriate manner in compliance with the law, industry standards and internal rules.

2.

Compliance with relevant laws and regulations

TH complies with laws, national guidelines and other norms relating to personal data.

3.

Personal data handled by TH

The Company will use personal information within the scope of the following purposes of use, unless otherwise required by law. If the information is to be used for purposes other than those listed below, we will notify the individual or make a public announcement at the time of obtaining the information. If personal information of a kind other than that indicated below is to be obtained, the purpose for which it is to be used will be notified or made public in advance. Where necessary, consent will be obtained before use.

3-1.

Personal data that TH obtains itself.

Types of personal information to be obtained and purpose of use
● Personal data relating to participants in seminars, lectures and other events organized by TH.

　・Contacting and responding to enquiries by email, telephone, etc. concerning information for participation in the events in question, information sharing after participation, etc.

　・Contacting and responding to enquiries by email, telephone, etc. regarding new event information, etc.

　・Analytical work to improve events, email content, etc.
● Personal data provided to third parties for sponsorship of events participated in by TH.

　・Provision of information on our services, events, seminars, campaigns, questionnaires, etc., by email, etc., and response to enquiries.

　・Analytical work to improve the selection of sponsored events, email content, etc.

● Personal data relating to visitors to TH

　・Filling in the ‘Office Access Control Form’ when visiting the Company, etc.

● Personal data relating to business partners

　・Contact by email, telephone, etc. concerning consultation and confirmation of transaction details, filling in dispatch slips, etc. for sending documents, etc.

　・Filling in dispatch slips, etc. for sending sample papers/magazines, etc.

　・Filling in dispatch slips for sending seasonal greetings cards, etc.

　・Provision of information on our services, events, seminars, campaigns, questionnaires, etc., by email, etc., and response to enquiries.

● Personal information of those who wish to work for TH and those who browse information provided by TH.

　・Use for necessary correspondence such as contact, selection and future recruitment planning for TH’s recruitment and employment.

● Personal data relating to executive officers, employees and family members of officers and employees of the Company and its group companies.

Examples of use in business operations, personnel management and other responses required for company operations.

　・Personnel Management (employment management, transfers, secondments, transfers, promotions, advancement, resignations, dismissals, reviews, disciplinary actions, emergency communications, etc.) and the performance of tasks related to employment management.

　・Performing tasks related to wage administration (salaries, bonuses, retirement benefits, company pensions, expense management, etc.)

　・Performing tasks related to social insurance.

　・Performing tasks related to taxation (income tax, residential tax, etc.)

　・Performing tasks related to proof of incumbency and retirement.

　・Performing tasks related to the implementation of education and training

　・Performing tasks related to insurance and safety management

　・Performing tasks related to welfare, health and safety, health care, etc.

　・Performance of tasks related to access control (e.g. creation of access (room) cards, acquisition of access logs, etc.).

　・Provision of TH internal services (cloud services, computer and smartphone rental).

　・Work related to or incidental to the above.

If the information is used for purposes other than those listed above, the purpose of use shall be presented to the officers and employees as necessary.

● Personal data of persons who contact TH

　・Contact by email, telephone, etc. in response to enquiries

　・Verification of the identity of the person making the enquiry.

● Personal information obtained through consumer surveys conducted by TH

　・Contact by email, telephone, etc. regarding surveys

　・Email and telephone contact regarding new survey requests, etc.

　・Analysis and publication at seminars, etc., after statistical processing to produce data that cannot be used to identify individuals.
3-2.

Personal data handled by TH on behalf of its clients.

Types of personal information to be obtained and purpose of use
● Personal information acquired, used or disposed of as a result of outsourcing from clients.

　・Use necessary in the course of carrying out various types of commissioned work (prize campaign work, event work, research and analysis work, email distribution work, etc.).

4.

Provision to Third Parties

The Company will not provide personal information to third parties without prior consent of the individual, except where the requirements and descriptions in the following laws and regulations are met.

・When required by law.

・Where it is necessary for the protection of a person’s life, body or property and it is difficult to obtain the consent of the person.

・Where it is particularly necessary for the improvement of public health or the promotion of the sound development of children and it is difficult to obtain the consent of the person concerned

・In the case of cooperation with a state body, a local authority or a person entrusted by them to carry out affairs prescribed by law, obtaining the consent of the person may impede the carrying out of such affairs.

・Where the individual has expressly requested disclosure or provision of the information to a third party.

・If a court, public prosecutor’s office, police force or an agency with equivalent authority requests disclosure of personal information in accordance with due process.

・Where personal information is provided as a result of the succession of a business due to a merger or other reason, and is handled within the scope of the purposes of use before the succession.

・When provided or disclosed to subcontractors to the extent necessary for the implementation of the purpose of use.

If, for reasons other than those stated above, information is to be provided to third parties in the future, the information to be provided and the purpose for which it is to be provided will be notified to the person concerned and will only be provided to a third party if consent is obtained.

5.

Joint Use

TH will use personal information jointly within the following scope. In the event that personal information of a type other than that indicated below is to be shared, this will be done after prior notification or publication.
Cases of Joint Use

● Where joint use with Hakuhodo DY Holdings Group companies is necessary in order to provide an appropriate response to an enquiry to TH.
1)

Jointly used information:

Name, address, telephone number, email address, name of employer, nature of enquiry
2)

Joint Users

Hakuhodo DY Holdings Group Companies

https://www.hakuhodody-holdings.co.jp/group/about/group.html

※Includes Hakuhodo DY Holdings Group Companies not displayed on above line (for names of businesses not listed, please refer to “Status of affiliated companies” in the Annual Securities Report)
3)

Objective of Use

Necessary responses to enquiries, such as contacting the person concerned and sending documents, etc.
4)

Person responsible for the management of personal data:

HAKUHODO Inc.

Akasaka Biz Tower, 5-3-1 Akasaka, Minato-ku, Tokyo 107-6322

President and Representative Director Masayuki Mizushima
● When communicating information from Hakuhodo DY Holdings Group Companies
1)

Information to be jointly used:

Personal information (company name, department, title, name, email address, telephone number, address) provided to third parties for participants in seminars, lectures and other events organized by TH and for sponsors at events sponsored by TH.
2)

Joint Users

Hakuhodo DY Holdings Group Companies

https://www.hakuhodody-holdings.co.jp/group/about/group.html

※Includes Hakuhodo DY Holdings Group Companies not displayed on above line (for names of businesses not listed, please refer to “Status of affiliated companies” in the Annual Securities Report)
3)

Objective of Use

Provision of information on our services, events, seminars, campaigns, surveys, etc. by email, etc.

Analytical work to improve email content, etc.
4)

Person responsible for the management of personal data:

HAKUHODO Inc.

Akasaka Biz Tower, 5-3-1 Akasaka, Minato-ku, Tokyo 107-6322

President and Representative Director Masayuki Mizushima

6.

Handling of personal data relating to minors

TH will not obtain or use the personal data of minors without the consent of their parents or guardians. In the unlikely event that you discover that a minor has provided personal information to TH without parental consent, please contact TH immediately.

7.

Security management measures

TH takes the following measures to ensure the safe management of the personal information entrusted to us.
・

Clarity regarding information handling.

TH has established rules for the safe and proper handling of personal data, including access, use, storage, disposal and return of personal data, and these are followed under the supervision of a management officer. In addition, personal data acquired will be properly erased and disposed of after the storage period required for legal or operational purposes has elapsed.
・

Confirmation of the appropriateness of personal information received in the course of business, its proper use and safe management.

With regard to the personal information we receive from our business partners in the course of conducting our business, we confirm the method of obtaining such information and the scope of authorization for its use, and use it appropriately in accordance with their requests and our internal rules.
・

Education of officers and employees.

Education and awareness-raising activities are regularly conducted to ensure that the company’s officers and employees understand the importance of personal information protection, legal requirements, management systems, handling rules and measures to be taken in the event of a breach (e.g. annual e-learning courses on information security, including personal information, are provided to all employees) and to promote proper handling of personal information and compliance with various regulations and rules.
・

Establishment of information handling management systems.

In order to protect personal data, TH defines its internal management and responsibility structure and appoints an officer responsible for the management of personal data.
・

Countermeasures against unauthorized access

In order to prevent theft, loss, falsification, or destruction of personal information due to unauthorized access, information systems and information management structures are in place to properly control access to areas where personal information is handled, protect against unauthorized access from outside and protect against unauthorized software.
・

Ensuring security when information processing is outsourced.

If the processing of personal data is outsourced to an external contractor, the contractor will be selected in accordance with internal rules and confirmed to ensure the safe management of the information, and appropriate supervision thereof will be carried out.
・

Establishment of an immediate response system in the event of a problem.

If a problem should arise, TH will establish an organizational structure to assess the situation without delay and accurately, and make appropriate decisions and responses.
・

Ongoing Improvement

Various improvements are implemented on an ongoing basis through monitoring of the management situation, including internal audits of information security by the Audit Office, and in response to changes in the external environment.
・

Understanding the external environment.

When storing or transferring entrusted personal information to a foreign country, TH complies with the laws and regulations concerning personal information and implements security management based on its knowledge of the system for the protection of personal information in the country concerned.

8.

Disclosure, correction and deletion of personal data.

If you wish to do any of the following with regard to the personal data that TH has obtained from you, please contact us at the email address provided in Section 9.

・Requests for disclosure or correction, addition, deletion, cessation of use, cessation of use of personal information or cessation of provision to third parties due to withdrawal of consent.

・Complaints about the handling of personal data, etc.

TH may not take such action for reasons stipulated by the Act on the Protection of Personal Data or for other reasons. In such cases, we will provide notification of the fact thereof and the reasons for it.

9.

Enquiries

Please address any enquiries to: inquiry.otoiawase@tbwahakuhodo.co.jp

10.

Officer in charge of handling personal data

TBWA HAKUHODO Inc.

No. 3 Toun Building, 1-13-10, Shibaura, Minato-ku, Tokyo 105-0023, Japan

Wataru Uchida, President and Representative Director

11.

Amendment of Privacy Policy

The Company may change the content of this Privacy Policy from time to time.

If changes are made, details will be posted on TH’s company website.

Established 29 September 2004

Amended on 1 April 2022

Amended on 1 April 2024