Privacy Policy
Personal Information Protection Policy
Reference Translation
This Personal Information Protection Policy is established in accordance with the laws of Japan. The Japanese version of this Personal Information Protection Policy constitutes the original and official version. This English version is provided for convenience and reference purposes only. In the event of any discrepancy or inconsistency between the Japanese version and the English version, the Japanese version shall prevail.
CAC Holdings Corporation (CAC) considers appropriate handling and protection of personal information to be not only important but also social responsibilities. We will establish the “Personal Information Protection Policy” as follows and promote corporate activities with the focus on compliance.
CAC will comply with laws, regulations, other rules, guidelines, and internal rules regarding handling of personal information and periodically review and aim to improve the personal information handling system.
When collecting personal information, CAC will either clearly indicate the purpose of use to the person concerned and obtain the person’s consent or release the purpose of use on our website. In addition, CAC will handle such information appropriately without using it for any other purpose and will take sufficient measures to ensure proper management. CAC will ensure the transparency and accuracy of the collected personal information. In principle, CAC will not provide personal information to a third party unless the person concerned consents to the provision.
CAC will safely manage and store the collected personal information under strict management and will prevent and correct the leakage, damage, or loss of personal information.
In cases where personal information processing is outsourced, CAC will manage such processing under its strict supervision.
CAC will establish a division to receive inquiries and consultations regarding personal information and will respond promptly to such inquiries and consultations.
CAC may revise the above policy according to changes in relevant laws, regulations, rules, guidelines, and internal rules. Any such revisions will be announced on this website, and we recommend that you review this website periodically.
Established on April 1, 2014
Revised on August 31, 2022
Ryota Nishimori
President and CEO
For more detailed information regarding CAC’s handling of personal information, please refer to the following.
Protection of Personal Information at CAC
You may access CAC’s website without disclosing any personal information. However, please note that certain content and services on CAC’s website may not be available unless you provide personal information.
1. Company Name, Address, and Representative
Please refer to the Company Profile section.
2. Personal Information Protection Manager
General Manager, Corporate Management Department
For contact information, please refer to the section “Contact for Inquiries Regarding the Handling of Personal Information” below.
3. Provision of Personal Information
As a general rule, CAC does not obtain personal information directly from an individual without that individual’s consent.
4. Purpose of Use of Personal Information
(1)
When an individual provides personal information directly to CAC in writing or by other means, CAC will inform the individual in advance of the purpose for which the personal information will be used.
If CAC subsequently needs to use the personal information beyond the scope of the purpose previously notified to the individual, CAC will obtain the individual’s consent again regarding the new purpose of use. The individual may consider the new purpose and may request CAC to cease the use of the personal information.
However, CAC may change the purpose of use without the individual’s consent in the following cases:
- When required by laws and regulations;
- When necessary for the protection of the life, body, or property of a person, and obtaining the individual’s consent is difficult;
- When particularly necessary for improving public health or promoting the sound development of children, and obtaining the individual’s consent is difficult;
- When it is necessary to cooperate with a national government agency, local government, or a person entrusted by such entities in performing duties prescribed by laws and regulations, and obtaining the individual’s consent may hinder the performance of such duties;
- When personal data is provided to an academic research institution, etc., and such institution needs to handle the personal data for academic research purposes (including cases where part of the purpose of handling the personal data is academic research), provided that there is no risk of unjustly infringing the rights and interests of individuals.
(2)
When acquiring personal information, CAC specifies the purpose of use as clearly as possible and acquires personal information only to the extent necessary to achieve such purpose.
Except where prior consent has been obtained from the individual concerned or where otherwise permitted under the Act on the Protection of Personal Information or other applicable laws and regulations, CAC uses personal information only for the following purposes:
- Conducting customer satisfaction surveys and other questionnaires;
- Responding to inquiries and communications;
- Managing contractual relationships with business partners;
- Managing shareholders, including:
- Exercise of rights and fulfillment of obligations under the Companies Act;
- Providing various benefits to shareholders in their capacity as shareholders;
- Implementing measures to facilitate relations with shareholders;
- Managing shareholder information, including preparation of shareholder data in accordance with applicable laws and regulations;
- Employment (including recruitment) and personnel management of employees and other personnel;
- Administration of tax, social insurance, and related matters;
- Use in business operations conducted among companies within the group in relation to the above activities;
- Providing information regarding services handled by CAC and its group companies in connection with the above activities.
5. Provision and Disclosure of Personal Information to Third Parties
As a general rule, CAC will not provide or disclose personal information provided by individuals to any third party without the individual’s consent.
Where personal information is provided or disclosed with the individual’s consent, CAC requires the recipient to appropriately protect such personal information.
6. Joint Use of Personal Information
The CAC Group jointly uses personal information held by CAC and its group companies as described below.
(1) Categories of Personal Information Subject to Joint Use
① Personal information relating to customers, business partners, partner companies, shareholders, and others
| Category | Examples | Purpose of Use |
|---|---|---|
| Basic Information | Name, address, telephone number, fax number, e-mail address, shareholding information |
|
② Personal information relating to directors and employees of CAC Group companies
| Category | Examples | Purpose of Use |
|---|---|---|
| Basic Information | Employee number, name, address, telephone number, fax number, e-mail address |
|
| Compensation Information | Company affiliation, department, title, annual income, monthly salary, bonuses, salary determination method, retirement benefits, etc. |
|
| Human Resources Information | Performance evaluations, educational background, qualifications and licenses, positions, employment history, disciplinary actions, commendations, etc. |
|
(2) Scope of Joint Users
Domestic subsidiaries within the CAC Group
(*Please also refer to the list provided at the end of this Policy.)
(3) Purposes of Joint Use
The purposes specified in Section 6(1) “Categories of Personal Information Subject to Joint Use.”
(4) Party Responsible for Management of Jointly Used Personal Information
CAC Holdings Corporation
7. Information Related to Individuals
“Information Related to Individuals” means information concerning the attributes of an individual, such as physical characteristics, assets, occupation, or title, that expresses facts, judgments, or evaluations and does not fall under any of the categories of Personal Information, Pseudonymously Processed Information, or Anonymously Processed Information.
(1) Types of Information Related to Individuals Collected
CAC may collect the following information related to individuals:
- Device information of website visitors (such as IP addresses, operating systems, and browser types);
- Behavioral history of website visitors (such as referral sources, dates and times of visits, and frequency of visits).
(2) Methods of Collection
Cookies
Certain pages on CAC’s website use a technology known as “Cookies” to improve user convenience and website functionality.
Cookies are small pieces of data that a web server stores on a user’s hard disk as identifiers. Some pages use Cookies to enable the reuse of information previously entered by a user, thereby simplifying website operations.
Cookies alone do not enable CAC to identify an individual user.
Users may change their browser settings to determine whether to accept Cookies when they are transmitted.
Collection and Handling of Information Through Third-Party Tools
CAC uses tools provided by third parties to collect and process information related to individuals. For details regarding the use of access data by each tool, please refer to the relevant websites indicated below.
Google Analytics
Google Analytics is a web analytics service provided by Google LLC. It collects user information through Cookies, web beacons, and similar technologies. The data collected is anonymous and does not identify individual users.
For more information regarding Google Analytics, please refer to the following:
Google Analytics Cookie Usage on Websites
Users who do not wish Google Analytics to collect their information may disable the service by installing the Google Analytics Opt-out Browser Add-on provided by Google.
Google Analytics Opt-out Add-on
(3) Purposes of Use of Information Related to Individuals
CAC may use information related to individuals for the following purposes:
- Analysis for service improvement;
- Delivery of advertisements and promotional activities.
8. Surveillance Cameras
For security purposes and for public relations activities relating to the promotion of boccia, CAC operates surveillance cameras in certain areas of its headquarters and business offices and retains recorded footage for a specified period.
CAC will not use such recorded image data for purposes other than security or, without the consent of the individual concerned, for public relations activities related to the promotion of boccia.
9. Security Control Measures for Personal Information
CAC implements necessary and appropriate security measures to prevent leakage, loss, or damage of personal information and to ensure proper management thereof. CAC also takes appropriate measures to ensure that personal information is used in accordance with the intentions of the individual concerned.
In addition, CAC exercises necessary and appropriate supervision over employees and contractors (including subcontractors) who handle personal information.
The specific security measures are prescribed separately in CAC’s Rules for Handling Personal Information. The principal measures are as follows:
(1) Establishment of a Personal Information Protection Policy
To ensure the proper handling of personal information, CAC has established this policy, which addresses matters including compliance with applicable laws, regulations, and guidelines, as well as contact points for inquiries and complaints.
(2) Establishment of Rules for Handling Personal Information
CAC has established Rules for Handling Personal Information that prescribe handling methods, responsible personnel, and their duties at each stage, including collection, use, storage, provision, deletion, and disposal.
(3) Organizational Security Measures
CAC appoints departmental personal information managers responsible for handling personal data and clearly defines employees who handle personal data and the scope of personal data handled by such employees.
CAC has established internal reporting procedures requiring employees to report to the relevant personal information manager when they become aware of facts or indications suggesting violations of the Act on the Protection of Personal Information or the Rules for Handling Personal Information.
CAC also conducts periodic self-inspections and audits by departments independent from those handling personal data.
(4) Personnel Security Measures
CAC provides regular training to employees regarding matters requiring attention in the handling of personal data.
CAC’s work rules also include provisions relating to the confidentiality of personal data.
(5) Physical Security Measures
CAC controls access to areas where personal data is handled and restricts the equipment that may be brought into such areas. Measures are implemented to prevent unauthorized persons from viewing personal data.
CAC also takes measures to prevent theft or loss of equipment, electronic media, and documents containing personal data and ensures that personal data cannot be easily identified when such equipment or media are transported, including within business premises.
(6) Technical Security Measures
CAC implements access controls to limit access to personal information databases and personal data to authorized personnel only.
CAC also employs systems and mechanisms designed to protect information systems handling personal data from unauthorized external access and malicious software.
(7) Outsourcing of Personal Information Processing in Foreign Countries
CAC may outsource system development, maintenance, operation, and other business activities to affiliated companies located in the People’s Republic of China (the “Chinese Service Providers”).
The measures implemented by CAC in connection with the outsourcing of personal information processing to Chinese Service Providers are as follows:
① Method of Providing Personal Information
CAC provides personal information to Chinese Service Providers pursuant to confidentiality agreements entered into between CAC and the relevant Chinese Service Provider.
② Measures Implemented by Chinese Service Providers
Under the confidentiality agreements, Chinese Service Providers are required to:
- Handle personal data only within the scope of the specified purposes of use;
- Implement necessary and appropriate security control measures;
- Exercise necessary and appropriate supervision over employees;
- Refrain from subcontracting without CAC’s prior approval;
- Refrain from providing personal data to third parties without authorization.
③ Personal Information Protection System in the People’s Republic of China
Please refer to the “People’s Republic of China” section available on the Personal Information Protection Commission’s webpage entitled “Survey of Systems and Frameworks for the Protection of Personal Information in Foreign Countries.”
④ Frequency and Method of Verification
CAC verifies, once annually, the implementation of the measures described above by obtaining written reports from the relevant Chinese Service Providers.
⑤ Suspension of Provision of Personal Information
If CAC determines that a Chinese Service Provider is handling personal information in violation of the confidentiality agreement, including the measures described above, and such violation is not remedied within a reasonable period despite CAC’s request for correction, CAC will suspend the provision of personal information to that service provider.
CAC will also suspend the provision of personal information if CAC confirms that the relevant legal system has been amended in a manner that conflicts with or undermines the measures described above.
10. Requests for Disclosure, Correction, Suspension of Use, and Complaints
Individuals who wish to request disclosure, correction, suspension of use, or make a complaint regarding their personal information are requested to contact the inquiry desk set forth below.
After confirming the identity of the individual concerned, CAC will investigate the relevant facts and respond within a reasonable scope.
Contact for Inquiries Regarding the Handling of Personal Information
CAC Holdings Corporation
Corporate Management Department
E-mail: cachd_riskmc@cac.co.jp
Please note that inquiries, complaints, requests for correction, and requests for suspension of use are accepted only by e-mail through the above contact address. Requests made by telephone, facsimile, in-person visits, or other means will not be accepted.
Reference: Personal Information Protection Policies of Domestic CAC Group Companies
For the Personal Information Protection Policies of domestic CAC Group companies, please refer to the relevant pages available on the websites of the respective companies.
EU Representative
As we are based outside of the EU, Article 27 required that we appoint an EU representative to handle certain data subject requests and queries. In compliance with this, we have appointed DataRep to act as our representative. Any queries requiring the input of our representative, should please be directed to them as follows: