Handling of Pseudonymously Processed Information and Anonymously Processed Information

• (1)
  Creation of Pseudonymously Processed Information
  If the Company creates pseudonymously processed information (i.e., information concerning individuals produced from processing personal information so as to be unable to identify specific individuals without cross-checking it with other information by taking measures prescribed by laws and regulations), the Company will process it appropriately in accordance with standards prescribed in laws and regulations.
• (2)
  Security Management Measures for Pseudonymously Processed Information, etc.
  In addition to those prescribed in Clause 12 “Security Management Measures” of the Privacy Policy, the Company will take security management measures pursuant to the provisions of laws and regulations regarding pseudonymously processed information and deleted information, etc. pertaining to such pseudonymously processed information (e.g., descriptions, etc. and individual identification codes deleted from personal information that was used in the creation of pseudonymously processed information, and information on the processing method (limited to information that would allow the personal information that was used in the creation of pseudonymously processed information to be restored)).
• (3)
  Handling of Pseudonymously Processed Information that is Personal Information
  The Company will implement the following if it handles pseudonymously processed information that is personal information.

  • We will use pseudonymously processed information that is personal information to the extent required for the Purpose of Use set forth in Clause 2 “Purpose of Use of Personal Information,” Clause 5 “Joint Use with the Company’s Group Companies and Business Partners,” and Clause 6 “Information Exchange System” of the Privacy Policy, and if we will change the Purpose of Use and use it for another purpose, we will publicly announce the changed Purpose of Use
  • We will make efforts to delete without delay any personal data that is pseudonymously processed information and deleted information, etc. that no longer needs to be used
  • Except in the cases set forth in Paragraph (1) of Clause 3 “Provision of Personal Data to Third Parties” of the Privacy Policy, we will not provide personal data that is pseudonymously processed information to third parties
  • We will not cross-check with other information for the purpose of identifying the individual pertaining to the personal information that is the source of the pseudonymously processed information that is personal information
  • We will not use contact information or other information included in pseudonymously processed information that is personal information for the purpose of contacting, etc. the individual pertaining to the personal information that is the source of that pseudonymously processed information
  • Except in cases permitted pursuant to laws and regulations, we will otherwise handle pseudonymously processed information that is personal information and personal data that is pseudonymously processed information in the same manner as ordinary personal information and personal data
• (4)
  Handling of Pseudonymously Processed Information that is not Personal Information
  The Company will implement the following if it handles pseudonymously processed information that is not personal information.

  • Except in the cases set forth in Paragraph (1) of Clause 3 “Provision of Personal Data to Third Parties” of the Privacy Policy, we will not provide personal data that is pseudonymously processed information to third parties
  • We will supervise employees who handle pseudonymously processed information that is not personal information as necessary and appropriate in accordance with standards prescribed by laws and regulations
  • If we outsource the handling of pseudonymously processed information that is not personal information, we will supervise the outsourcees as necessary and appropriate in accordance with standards prescribed by laws and regulations
  • We will not cross-check with other information for the purpose of identifying the individual pertaining to the personal information that is the source of the pseudonymously processed information that is not personal information
  • We will not use contact information or other information included in pseudonymously processed information that is not personal information for the purpose of contacting, etc. the individual pertaining to the personal information that is the source of that pseudonymously processed information
• (5)
  Changed Purpose of Use
  Not applicable

• (1)
  Creation, etc. of Anonymously Processed Information
  If the Company creates, etc. anonymously processed information (i.e., information concerning individuals produced from processing personal information so as to be unable to identify specific individuals by taking measures prescribed by laws and regulations, and so as to be unable to restore such personal information), we will implement the following.

  • We will process it appropriately in accordance with standards prescribed in laws and regulations
  • We will take security management measures to prevent the leakage of deleted information and information on processing methods in accordance with standards prescribed in laws and regulations
  • We will publicly announce the categories of information that are included in the anonymously processed information that was created
  • We will not take actions to identify the individual whose personal information was the source for the creation
  • If we acquired anonymously processed information from a third party, we will not acquire deleted information or information on processing methods, or cross-check against other information, for the purpose of identifying the individual pertaining to the personal information that is source
• (2)
  Provision of Anonymously Processed Information
  If the Company provides anonymously processed information to a third party, we will publicly announce the categories of information concerning individuals that are included in the anonymously processed information that we intend to provide and the method of provision, and will also clearly state to the third-party recipient that the provided information is anonymously processed information.
• (3)
  Categories of Information Included in Created Anonymously Processed Information
  Not applicable
• (4)
  Categories of Information Concerning Individuals Included in Anonymously Processed Information to be Provided and Method of Provision
  Not applicable

The Company will respond appropriately and quickly to complaints and consultations concerning the handling of anonymously processed information and pseudonymously processed information that is not personal information. For contact information, please see Clause 14 “Contact Information” of the Privacy Policy.