Personal Information Protection Policy

Aderans Co., Ltd. ("the Company") adequately recognizes its social mission regarding the protection of all personal information that it handles, will protect the rights of people whose information it possesses, and will comply with laws and regulations concerning the protection of the rights of individuals concerned and personal information. Moreover, the Company has established a personal information protection management system to realize the policy presented below, and hereby declares that it will endeavor on a companywide basis to continually improve it while constantly recognizing the latest IT trends, changes in social requirements, and changes in the business environment.

• The Company acquires, uses and provides personal information only to the extent necessary to accomplish the Company's legitimate operations in the hair related business, as well as employment of employees and personnel management. We do not handle personal information beyond the scope required to achieve the specified purposes of use (non-purpose use). We also take measures to prevent non-purpose use.
• We comply with laws and regulations, guidelines determined by the Japanese government, and other norms regarding personal information protection.
• We will adopt reasonable safety measures in relation to risks such as leakage and loss of as well as damage to personal information, and will continuously improve the personal information security system by allocating management resources that are consistent with the actual business situation to prevent such occurrences. In addition, we will take corrective action promptly when we determine that there is a problem in terms of protection of personal information.
• We will respond swiftly, sincerely and appropriately in relation to complaints and consultation concerning the handling of personal information.
• We will review the personal information protection management system in a timely and appropriate manner and continually improve it in light of changes in the environment surrounding the Company.

This policy shall be distributed and made known to all employees, and shall be made available to anybody at any time by means of its publication on the Company's website, pamphlets and other types of media.

Inquiries regarding the Personal Information Protection Policy will be accepted at the point of contact below.

Handling of personal information

Purposes of use of personal information handled by the Company

• Purpose of use of personal information acquired by means of a written document directly from the individual concerned (including information based on a website or e-mail)
  In advance of its acquisition, the purpose of use shall be specified in writing to the individual concerned.
• Purpose of use of personal information acquired by a method other than that in the preceding paragraph

Category	Purpose of use
Customer information acquired verbally in counseling, acquired by means of images, etc.	For the provision of products and services For management of the customer's usage history For responding to an inquiry
Customer information acquired by telephone	For reservation procedures For responding to an inquiry
Personal information collected from customers in association with the entrustment of business or services	To appropriately accomplish the applicable business or services that have been entrusted
Supplier contact information	To confirm order contents (communication records, etc.)
Information on job seekers obtained from a recruitment agency or job advertising agency	For recruiting activities

Ensuring awareness of matters regarding retained personal data

The Company will respond based on the following guidelines to personal information (referred to as a "retained personal data" hereafter) that it possesses in regard to requests from the individual concerned or his/her representative for notification, disclosure, correction, addition or deletion of the contents, suspension of use, deletion and suspension of provision to third parties (referred to as a "request for disclosure, etc." hereafter).

• Name of business operator
  Aderans Co., Ltd.
• Personal Information Manager
  Name of manager: Senior Executive Manager of Administration Group
  Contact information: See below “Personal information inquiries point-of-contact”
• Purpose of use of all retained personal data
　　　　　　　　　　　　　

Category	Purpose of use
Personal customer information	For user support For management of the customer's usage history For the provision of products and services For providing information on products and services, For responding to an inquiry
Supplier contact information	To confirm order contents (communication records, etc.)
Information on the Company's employees	For personnel and labor management, work management, health management and security management of employees
Information on applicants seeking jobs at the Company	To contact employment applicants and manage our recruiting operations
Specific personal information	For the purposes of use prescribed in the My Number Act

• Contact for complaints regarding handling of retained personal data
  
  Aderans Co., Ltd.　Personal information inquiries point-of-contact
  Customer Service Center
  Shinagawa Seaside Canal Tower 4-12-6, Higashi Shinagawa,
  Shinagawa-ku, Tokyo, 140-0002, Japan
  Tel: 0120-03-9696
  Reception hours: Monday-Friday: 10:00 am-6:30 pm
  Saturday, Sunday and public holidays: 9:00 am-5:30 pm
  (excluding December 30-January 4 at end of year/beginning of year)
• Regarding "Accredited Personal Information Protection Organizations"
  
  At present, the Company is a member of the following organization.
  ・Name of the organization: JIPDEC
  ・Attention to file a complaint for a resolution: Personal Information Protection Consultation Service Office
     Location: Roppongi First Building, 9-9 Roppongi 1-chome, Minato-ku Tokyo, 106-0032, Japan
     Phone numbers: +81 (0)3-5860-7565 / Toll free (Domestic only) 0120-700-779
                             (reception hours: 9:30-12:00,13:00-16:30 on weekdays)
  *The above point of contact is not for inquiries regarding our products and/or services.
• Procedures corresponding to requests for disclosure, etc. of retained personal data
  • Contact for requests for disclosure, etc.
    For requests for disclosure, etc., please contact the personal information inquiries point-of-contact above.
  • Procedures related to requests for disclosure, etc.
    (i) After receiving your request, the Company will mail you the prescribed request form, "Request for Disclosure, etc. of retained Personal data " which you can use.
    (ii) Please mail us the filled-in request form, and in the case of a request by a representative, please send this to the above personal information inquiries point-of-contact together with a document that verifies that this is your representative and a postal money order for the fee (only in the case of a request for notification and disclosure of the purpose of use).
    (iii) After receiving the above request form, in order to to confirm your identity, we will ask for approximately two items of information (e.g., your telephone number and date of birth) that can verify your identity among the personal information that you have registered with the Company.
    (iv) Responses will, in principle, be made in a written form (sealed mail) to the individual concerned.
  • In the case of a request by a representative, documents to confirm the identity of the representative If the person who requests disclosure, etc. is a representative, please enclose a document to prove that this person is a representative and a document to prove the identity of the representative. Please fill in the legal domicile information included in each document as far as the prefecture and then mask or otherwise conceal the information thereafter. In addition, please send each document without including any personal numbers or mask or otherwise conceal all digits. (i) Documents to prove that someone is a representative
    <In the case of a representative that has been authorized by the individual concerned in regard to a request for disclosure, etc.>
    Power of attorney (original document) to act on behalf of the individual concerned <If the representative is the statutory agent of a minor> A photocopy of one of the following
    Family register
    Certificate of residence (showing the family relationship)
    Another public document that can verify the power of legal representation <If the representative is the statutory agent of an adult ward> A photocopy of one of the following
    A certificate of registered matters regarding guardianship registration, etc.
    Another public document that can verify the power of legal representation (ii) Documents to prove the identity of the representative
    Driver's license
    Passport
    Health insurance certificate
    Certificate of residence
    
  • Fee for request for notification or disclosure of purpose of use
    1,000 yen per request
    (Please enclose a postal money order with the sent request form.)

Handling of personal information

In addition to Chapter 1, Chapter 2 provides our policy to handle personal information of persons residing in the European Economic Area (hereinafter referred to as “EEA”) based upon the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive“95/46/EC”. In the event that any provisions of this chapter contradict those of Chapter 1, the provisions of this Chapter shall prevail.
However, please note that this chapter does not apply to those who live in Japan and are visiting/browsing this page from/within Japan.

• Customer under the age of 16

A guardian’s consent or permission must be obtained in the event that a customer under the age of 16 uses the Company’s service and consents to this Privacy Policy. The data subject’s consent to this Privacy Policy must be obtained in the event that a person such as family member apply for the Company’s service on behalf of the data subject.



• Request about handling of Personal Information

If the Company receives a request from an EEA resident, with regard to the customer’s personal information stored in a database held by the Company, the request will be handled as follows, within a reasonable timeframe and scope, after confirming that the request was submitted by the customer themselves.




①Request for disclosure
After due review of the request, personal information will be disclosed by the customer’s request.

②Request for correction, deletion, addition
After due review of the request, personal information will be corrected, deleted, or added, after verification of customer’s request, within reasonable scope.

③Requesting discontinuance of usage or erasure
According to the contents of your request, the personal information specified will be suspended or deleted wherever possible and appropriate.

④Request for withdrawal
After reviewing the request, personal information will be deleted or suspended in accordance with the customer’s request, wherever possible and appropriate.

⑤Request for data portability
After confirming the details of customer's request, the company will transfer or receive personal information requested, whenever possible and appropriate.

⑥Request for objection
After confirming the details of customer's objection, the company will stop using the personal information, whenever possible and appropriate.

⑦Procedure for making the request
If a customer wishes to make a request provided in this clause, please contact the data protection officer's e-mail address as indicated at the end of this clause. An adequate claim form among ① to ⑥ above will be sent by e-mail.



• Transfers to outside the EEA

The Company may provide the customers’ personal data to third parties, such as its affiliates and its outside contractors (some of them are located outside the EEA) to implement the purposes of use, after obtaining a consent from customer. In the case that the country in which the third party is located is outside the EEA, such country may not have the same data protection laws as the EEA. As such, many of the rights provided in the EEA to the data subjects of the data will not necessarily be provided.
The Company has secured the right of customer with regard to personal information by entering into an agreement which provides SCC (Standard Contract Clauses) with those companies that receive the personal information.



• Change of purposes of use of personal data

In the case of a change to the purposes of use of personal data, the Company will　announce the revised Privacy Policy in advance on the Company’s website.
（https://www.aderans.co.jp/corporate/）.



• Lodging a complaint with an authority

Customers have the right to lodge a complaint on the processing of their personal data with the data protection authority having jurisdiction over their residence. Please use the following URL to contact the authority having jurisdiction over your residence:
（https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080）



• The contact information of data protection officer

You can contact Aderans Europe B. V.’s data protection officer at dpo@aderanseurope.com.