Privacy Policy

DIGITAL HEARTS HOLDINGS Co., Ltd. (hereinafter referred to as the "Company") recognizes the protection and management of information in a society with advanced information and telecommunication as one of its responsibilities to society, and it regards the protection of personal information as one of the top priorities in its corporate activities. In addition, in order to ensure the implementation of this policy, the Company has formulated the following Privacy Policy, and executives and employees will strive to appropriately handle and manage personal information in accordance with this policy.

1. Acquisition, Use and Provision of Personal Information in an Appropriate Manner

The Company shall identify the Purpose of Use within the scope necessary for its business operation and shall acquire, use and provide personal information in an appropriate manner. The obtained personal information shall be used only within the scope of the purpose of use and measures shall be taken to prevent use for other purposes.

2. Compliance with relevant laws and guidelines

The Company shall comply with the laws and regulations concerning the handling of personal information and the guidelines and other standards established by the State with regard to the personal information handled by the Company.

3. Matters concerning safety management measures

The Company will take reasonable safety measures and take corrective measures against risks such as leakage, loss, or damage of personal information.

4. Response to inquiries and complaints

The Company will respond without delay to requests for disclosure, correction, deletion, suspension of use, and complaints and inquiries of personal information in its possession.

5. Continuous improvement of the personal information protection management system

The Company will continuously review and improve its management system for the protection of personal information.

6. Revisions to the policy on the personal information protection

The Company may revise the contents of this Policy as necessary in order to protect personal information and to comply with revisions to laws and regulations. In this case, the revised policy will be applied from the date of publication of the revised version.

Established: October 1, 2013
Date of final revision: April 1, 2021

DIGITAL HEARTS HOLDINGS Co., Ltd.
President and CEO, Yasumasa Ninomiya

Handling of personal information

Date of revision:April 1, 2022

1. Purpose of use of personal information

Personal information obtained by the Company shall be used for the following purposes:

When obtaining personal information, if the purpose of use is specified separately to the individual, such personal information shall be used for the purpose specified at the time of acquisition.

(1)Personal data subject to disclosure

① Personal data obtained directly from the individual

Information on applicants for job offers ・For the purpose of providing or communicating information of employment and others to applicants
・For the implementation and management of recruitment services
Information of executives and employees of the Company ・For business communication and management of facilities and equipment
・For personnel management
・For labor management
・For determining and paying wages, bonuses and other remuneration, tax processing, and social insurance-related procedures
・For the provision of welfare
・For health and safety, health care, and disease prevention
・For the purpose of responding to labor-related laws and regulations concerning retirees and other necessary communications
Information obtained by receiving inquiries ・For responding to inquiries, checking and recording them
・For non-personally identifiable forms of statistical material
Information obtained in Information obtained in connection with a request for disclosure, etc. ・For investigation to the extent necessary for a request for disclosure and identification of the person in question, and response to the request

② Personal data obtained by means other than ①

Information on the contracting authority and the person in charge of the subcontractor ・For business communication, business negotiations, discussions, and other related procedures
・For the conclusion and execution of contracts
・To manage outsourcing partners and outsourced content
・In response to inquiries

(2)Personal data not subject to disclosure

Information of shareholders and investors ・For shareholder control under laws and regulations
・For the exercise of rights and fulfillment of obligations under laws and regulations
・For responding to inquiries
Information on directors, officers, and employees of group companies obtained in the course of performing human resources, labor, and other services for group companies ・To perform human resources and labor services for group companies entrusted by the Company

2. Purpose of use of the Retained Personal data

Personal data (personal information subject to disclosure)* held by the Company will be used for the same purposes as those listed in (1) of "Purposes of Use of Personal Information" above.

※Retained personal data (personal information subject to disclosure) is personal data for which we have the authority to respond to all requests for disclosure, correction, addition or deletion of content, suspension of use, deletion, and suspension of provision to third parties, and for which the public interest or other interests would be harmed if its existence or nonexistence were made clear. (2) "Other than those stipulated in this document" means those that are not stipulated in this document.

3. Entrustment of Handling of Personal information

The Company may entrust the handling of personal information in whole or in part within the scope of the purpose of use. In the event of consignment, we will appropriately supervise the consignee by concluding an agreement with the consignee regarding the handling of personal information.

4. Provision of Personal information to Third Parties

The Company shall not provide personal information to any third party without obtaining the prior consent of such third party except in accordance with laws and regulations.

5. Joint Use of Personal information

(1) Shared Use of Information of the Company’s Employees

In order for the Company’s group companies to cooperate and provide comprehensive services, the Company will share the information of the Company’s employees within the scope of the purpose of use at the time of acquisition as follows.

Items of personal information to be used jointlyInformation such as the name, gender, skills, and work history of the Company's employees Provided, however, that the individual number and special care-required personal information shall be excluded.
Scope of joint users ・DIGITAL HEARTS HOLDINGS Co., Ltd.
・DIGITAL HEARTS Co., Ltd.
・AGEST, Inc.
・FLAME Hearts Co., Ltd.
・Aetas, Inc.
・ANET Corporation
・identity Inc.
・DIGITAL HEARTS PLUS Co., Ltd.
Purpose of Use by Jointly Used Persons ・For group personnel and labor management (including temporary transfer, transfer, etc.)
・For the purpose of proposing, guiding and performing transactions to customer or client (including communication and coordination between persons in charge)
The name of the person or the company, who is responsible for the management of the personal information to be used jointly. DIGITAL HEARTS HOLDINGS Co., Ltd.
20-2, Nishi-Shinjuku 3-chome, Shinjuku-ku, Tokyo
Tokyo Opera City Building 41F
President and CEO, Yasumasa Ninomiya
Method of obtainingIn writing or electronic data

(2) Joint use of information by executives and employees of business partners

In order to comprehensively provide services that utilize the expertise of Group companies, the Company will jointly use the information of executives and employees of business partners within the scope of the purpose of use at the time of acquisition as follows.

Items of personal information to be used jointlyInformation such as the names of executives, employees, and freelances of business partners, the names of the organizations to which they belong, department names, locations, titles, e-mail addresses, telephone numbers, fax numbers, transaction histories, etc.
Scope of joint users ・DIGITAL HEARTS HOLDINGS Co., Ltd.
・DIGITAL HEARTS Co., Ltd.
・AGEST, Inc.
・FLAME Hearts Co., Ltd. Co., Ltd.
・Aetas, Inc.
・ANET Corporation
・identity Inc.
・DIGITAL HEARTS PLUS Co., Ltd.
Purpose of Use by Jointly Used Persons ・For the purpose of proposing, guiding and performing transactions to customer or client (including communication and coordination between persons in charge)
The name of the person or the company, who is responsible for the management of the personal information to be used jointly. DIGITAL HEARTS HOLDINGS Co., Ltd.
20-2, Nishi-Shinjuku 3-chome, Shinjuku-ku, Tokyo
Tokyo Opera City Building 41F
President and CEO, Yasumasa Ninomiya
Method of obtaining In writing or electronic data

6. About Cookies

We use cookies on our website.

Cookies are information sent from a website to a customer's browser and stored in the customer's terminal. The cookie itself does not contain any information that identifies the individual, such as the customer's name, address, telephone number, or e-mail address. In addition, cookies do not have any adverse effect on the terminal used by the customer.

You can also disable cookies by changing the settings of your browser; please refer to the "Help" menu of your browser for details on how to set cookies.

Please note that if you choose to disable all cookies, you may not be able to use services that require authentication, or you may be restricted from using various services on the Internet.

<Purpose of use of cookies>

・We analyze search keywords, visit routes, etc. from the acquired information such as browsing history, and utilize it to improve the content.

7. Voluntary Provision of Personal Information

It is a voluntary choice for each individual as to whether to provide their personal information or not, but in cases where you choose not to provide your personal information, the outcome may not be one that fully meets your expectations (for example, we may not be able to respond to your request).

8. Procedures for Responding to Requests, etc. for Disclosure, etc. of Retained Personal data

Individuals may request disclosure of retained personal information*. The Company accepts requests for disclosure of retained personal information as follows.

※Request for Disclosure, etc. means a request for notification of the purpose of use of retained personal data, a request for disclosure, correction, addition or deletion of content, suspension of use, erasure or suspension of provision to a third party of retained personal data, or a request concerning disclosure of records provided to a third party.

(1) How to entry and contact

Please attach the necessary documents to the prescribed application form and send it by postal mail (mail that can confirm the delivery record) to the "Personal Data Inquiry Desk" below.

※The fee for mailing the application form is to be borne by the customer.

※We would appreciate it if you could write "Application for Disclosure of Personal Information Enclosed" in red ink on the envelope.

※Please note that we will not accept requests for direct visits to the office of the Company.

(2) Documents to be Submitted, etc.

 (a) Request Form for Disclosure, etc. of Retained Personal Data

 (b) Agreement regarding handling of personal information

 (c) Documents verifying that the applicant is the principal or proxy

 (d) Postage stamps equivalent to the commission(When applying for a response that requires a fee)

(3) Documents to verify that the person who makes the Request for Disclosure, etc. is the principal or agent

 (a) Cases of Request for Disclosure, etc. by Principal

 A copy of the following identification documents shall be submitted.

 ①Identification documents sufficient for one of the following

 A copy of the identification document with a facial photograph issued by a government agency, such as a driver's license, passport, residence card, or individual number card (face containing the individual number is not required).

 ②Identification documents required for two different froms among the following

 A copy of the identification documents without a facial photograph issued by a government agency, such as a health insurance card, pension record, etc.

 (b) Cases of Request for Disclosure, etc. by Agent

 If the person making the Disclosure Request, etc. is a legal representative of the person, such as a minor, or a voluntary representative designated by the person, the following documents shall be submitted.

 ①Documents confirming the right of representation

 (i)Case of a legal representative

 ・In the case of a minor: A copy of the person's family register or a copy of the insurance card with dependents listed.

 ・In the case of an adult ward: matters to be certified as prescribed in Article 10 of the Act on Registration of Guardianship, etc.

 (ii)Case of a voluntary agent

 ・A letter of attorney and a certificate of registration of the applicant's seal impression.

 ②Documents for Identification of Agent

 A copy of the identification documents listed in (a) above shall be submitted with respect to the agent.

(4) The amount of the fee for a response that requires a fee

There are two types of responses that require a fee.

・When requesting "notification of the purpose of use" of personal data held by the Company

・To request the "disclosure" of personal data held by the Company

The amount of the fee is 1,000 yen per request (including tax and postage for returning the request by mail).

※Please enclose postage stamps in the amount equivalent to the fee with the submitted documents.

※If the fee is insufficient or not enclosed with the submitted documents, we will inform you of this. Please note that if the fee is not paid by the date specified by us, it will be assumed that no request for a response requiring a fee has been made.

※Please note that the fee will not be refunded even if the request cannot be met.

Measures taken for security control of retained personal data

(1) Formulation of Basic Policy

To ensure the proper handling of personal data, we have formulated basic policies regarding "compliance with relevant laws, regulations, guidelines, etc." and "response to inquiries and complaints.

(2) Establishment of Rules for Handling Personal Data

The Company has established regulations related to the protection of personal information by stipulating the handling of personal data at each stage of acquisition, use, storage, disposal, etc.

(3) Organizational Safety Control Measures

In addition to appointing a person responsible for the handling of personal data, the Company clarifies the divisions that handle personal data and the scope of their handling, and establishes a system for reporting any nonconformity (such as facts or signs of violation of the Personal Information Protection Law or personal information protection-related regulations) to the responsible person.

(4) Personnel Safety Control Measures

Regular training is provided to directors and employees on points to keep in mind regarding the handling of personal data.

(5) Physical security control measures

The office has access control and measures to prevent unauthorized persons from viewing personal data in areas where personal data is handled.

(6) Technical safety control measures

A system is in place to protect information systems that handle personal data from unauthorized external access or unauthorized software.

[Contact for Personal Information]
DIGITAL HEARTS HOLDINGS Co., Ltd.
Contact point for inquiries about personal information
〒163-1441 20-2, Nishi-Shinjuku 3-chome, Shinjuku-ku, Tokyo
Tokyo Opera City Building 41F
e-mail: privacy_DHhd@digitalhearts.com

This Privacy Policy is written in Japanese and translated into English. The Japanese version is the original, and the English version is for reference only. In the event of any conflict between these two language versions, the Japanese version shall prevail.