Personal Information Protection Policy (Detailed Explanation)

1. Basic Policy

  1. NH Foods Ltd. (the “Company”, “we” “our”), in relation to the protection of personal information, complies with the “Act on the Protection of Personal Information” and other related laws and regulations, and also based on various guidelines provided by the Personal Information Protection Commission and other generally accepted customary practice regarding handling of personal information, we strive to properly acquire, use and otherwise handle the personal information.
  2. The Company will maintain internal rules concerning the handling of personal information and keep all employees including officers and employees informed. In addition, we will take responsibility for management of contractors to which the Company entrusts handling of personal information and will request such contractors to handle personal information appropriately.
  3. Regarding the safety management of personal information, the Company will appoint a chief administrator and seek to establish an organizational structure for the safety management measures, educate employees, manage areas handling personal information and manage safety regarding information media and information systems which manage personal data.
  4. With respect to any submissions of inquiries or complaints etc. raised from individuals identified from the personal information (“Principals”), as well as requests of disclosure, correction, addition, removal, suspension of use, deletion or suspension of provisions to third parties regarding the retained personal data, the Company will respond in good faith according to laws and regulations upon receiving such submissions or requests through the prescribed contact point.

2. Purposes of Use etc.

  1. The Company will acquire personal information necessary for the execution of our businesses and use it for the following purposes. We will not use personal information for purposes other than the following purposes without prior consent of the Principal, except where permitted by laws and regulations.
    • (1) Personal Information of Customers
      1. Providing information and services relating to our products and new products
      2. Shipping and responding inquiries for our gift products
      3. Questionnaire survey and analysis relating to various operations of the Company
      4. Sending out invitations or information on campaigns, exhibitions, events and other sales promotion activities relating to our products and new products, and the operations thereof
      5. Operating open factories (factory tours) hosted by the Company
      6. Operating online shops, mail orders etc. for our products
      7. Responding inquiries to our “Customer Communication Dept”
      8. Responding inquiries to our “Personal Information Inquiry Desk”
      9. Other business operations closely related to the above business operations
    • (2) Personal Information of Job Applicants
      1. Recruiting activities of our employees
      2. Other business operations closely related to the above business operations
    • (3) Personal Information of Business Partners
      1. Providing information and services relating to our products and new products
      2. Implementation and communication on joint development of products and technology
      3. Implementation and communication on business negotiations
      4. Providing services for entrusted works
      5. Providing producer traceability information for the purpose of breeding and fattening livestock
      6. Entry and exit control to our facilities
      7. Other business operations closely related to the above business operations
    • (4) Personal Information of Shareholders or Former Shareholders
      1. Information management of shareholders based on various laws and regulations
      2. Exercises of rights or performances of obligations by shareholders or the Company
      3. Providing services to shareholders and former shareholders
      4. Other business operations closely related to the above business operations
  2. The Company may share personal data of a Principal with our group companies. The purpose of use and items of the sharing personal data, the range of the sharing users, and the entity responsible for managing the sharing personal data are as follows.
    • (1) Purpose of Use and Items of Sharing Personal Data
      1. Purpose of use: purposes described in 1. above
      2. Items: name, address, telephone number, fax number, e-mail address, affiliation information (company name, department name, position title, etc.), inquired matters, requests, matters concerning purchase of products, matters concerning contracts
    • (2) Range of Sharing Users
      Our group companies
    • (3) Entity Responsible for Managing the Sharing Personal Data NH Foods Ltd.

3. Provision etc. to Third Parties

  1. To the extent necessary for achieving the purposes of the use stipulated in 1. of [2] above, the Company may provide personal data to contractors when entrusting all or part of handling the personal data to such contractors. In such case, we will request the contractors to handle the personal data appropriately. In addition, even after selection and entrustment to the contractors, the Company will confirm as necessary whether safety management in relation to personal data is being appropriately carried out by the contractors.
  2. The Company will not disclose or provide personal information of a Principal to third parties unless there is a situation which falls into one of the followings:
    • where the consent of the Principal is given regarding disclosure or provision to third parties;
    • where it is based on laws and regulations;
    • where it is necessary for the protection of life, body or property of a person and it is difficult to obtain consent from the Principal;
    • where it is particularly necessary to improve public health or promote the sound growth of children, and it is difficult to obtain consent from the Principal; or
    • where it is necessary to cooperate with the government agencies, local governments or contractors entrusted by them in carrying out the affairs prescribed by laws and regulations, and obtaining the consent of the Principal is likely to impede the execution of such affairs.

4. Management of Anonymously Processed Information etc.

  1. In cases where the Company creates anonymously processed information (meaning information on an individual obtained by processing personal information so that a specific individual cannot be identified, in accordance with the provisions of the laws and regulations, and that the personal information is not capable of being restored; the same applies hereinafter), we will carry out appropriate processing. Further, when the Company created anonymously processed information, we will publicize items of information contained in the said information, take measures for safety control measures and complaints handling, etc., and publicize such measures.
  2. When the Company created anonymously processed information, we will take security control measures of information such as the processing method and implement appropriate handlings.
  3. When the Company provides anonymously processed information to third parties, we will publicize the items of information to be provided and method of the provisions.
  4. When the Company uses the anonymously processed information on its own, we will not collate it with other information for the purpose of identifying the person relating to the original personal information.

5. Responding Desk to Requests from Principals

  1. With respect to handling of the personal information by the Company, any inquiries or other requests from a Principal will be received at “Personal Information Inquiry Desk” described below.
  2. Any requests of disclosure of retained personal data of a Principal raised by the Principal will be received by “Personal Information Inquiry Desk” described below. Disclosure requests will be responded within a reasonable period and to the extent reasonable in accordance with the prescribed procedure. However, please understand that we may not be able to fulfill your requests for disclosure due to laws and regulations, etc.
  3. Any requests for correction, addition or removal of retained personal data of a Principal raised by the Principal will be received by “Personal Information Inquiry Desk” described below. When a request for correction, addition or removal is raised, we will investigate and confirm in accordance with the prescribed procedure, and if the content of the said retained personal data is factually inaccurate, such retained personal data will be corrected, added or removed within a reasonable period and to the extent reasonable.
  4. Any requests for suspension of use or deletion of retained personal data of a Principal raised by the Principal will be received by “Personal Information Inquiry Desk” described below. When a request for suspension of use or deletion is raised, we will investigate and confirm in accordance with the prescribed procedure, and if it meets the requirements prescribed under laws and regulations, such retained personal data will be suspended from use or deleted within a reasonable period and to the extent reasonable.
    Please be advised that by suspending use or deleting, we may not be able to provide services as per your request.
  5. Any requests for suspension of provision of retained personal data of a Principal to third parties raised by the Principal will be received by “Personal Information Inquiry Desk” described below. When a request for suspension of third party provision is raised, we will investigate and confirm in accordance with the prescribed procedure, and if such retained personal data is provided to a third party in violation of laws and regulations, such retained personal data will be suspended from any third party-provision within a reasonable period and to the extent reasonable.
  6. How requests are to be received
    The Company will receive requests described in paragraphs 2 through 5 by the following method. Please be advised that we may not be able to fulfill your requests which are not submitted pursuant to the following method.
    <Acceptance of Requests>
    Please submit a written request addressed to the “Personal Information Inquiry Desk” in accordance with the following method. Please understand that we may ask about your personal information to the extent necessary to search your personal information when we receive your request. Also, please note that documents submitted at the time of your request and documents for identity verification that you are the Principal, etc. will not be returned.
    We will reply in writing after certain period of internal investigation.
    <Method of Requests>
    Documents, etc. to be submitted at the time of requests described in paragraphs 2 to 5 above:
    • Written requests concerning disclosure, correction, suspension of use of personal information.
    • Documents for identity verification of a Principal
      (In either of the below cases, please send us a copy of a document which shows the name and address of the Principal.)
      • (A) Please submit one of the followings (if they are with your photo):
        1) Driver's license, 2) Passport, 3) Basic Resident Registration Card with your photo, 4) Physical Disability Handbook with its certificate, or 5) Alien Registration Certificate
      • (B) Please submit two of the followings (if they are without your photo):
        1) Health Insurance Certificate for the insured persons, 2) various pension handbooks with their certificates, 3) Certified copy or extract of Family Register
    • If the requesting person is not the Principal but an agent, in addition to (A) or (B) of 2 above, the following documents shall be submitted by the agent:
      • (C) Documents for identity verification of the agent ((A) or (B) of 2 above)
      <Where delegated>
      • (D) A power of attorney in a form designated by the Company which is stamped with the registered seal of the subject person (Principal) of the disclosure
      • (E) Seal Registration Certificate of the subject person (Principal) of the disclosure
      <Where the Principal is a minor or a ward>
      • (F) Documents that prove that the agent is the statutory representative of the Principal (a certified copy or extract of the Family Register of the Principal, a judgment regarding commencement of wardship, etc.)
[Inquiry Desk for Personal Information]
Think Park Tower, 2-1-1 Osaki, Shinagawa-ku, Tokyo 141-6014
Personal Information Inquiry Desk, Legal Affairs Department
NH Foods Ltd.
TEL: +81-3-4555-8017

Note: Inquiries over phone can be received Monday through Friday (except public holidays) from 9:00AM to noon and from 1:00 PM to 5:30 PM (except for the Company’s Year-end and New Year Holidays as well as Bon Holiday Break).

6. Others

This Personal Information Protection Policy may be subject to renewal or revision without prior notice. Thank you for your understanding.

Revised as of April 1, 2019
NH Foods Group
NH Foods Ltd.
President and Representative Director
Yoshihide Hata