NDR - Privacy Policy

1. Definition of Personal information

NDR Co., Ltd. (hereafter referred to as NDR) treats the following information pertaining to an individual as specified in the Personal Information Protection Law as the PERSONAL INFORMATION and strives to protect the same.

	Name, Date of Birth, any other information that uniquely identifies an individual such as ID card number etc.
	Other information connected with an individual such as E-mail address, User ID, Password etc.
	Other personal attributes such as Hobby, Family details, Age etc.

2. Cookie and IP address information

NDR does not treat Cookie and IP address as PERSONAL INFORMATION, since these cannot specify an individual by themselves. However, if these are used along with other Personal information as an unit, then it is also treated as PERSONAL INFORMATION.
In case of NDR’s media, even if the Cookie and IP address information is unable to identify a particular individual, the purpose and the usage of the Cookie and IP address is disclosed explicitly. The cookie information can be rejected (disabled) by making suitable settings in the browser. In case of services that cannot be used if cookies are disabled, that will be explicitly mentioned too.

3. Purpose of Personal Information Usage

NDR defines the purpose of the usage of the personal information to the best possible extent.

4. Restriction/Limitation of Personal information Usage

NDR shall not use the personal information beyond the necessary level for any purpose, without the prior approval of the concerned individual. Even in case of M & A, NDR shall not use the acquired personal information before the acquisition beyond reasonable limits without the permission of the concerned individual. However, the same may not be applicable in the following cases.

	When the usage is enforced by law
	When the usage is absolutely necessary to protect life, body or a property of a person and it is impossible to get the consent of the individual (owner of such data).
	When the usage is absolutely required for the promotion of public health improvement and healthy growth of the children and it is impossible to get the consent of the individual (owner of such data).
	When it is very much necessary to cooperate with national government organizations, regional public organizations or any other contractor working under these organizations, in order to implement the work enforced by the law and it is impossible to get the consent of the individual(owner of such data).

5. Appropriate acquisition of Personal information

NDR always acquires Personal information in appropriate and fair manner and shall not acquire information in illegal way. Further, in case of children below the age of 15, NDR shall not acquire their personal information without the consent of their legal parent/ guardian by tampering.

6. Notification of purpose of acquisition of Personal Information

NDR shall publicly disclose the purpose and usage of the personal information before acquisition. However, there are following exceptions.

	When there is an apprehension about harm to the life, health, property or any other rights or profits of individual or third party that may be caused by the notification of purpose of acquisition to the individual or by the public disclosure of the same.
	When there is an apprehension about loss of rights or legitimate profits that may be caused by the notification of purpose of acquisition to the individual or by the public disclosure of the same.
	When it is very much necessary to cooperate with national government organizations, regional public organizations in order to implement the work enforced by the law and when there is an apprehension about extending damages or problems to the implementation of this work that may be caused by the notification of purpose of acquisition to the individual or by the public disclosure of the same.
	When it is already clear about the purpose of acquisition by looking at the status of information acquisition.

7. Change in usage of the Personal Information

In case of changing the purpose of personal information usage, the usage shall not change beyond reasonable limits. NDR shall inform the concerned individual or publicly disclose the new usage or purpose.

8. Safety(Security) Control of Personal information and employee supervision

NDR has established a Basic Information Security procedure and an exhaustive Information Security policy, has an Information Security management committee that suitably and appropriately supervises and manages the employees, in order to prevent the leak, loss or damage to the personal information and hence implement an efficient Information Security Control. NDR suitably manages its employees when they are made to use the personal information of certain individuals and ensures the information security.

9. Supervision/ Management of the Contractor

In case of outsourcing the handling and usage of the personal information to a contractor (completely or partially), NDR shall ensure that Non-Disclosure Agreement (Information Security agreement) is signed with the contractor or that the contractor agrees and abide by the terms and conditions of NDR regarding the Information Security. Further, NDR shall closely supervise and manage the contractor so that information security is ensured..

10 .Limitations about information provision to Third Party

NDR shall not provide the personal information to the third party without obtaining the consent of the individual in advance, except in the following circumstances.

When it is enforced by law

	When the usage is absolutely necessary to protect life, body or a property of a person and it is impossible to get the consent of the individual (owner of such data).
	When the usage is absolutely required for the promotion of public health improvement and healthy growth of the children and it is impossible to get the consent of the individual (owner of such data).
	When it is very much necessary to cooperate with national government organizations, regional public organizations or any other contractor working under these organizations, in order to implement the work enforced by the law and it is impossible to get the consent of the individual(owner of such data).
	When NDR has informed or publicly announced the following in advance
	Provision of information to the third party is clear in the purpose (usage) of information
	Data items to be provided to the third party
	Procedure and Methods of data provision to the third party
	The provision of data to the third party shall not be done, when there is a request from the concerned individual.

However, in the following cases, it does not correspond to the third party.

	When NDR assigns the data handling task either completely or partially to another party, within the reasonable limits with the intention of fulfilling the purpose of data acquisition.
	When providing personal information in case of merger or other business succession reasons.
	When it is necessary to share the information with a particular person or entity and the following has been informed to the concerned individual in advance or if these are kept ready so that the concerned individual can access these information at any time very easily.
	When it is already clear about the purpose of acquisition by looking at the status of information acquisition.

	Fact that the personal information shall be shared with an entity
	The information that would be shared
	The limitations of the entity with whom the information would be shared
	The purpose of the sharing
	The name of the person (administrator) who would be responsible for the information management

When it is necessary to share the information with a particular person or entity and the purpose of sharing or the name of the person (administrator) in charge of the information management changes, the contents of the changes shall be informed to the concerned individual in advance or it is kept ready so that the concerned individual can access it at any time very easily.

11.Publication of personal information

NDR shall ensure that the information shall be easily accessible by the concerned individual and also shall reply without delay whenever there is any query from the individual, in the following cases.

	Usage details of the personal information (However, this is exempted if there is no obligation according to the Personal information Protection policy. If it is decided not to reply the individual, the same is informed to the individual without delay.)
	Contact person details regarding personal information

12. Disclosure of personal information

NDR will provide personal information to the individual on request without any delay. However, if the disclosure would lead to any of the following, NDR may not disclose the information completely or partially. In such cases, the same would be explained to the individual without any delay.

	When there is an apprehension about harm to the life, health, property or any other rights or profits of individual or third party.
	When there is an apprehension about damage to the correct operation of NDR.
	When this would lead to the violation of other rules and regulations.

In general, information other than personal information like access log etc. shall not be disclosed.

13. Correction of Personal Information

When NDR is informed by the individual that the existing personal information is wrong and modification, addition or deletion (henceforth, collectively referred to as Correction) is requested, NDR shall consider this request, perform the necessary investigation within the reasonable limits necessary for the achievement of the usage purpose without further delay, correct the information based on the result of the investigation performed and notify the individual about the completion of correction, in all cases except when any special procedure has to be implemented due to the other rules and regulations.

14. Suspension of personal information usage

When NDR is informed by the individual that the usage of the personal information is beyond reasonable limits that were disclosed prior to the usage or that the personal information has been acquired in an illegal manner, and hence the suspension of the usage of personal information or deletion of the personal information (henceforth collectively referred to as Usage suspension) is requested, NDR shall investigate the same without delay, suspend the usage of the personal information based on the investigation result and inform the same to the concerned individual. However, if the usage suspension requires large expenses and hence it becomes difficult to suspend the usage, NDR shall discuss with the individual and take alternative measures to protect the rights of the individual.

15. Explanation of reasons

When NDR shall not

	notify the usage purpose OR
	disclose the personal information either completely or partially OR
	suspend the information usage OR
	suspend the provision of information to a third party

despite the request from the individual, NDR shall strive hard to explain the reason to the individual to the best possible extent.

16. Contact

Please contact the following in case of any queries regarding the Privacy policy of NDR.

Privacy policy desk
NDR Co., Ltd.
2F, Sumitomoseimei Minatomachi
MT Bldg., 1-18-4,
Minamihorie, Nishi-Ku,
Osaka 550-0015, Japan.

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