Hankyu Hanshin Holdings (hereinafter, “the Company”) believes that the Company has an important obligation to appropriately manage and protect information that can help identify individual customers, such as their names, addresses, telephone numbers and e-mail addresses (hereinafter, “personal information”). Accordingly, as a data controller, the Company has set forth Privacy Policy Guidelines as follows:

1. Personal Information to Be Subject to the Privacy Policy

All of the personal information the Company processes shall be subject to its privacy policy.

2. Compliance

The Company shall comply with laws, governmental ordinances, national guidelines, and other regulations regarding the processing of personal information.
The Company shall process personal information on any of the following legal bases:
・The Company has obtained the consent of the person whom the information is about (hereinafter, “the data subject”) or has communicated required matters to him or her in accordance with applicable laws and regulations.
・The Company is required to process the information to perform its obligations under its contract with the data subject.
・The Company is required to process the information to fulfil its legal obligations.
・The Company is required to process the information to secure its legitimate interests.

3. Company Structure

The Company shall set up a department which promotes activities to protect personal information and appoint a manager in charge of personal information in each division in order to establish an internal control function concerning personal information.

4. Use of Personal Information

The purposes of the use of personal information shall be clearly designated, and the use thereof shall be limited to the minimum necessary for the purposes.
The Company may provide personal information to a company to which it outsources the running of its websites in accordance with the General Data Protection Regulation (GDPR) for the purposes defined separately.
In such a case, the Company will transfer personal data based onEU-Japan adequacy(Article 45 of the GDPR).
The Company shall store personal information for the period necessary for achieving the purposes.

5. Acquisition of Personal Information

The Company shall acquire personal information in legal and appropriate ways.

6. Maintenance of the Accuracy of Personal Information

The Company shall take appropriate measures to maintain accurate and updated personal information.

7. Maintenance of the Security of Personal Information

The Company shall take necessary and proper security measures to prevent illegal access to personal information or the loss, destruction, falsification or leakage of personal information.

8. Supervision of Subcontractors

When outsourcing the processing of personal information to a subcontractor, the Company shall exercise necessary and proper supervision over that subcontractor to ensure the security of personal information.

9. Actions on the Rights of Individuals

The Company shall take appropriate actions at the requests of the data subject concerning the processing of personal information about him or her in accordance with applicable laws and regulations. The data subject may request the Company’s action by submitting any of the following requests, complaints, etc.:
・Request for access to the personal information
・Request for the rectification or erasure of the personal information
・Request for restriction on the processing of the personal information
・Complaint against the processing of the personal information
The data subject may lodge a complaint with the supervisory authority.
・Request for data portability of the personal information
・Request for the withdrawal of his or her consent for the processing of the personal information
・Objection against the processing of the personal information

10. Inquiries about Personal Information

Inquiries concerning personal information shall be accepted and processed at the following contact point.
>Contact Point of the Data Controller<
Group Business Development Department, Hankyu Hanshin Holdings, Inc.
Phone: +81-6-6373-5343
Office hours: 9:00 to 17:50, Japan Standard Time (closed on Saturdays, Sundays, New Year holidays, “Golden Week” holidays [from around the end of April to the first week of May], and other public holidays)

11. Continuous Improvement of Privacy Policy

The Company shall conduct regular audits to continuously revise and improve the in-house regulations as well as the company structure for the purpose of appropriately protecting personal information.

12. Language

The original version of this privacy policy was created in English. If there is any difference between a translated version of this privacy policy and the original English version, the original English version shall prevail.

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