Privacy Policy

Personal Information Protection Policy

Joint Use

Handling of Anonymously Processed Information

Handling of Location Information

Personal Information Protection Policy

Culture Convenience Club Co., Ltd. (hereinafter referred to as “the Company”) recognizes that, considering the importance of personal information protection, appropriately handling customers’ personal information in consideration of the nature and scale of its business constitutes its social responsibility.The Company hereby establishes the following Personal Information Protection Policy and ensures that all officers and employees comply with it to thoroughly protect personal information. The Company will also appropriately review and continuously improve its management system for the protection of personal information in response to changes in social needs and other circumstances.
Unless otherwise specified, terms used in this Policy shall be governed by the Act on the Protection of Personal Information (Act No. 57 of 2003, including subsequent amendments; hereinafter referred to as the “APPI”), related cabinet orders, regulations, and government guidelines.

１　Scope of Application

This Policy applies to the handling of customers’ personal information by the Company.When customers use individual services, events, seminars (hereinafter referred to as “Services, etc.”) or websites provided by the Company, the terms of use and privacy policies presented by the Company (hereinafter referred to as the “Terms, etc.”) may contain provisions regarding the handling of personal information. Please review them as well.In the event of any inconsistency between this Policy and the Terms applicable to individual Services, etc. or websites provided by the Company, the provisions of the relevant Terms shall prevail.

２　Compliance with Laws and Regulations

The Company shall comply with laws and regulations concerning the handling of personal information, as well as related rules, guidelines, and other norms established by the government.

３　Acquisition of Personal Information

When acquiring personal information, the Company shall notify or publicly announce the purpose of use (including publication through this Policy). When acquiring personal information directly from the individual via contracts or other documents (including electronic records), the Company shall clearly indicate the purpose of use in advance and acquire such information by lawful and fair means. Personal Information acquired by the Company includes the following:

（1）Information obtained directly from customers

（2）Information collected through the use of products and services provided by the Company or its partners

（3）Other personal information acquired in compliance with applicable laws, including the APPI

（4）Results obtained by analyzing the above items⑴through⑶(including the Company’s estimation of customers’ interests, concerns, lifestyle attributes, or tendencies, including lifestyle habits related to health maintenance and preventive care).

４　Use of Personal Information

Except when customer consent has been obtained or permitted by law, the Company shall use personal information only within the scope necessary to achieve the specified purposes that have been notified, published, or clearly indicated to customers. The Company will specify the purposes of use in the Services, etc. or websites used by customers, and in addition, will use personal information for the following common purposes:

（1）For Analysis

The Company may analyze customers’ personal information for the following purposes.In conducting such analysis, the Company may compare customers’ personal information with that of other customers, or, if customers use multiple products or services provided by the Company, link personal information across those products or services.The Company may also process personal information into statistical information, pseudonymously processed information, or anonymously processed information (and where required by law, will carry out necessary public notice procedures).

（2）For Information Provision

The Company may use customers’ personal information to provide the following information.Such provision may be tailored based on customers’ interests, concerns, lifestyle attributes, or tendencies derived from the above analysis.If you wish to stop receiving lifestyle proposals, please notify us through the method designated by the Company or the contact point described in Section 10.

５　Provision of Personal Information

Except as provided by laws and regulations, the Company will not provide customers’ personal information to third parties without obtaining prior consent from the customer.

６　Outsourcing Personal Information Handling

The Company may outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use.In such cases, the Company shall enter into an agreement with the contractor and provide necessary and appropriate supervision to ensure the safe management of personal information by the contractor.

７　Joint Use of Personal Data

When the Company jointly uses customers’ personal data, the Company will notify customers of the matters required under the APPI or make such information readily accessible to customers by posting it on the Company’s website or by other appropriate means.

８　Management of Personal Information

The Company shall take necessary and appropriate measures to prevent leakage, loss, or damage of personal information handled by the Company and to otherwise ensure its secure management.

９　Requests for Disclosure, etc.

When a customer requests notification of the purpose of use, disclosure, correction, addition, or deletion of content, suspension of use, erasure, suspension of provision to third parties, or disclosure of records of third-party provision (hereinafter collectively referred to as “Disclosure, etc.”) regarding his or her own personal information, the Company will confirm the identity of the requester and respond appropriately.For specific request procedures, please contact the inquiry desk described in Section 10.

１０　Handling of Complaints and Inquiries

The Company has established a contact point for handling complaints and inquiries from customers regarding the handling of personal information and will respond appropriately.
The contact point is available here.

The Company will jointly use personal data as follows:

１．Joint Use of Customers’ Personal Data

（1）Items of Personal Data Subject to Joint Use
Items described in “３　Acquisition of Personal Information” of the Personal Information Protection Policy.

（2）Scope of Parties Using the Data Jointly
The Company’s consolidated subsidiaries and equity-method affiliates.

（3）Purpose of Use by the Parties
Purposes described in “４　Use of Personal Information” of the Personal Information Protection Policy.

（4）Name of the Party Responsible for Management of Personal Data
Culture Convenience Club Co., Ltd.
（For address and representative name, please refer to “Company Overview.”）

２．Joint Use of V Member Personal Data

（1）Items of Personal Data Subject to Joint Use
Items of personal information specified in Article 4, Paragraph 2 of the V Membership Terms.

（2）Scope of Parties Using the Data Jointly
The Company’s consolidated subsidiaries and equity-method affiliates.

（3）Purpose of Use by the Parties
Purposes described in Article 4, Paragraph 3 of the V Membership Terms.

（4）Name of the Party Responsible for Management of Personal Data
V POINT MARKETING Co., Ltd.
（For address and representative name, please refer to the company’s “Company Overview.”）

*“V Member” refers to an individual who has agreed to the V Membership Terms and completed the prescribed membership registration procedures to receive services for V Members selected by V POINT MARKETING Co., Ltd. (Please refer to theV Member Terms of Use for details.)

３．Others

In addition to the above 1 and 2, the Company may jointly use customers’ personal data.In such cases, the Company will notify customers of the matters required under the APPI or make such information readily accessible by posting on the Company’s website or by other appropriate means.

Handling of Anonymously Processed Information

The Company complies with the APPI and related cabinet orders, regulations, and government guidelines, and continuously creates and provides anonymously processed information to third parties after taking appropriate protective measures to prevent identification of specific individuals and restoration of the personal information used for its creation.

1. Items of Information Contained in Anonymously Processed Information and Items Provided to Third Parties

The Company creates and provides anonymously processed information by applying measures such as partial deletion, substitution, and generalization to customers’ identifiers, personal attribute information (gender, date of birth, address), and purchase history (including service usage history and survey responses).

2. Methods of Creating Anonymously Processed Information

In accordance with the processing standards prescribed by the APPI, the Company creates anonymously processed information from the items described above through the following processing methods, individually or in combination:

Main Processing Methods and Examples

Converting member numbers and other identifiers into random strings that cannot be re-identified
Converting date of birth into year and month of birth
Converting address into postal code (first three digits only)
Converting purchase history for a certain period into purchasing trends
Deleting items that can identify a specific individual (including combinations of descriptions that enable identification)
Deleting items that can identify a specific individual (such as name and telephone number)
Pseudonymizing items that can identify a specific individual
Generalizing items that may lead to identification of a specific individual or restoration of original personal information
When aggregation results for individual items result in a single case, processing the data to a state where individuals cannot be identified

3. Method of Providing Anonymously Processed Information

When providing anonymously processed information to third parties, the Company ensures security through encryption, password protection, or similar measures, and provides the data via secure data transfer, physical recording media, or documents.

4. Security Control Measures for Anonymously Processed Information

The Company establishes internal regulations and implements appropriate security control measures. Based on these internal regulations, the Company provides education and supervision to employees handling anonymously processed information.

Handling of Location Information

The Company and its consolidated subsidiaries or equity-method affiliates (hereinafter collectively referred to as “the Group”) acquire device location information (GPS location information obtainable from devices, Bluetooth information, etc.) generated when customers use application services provided by the Group (hereinafter referred to as the “Services”), including when customers have always enabled background location tracking.Such information will be used within the scope of the purposes specified in the Company’s Personal Information Protection Policy, Article 4, Paragraph 3 of the V Membership Terms, and each application’s terms of use.