Definition of Personal Information
OEN, Inc. recognizes personal information to be the following. Personal information is information related to a living individual as set out in the Act on the Protection of Personal Information (name, date of birth, and other personally identifiable information) as well as information linked to a specific individual, such as email addresses, user IDs, passwords, and credit card information. It also includes segment information combined with personal information such as hobbies, family structure, age, and other personal segment information.
Cookies and IP Address Information
We do not consider cookies and IP addresses to be personal information as they cannot identify a specific individual alone. However, when the information is used in combination with personal information, we deem the information to be personal information. For the media run by OEN, Inc., the purpose and method will be disclosed when using cookies and IP addresses, even if they do not identify a specific individual. Also, cookies information can be blocked through a browser setting. If you are unable to receive services when cookies are blocked, we will disclose that information.
Specifying the Usage Purpose of Personal Information
When handling personal information, OEN, Inc. shall specify the usage purpose as much as possible.
Limitations to the Usage of Personal Information
OEN, Inc. does not handle personal information beyond the scope necessary to achieve the usage purpose without a prior agreement from the person concerned. For cases where personal information has been obtained through a merger or other reasons, the personal information will not be handled beyond the scope of the usage purpose prior to the inheritance without an agreement from the person concerned in advance. However, the following situations shall be exceptions.
(1) When it is based on laws and regulations
(2) When there is a need to protect human life, body, or property and it is difficult to get an agreement from the person concerned
(3) When there is a need to improve public health and promote healthy growth of children, and it is difficult to get an agreement from the person concerned
(4) When it is necessary to cooperate with tasks set out by laws and regulations that are conducted by a government agency, a local public entity, or a party consigned, and when getting an agreement from the person concerned could interfere with conducting the said work
Appropriate Obtainment of Personal Information
OEN, Inc. shall obtain personal information through appropriate means and shall not obtain information through falsification and other illegal means. Also, caution shall be exercised not to indiscriminately collect personal information from children under age fifteen without parental consent.
Notice of Usage Purpose when Obtaining Personal Information
OEN, Inc. shall disclose the usage purpose in advance when obtaining personal information. However, this shall not apply to the following situations.
(1) When notifying the usage purpose to the person concerned or making it public could harm the life, body, property, or other rights and interests of the person concerned or third parties
(2) When notifying the usage purpose to the person concerned or making it public could harm the rights and rightful interests of OEN, Inc.
(3) When it is necessary to cooperate with tasks set out by laws and regulations that are conducted by a government agency or a local public entity, and when notifying the usage purpose to the person concerned or making it public could interfere with conducting the said work
(4) When the usage purpose is clear from the obtainment situation
Changes to the Usage Purpose of Personal Information
When changing the usage purpose of personal information, OEN, Inc. shall not do so beyond a reasonably recognized scope that is sufficiently related to the usage purpose before the change and shall notify the person concerned about the changed usage purpose, as well as making it public.
Safety Management of Personal Information and Supervision of Employees
OEN, Inc. sets out a Personal Information Protection Regulation to ensure the prevention of leakage, loss, or damage of personal information and to conduct other personal information safety controls, and provide the necessary and appropriate supervision to employees.
Supervision of Consignees
When consigning whole or part of personal information handling, OEN, Inc. shall conclude a contract with the consignee that includes a confidentiality protection clause or request agreement to the policy set by OEN, Inc. OEN, Inc. shall also provide necessary and appropriate supervision to ensure safety controls of the personal information by the consignee.
Third-party Provision Limitations
OEN, Inc. shall not provide personal information to a third party without the prior agreement from the person concerned, except for the following situations listed.
(1) When it is based on laws and regulations
(2) When there is a need to protect human life, body, or property and it is difficult to get an agreement from the person concerned
(3) When there is a need to improve public health and promote healthy growth of children, and it is difficult to get an agreement from the person concerned
(4) When it is necessary to cooperate with tasks set out by laws and regulations that are conducted by a government agency, a local public entity, or a party consigned, and when getting an agreement from the person concerned could interfere with conducting the said work
(5) When following matters are notified or made public in advance:
1．Usage purpose includes provisions to third parties
2．Date items provided to third parties
3．Means and methods of provisions to third parties
4．Stopping provision of personal information to third parties when requested by the person concerned
However, the following shall not correspond to the third party indicated above.
(1) When OEN, Inc. consigns a whole or part of personal information handling within the scope necessary to achieve the usage purpose
(2) When personal information is provided as a result of business transfer such as a merger and other reasons
(3) When personal information is shared and used between specific parties, and that fact, categories of shared and used information, the scope of persons for the shared usage, usage purpose of the user, and the name/title of the manager responsible for managing the said personal information, are notified to the person concerned in advance, or the person concerned can easily know the above information.
Public Disclosure of Matters Related to Personal Information
For the following matters related to personal information, OEN, Inc. shall have them easily known for the person concerned and promptly respond to requests from the person concerned.
(1) The usage purpose of personal information (excluding information not obligated in the Act on the Protection of Personal Information. If we decide not to answer, we will promptly notify the person concerned regarding the matter.)
(2) Inquiry Desk Regarding Personal Information
Disclosure of Personal Information
OEN, Inc. shall promptly disclose personal information to the person concerned when requested by the person concerned. However, if it corresponds to one of the following regarding the disclosure, we may not disclose whole or part of the information. We shall promptly give notification if we decide not to disclose the information.
(1) If there are risks of harming the life, body, property, and other rights or interests of the person concerned or third parties
(2) If there are risks of causing significant disruption to OEN, Inc. conducting work appropriately
(3) If other laws and regulations are violated. In principle, we do not disclose information other than personal information such as access logs.
Correction of Personal Information
If the person concerned requests OEN, Inc. to correct, add or delete (hereafter referred to as “corrections”) personal information because the information is false, OEN, Inc. shall conduct necessary investigations promptly and implement corrections on the personal information content based on the results, then notify the person concerned, unless other provisions of laws and regulations set special procedures.
Usage Suspension of Personal Information
If the person concerned requests usage suspension or deletion (hereafter referred to as “usage suspensions”) for reasons such as the personal information of the person concerned was used beyond the scope of usage purposes announced in advance, or the personal information was obtained through falsification or other illegal means, OEN, Inc. shall promptly conduct necessary investigations and conduct usage suspensions of personal information based on the results, then notify the person concerned. However, if the usage suspensions of personal information cost large amounts of money or if usage suspensions are hard for other reasons, and if another measure to protect the rights or interests of the person concerned can be taken, the alternative measure shall be taken.
Explanation of Reasons
OEN, Inc. shall strive to explain the reason to the person concerned when deciding the following despite requests from the person concerned:
(1) Not notifying the usage purpose
(2) Not disclosing whole or part of personal information
(3) Not conducting usage suspensions of personal information
(4) Not suspending provisions of personal information to third parties
Inquiry
For the following matters related to personal information, OEN, Inc. shall have them easily known for the person concerned and promptly respond to requests from the person concerned.
(1) The usage purpose of personal information (excluding information not obligated in the Act on the Protection of Personal Information. If we decide not to answer, we will promptly notify the person concerned regarding the matter.)
(2) Inquiry Desk Regarding Personal Information
Please contact the representative below if you have any inquiries regarding the privacy policy of OEN, Inc. Abema Towers 40-1 Udagawacho Shibuya-ku,Tokyo 150-0042
OEN, Inc. Privacy Policy Management Representative, Legal & Compliance Office