LY Communications Corporation (the “Company”) recognizes that the fair and honest handling and careful protection of the following information are important management issues; namely, information relating to a living individual which contains a name, date of birth, or other identifier or the equivalent that can be used to identify a specific individual (this includes any information that can be easily collated with other information and thereby used to identify that specific individual; hereinafter, “Personal Information”).
In addition to complying with the laws and regulations applicable in the countries and regions where the Company operates its business, the Company is also committed to protecting Personal Information in an appropriate manner in accordance with this LY Communications Privacy Policy (this “Policy”), while taking ethical and social perspectives into account.
Furthermore, in order to protect Personal Information on an ongoing and permanent basis, this Policy will be reviewed from time to time in accordance with changes in social norms, and the organization as a whole will strive to handle Personal Information in an appropriate manner.
At the same time, the Company will continuously review its Personal Information Protection Management System from the perspectives of safety and efficiency.
This Policy applies to all Personal Information handled by the Company.
The Company will use any Personal Information to the extent necessary for the following purposes of use. In addition, when the Company acquires Personal Information directly from users in writing (including input via the Company’s website) or it becomes necessary for the Company to access users’ Personal Information, the Company will clearly indicate the purposes thereof, etc. and obtain their prior consent before acquiring or accessing the relevant Personal Information.
Please note that the Company may record the content of the calls in writing, audio or electronic means in order to accurately monitor the content of inquiries, etc. and to improve the quality of the services.
The Company shall acquire Personal Information, such as the information listed below, in a fair and lawful manner:
・Contact information such as name, address, telephone number, and email address;
・Image data such as facial and physical appearance;
・Audio data, such as records of customer service interactions;
・Data registered for services provided by the Company (e.g., name, address, image data); and
・Mobile service usage history (including cookies and advertising identifiers) and browsing history
The Company acquires and uses Personal Information within the scope of the following purposes of use:
・To handle inquiries and comments to the Company;
・To propose products and services, conduct business negotiations, perform contracts, and carry out necessary work-related communications toward users;
・To provide information about events, seminars, exhibitions, etc. by direct mail, email, telephone, and other communication channels;
・To sell and ship products and to provide services;
・To provide various mobile and web media services (including apps);
・To provide information about products and services of third parties, such as business partners;
・To engage in the Company’s public relations activities both internally and externally;
・To monitor suspicious persons by installing security cameras, etc., and to control entry to and exit from facilities; and
・To confirm the content of calls, to assess the quality of customer service interactions, and to provide education and training
・To propose products and services, conduct business negotiations, perform contracts, and carry out necessary work-related communications toward users;
・To provide information about events, seminars, exhibitions, etc. by direct mail, email, telephone, and other communication channels; and
・To manage information on business partners
The purposes of use of Personal Information concerning hiring and applications are separately publicized link(This page is currently only available in Japanese).
The purposes of use of Personal Information concerning employees shall be separately established in the Company’s internal regulations.
The purposes of use of Personal Information concerning services provided by the Company are separately publicized link(This page is currently only available in Japanese).
The Company shall use Specific Personal Information to the extent necessary for the following purposes of use in accordance with the Act on the Protection of Personal Information (Act No. 57 of 2003) (the “Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of 2013), and other related laws and regulations.
In addition, when the Company acquires Specific Personal Information in writing directly from a specific individual identifiable by the relevant Personal Information (the “identifiable person”), the Company shall clearly indicate the purposes of use to the identifiable person each time. Furthermore, in the case of acquiring Specific Personal Information directly by other means or indirectly from a person other than the identifiable person, the Company shall use Specific Personal Information within the scope necessary to achieve the following purposes of use.
・To perform processes such as collection and registration of Specific Personal Information, etc. in the course of processes using individual numbers or processes related to individual numbers, and to handle inquiries in relation to the foregoing under entrustment services;
・To perform processes for preparation of payment records for remuneration, fees, etc.;
・To perform processes for payment records concerning real estate transactions, etc.;
・To perform processes for payment records for dividends, distributions of surplus, and interest on funds
・To perform processes for withholding tax certificates;
・To perform processes for statutory documents related to financial instruments transactions under the Workers’ Property Accumulation Savings System;
・To perform processes related to resident tax;
・To perform processes related to social insurance;
・To perform processes related to national and corporate pensions;
・To perform processes related to labor insurance;
・To perform processes for legal documents related to financial instruments transactions pertaining to shareholding associations
When the Company receives Personal Information and Specific Personal Information from an entrustor to perform operations, the Company shall use such Personal Information and Specific Personal Information to the extent necessary to achieve the purposes of the operations entrusted to the Company, and shall handle the same in an appropriate manner. The Company may record the content of inquiries handled under the entrusted operations in writing, audio or electronic means in order to enhance service satisfaction through confirmation of content of calls, assessment of the quality of customer service interactions, and provision of training sessions based on such assessment.
The Company stores the Personal Information and Specific Personal Information of Japanese users in data centers in Japan, the United States and Korea. The Company has established a basic policy for the proper management of Personal Information, and manages Personal Information and Specific Personal Information by taking strict organizational, human, physical and technical security measures to prevent any leakage, loss or damage, etc. of Personal Information.
The Company shall not disclose or provide to any third party any Personal Information that is registered in a database that is systematically organized in order to be easily searchable for specific Personal Information (Personal Information registered in such database shall hereinafter be referred to as “Personal Data”) or Specific Personal Information; provided, however, that the Company may provide Personal Data to third parties in the following cases:
・cases in which the consent of the identifiable person is obtained;
・cases based on the laws and regulations;
・cases in which there is a need to protect the life, wellbeing, or property of an individual, and it is difficult to obtain the consent of the identifiable person;
・cases in which there is a special need to improve public wellbeing or promote the healthy development of children, and it is difficult to obtain the consent of the identifiable person;
・cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by the laws and regulations, and it is difficult to obtain the consent of the identifiable person;
・cases in which Personal Information is provided when a person succeeds to a business due to a merger or other such circumstances, and such Personal Information is handled within the scope necessary for achieving the pre-succession purposes of use for such Personal Information; or
・cases in which Personal Information is entrusted to a third party within the scope of the purposes of use
The parties to which Personal Data or Specific Personal Information are provided include third parties such as entrustees in the relevant user’s country or region and LY’s group companies to which the Company belongs (meaning LY Corporation’s subsidiaries or affiliates, including subsidiaries or affiliates located outside of Japan, as defined in the Japanese “Regulation on Terminology, Forms, and Preparation Methods of Financial Statements”). (For information on systems concerning the protection of Personal Data in the countries or regions to which the third parties belong (the third parties herein mean the parties to which the Personal Data or Specific Personal Information are provided), please refer to “Systems Concerning Protection of Personal Information in Each Country.”
Parties to which Personal Data or Specific Personal Information are provided: Japan, the United States, South Korea, Thailand, and Taiwan
When accessing Personal Data provided by the Company, access may occur from another country that does not have the equivalent level of Personal Data protection legislation as that of Japan. Even when such access occurs from such other country, the Company will implement necessary measures to protect Personal Data in an appropriate manner in accordance with its security standards, such as by way of: (i) requiring the entrustees performing such access to conduct appropriate security management by executing an entrustment agreement, etc. therewith; and (ii) taking measures such as management and supervision; as well as (iii) taking appropriate encryption measures in access routes to Personal Data; and (iv) establishing a system to ensure that entrustees comply with the Personal Information protection systems of the countries in which they are located.
The Company may entrust third parties with certain operations that are necessary to provide the Company’s services. Upon such entrustment, the Company shall entrust all or part of the Personal Data to such third parties, including entities located in the countries or regions specified below.
These entrustees will only have access to the minimum amount of Personal Data necessary to perform the operations on behalf of the Company and will not use Personal Information beyond the scope of their entrusted operations.
The Company will comply with the applicable laws, examine entrustees for their eligibility, stipulate confidentiality obligations when executing contracts, and thereby establish a system to ensure that entrustees comply with the systems for protection of Personal Data in the countries where the entrustees are located and that Personal Data is properly managed.
Parties to which Personal Data or Specific Personal Information are transferred: Japan, the United States, South Korea, Thailand, and Taiwan
To the extent necessary to achieve the purposes of use, the Company may jointly use Personal Data acquired by the Company with the group companies or third parties that the Company reasonably determines to be necessary and appropriate. Please refer to the “List of Group Companies” for a list of the group companies among which joint use is conducted.
The Personal Data to be jointly used is the same as the items listed in 3.a. above.
The purposes of joint use are the same as the purposes of use specified in 3.b.i and 3.b.ii above (provided, however, that, regarding the purposes of use, the term “the Company” shall be deemed to be replaced with the name of the company with which the joint use is conducted and the term “the Company’s services” shall be deemed to be replaced with the services provided by the company with which the information is jointly used).
The Company shall serve as the person responsible for management of the joint use.
Please use the contact information specified in “12. Inquiries” at the end of this Policy for any request to disclose, correct, add, cease the use of, cease the provision of to third parties, delete content from, or otherwise notify the purposes of use of the Company’s Personal Data (“Disclosure Request, Etc.”). When a user requests the Company to disclose Personal Information that cannot be confirmed in the Company’s services, or to notify a user of the purposes of use, such user may request disclosure to the extent permitted by the laws and regulations, except in the following cases:
・If disclosure is likely to harm the life, wellbeing, property, or other rights or interests of the identifiable person or a third party;
・If disclosure is likely to seriously interfere with the proper implementation of the Company’s business;
・If disclosure would violate the laws or regulations; or
・If the Company cannot confirm that the request is being made by the identifiable person him/herself
If disclosure reveals that the Company’s Personal Information is incorrect, the relevant user may request the Company to correct, add, cease the use of, cease the provision of to third parties, or delete content from the Personal Information. In this case, the Company shall investigate without delay to the extent necessary to achieve the purposes of use, and based on the result thereof, the Company shall correct, add, cease the use of, cease the provision thereof to third parties, or delete content from such Personal Information.
If a user requests the Company to disclose Personal Information that cannot be confirmed in the Company’s services, the Company may charge disclosure fees pursuant to the procedures separately stipulated by the Company.
The Company’s services are intended for general users. When a user who is a minor provides his/her Personal Information in using the Company’s services, such minor user must only do so after obtaining the consent of his/her guardian.
The Company may use cookies and other technologies provided by other companies to monitor and analyze the access status to this website. Visitors to this website have the right to choose whether or not to accept cookies. Each user should check the settings of the browser he/she is using regarding the choice of accepting cookies.
To enhance the Company’s services, the Company uses Google Analytics provided by Google to measure the Company’s services, including its website. In order to obtain data, Google may set cookies or read existing cookies. On such occasion, information such as the URLs of the pages users have accessed and users’ IP addresses will be automatically sent to Google. The Company may use such information for monitoring usage status and the Company’s services, etc. Please confirm the Google Analytics Terms of Use and Google’s Privacy Policy for Google’s handling of data in Google Analytics.
This Policy may be revised from time to time, and the latest version of this Policy shall be available on this website at all times. When making important changes, the Company will notify users of such changes in a clear and concise manner. Please fully confirm the content of the latest version of this Policy.
For any questions concerning this Policy, any questions, complaints, or concerns concerning the handling of Personal Information, or any request for Disclosure Request, Etc., please contact us using the inquiry form or by mail to the following address.
12F JRJP Hakata Building, 8-1 Hakata Station Chuo-gai, Hakata-ku, Hakata-shi, Fukuoka, 812-0012
Attention: LY Communications Corporation, Information Security Department
Person Responsible for Personal Information Protection
Risk Management Division General Manager
Established on June 1, 2024
LY Communications Corporation
Yusuke Suzuki, Representative Director/President/CEO