Hankyu Railway (“the Group”) believes that companies have an important obligation to appropriately manage and protect personal information that can be used to identify a customer, such as the customer’s name, address, telephone number and e-mail address (hereafter, “personal information”). Accordingly, the Group has set forth Privacy Policy Guidelines (“Policy Guidelines”) as follows.
1. Scope
These Policy Guidelines shall apply to all personal information handled by the Group.
2. Legal compliance
The Group shall comply with laws, governmental ordinances, national guidelines and other regulations regarding the handling of personal information, provided that those regulations are established in Japan.
3. Internal structures
The Group has put in place internal structures to facilitate the management of personal information, including by forming a department to oversee the protection of personal information and by assigning supervisors responsible for managing personal information in each of its departments.
4. Use of personal information
Whenever using personal information, the Group shall define the purpose of use of personal information and restrict the use of information to the scope necessary to achieve that purpose.
5. Acquisition of personal information
The Group shall acquire personal information using lawful and appropriate means.
6. Accuracy
The Group shall take appropriate measures to ensure that the personal information in its possession is accurate and up-to-date.
7. Security
The Group shall take necessary and appropriate measures to ensure the integrity of the personal information in its possession so as to prevent unauthorized access, loss, destruction, alteration, improper disclosure, or other misuse.
8. Supervision of subcontractors
When outsourcing the handling of personal information, the Group shall implement the necessary and appropriate supervision to ensure contractors manage personal information safely.
9. Disclosure and modification of personal information
The Group shall accommodate requests by individuals to access or modify their personal information in an appropriate manner and in accordance with predetermined procedures.
10. Cookies
A cookie is a small text file that the website sends to your device for the purpose of keeping records. It identifies your device, typically your web browser, but it cannot directly identify you.
Some cookies are necessary to operate its website (e.g. for establishing and keeping sessions), while other cookies may be used for the following purposes:
-Improving website functionality;
-Collecting analytical data to improve website performance;
-Delivering advertisements that may be of interest to you from us or our advertising partners based on information collected by tracking users across the internet;
Where the Group is required by applicable privacy/data protection laws, you can choose whether to allow us or third-parties (e.g. its analytics, advertising and social media partners) to set cookies which are not strictly necessary for the functioning of the website via the cookie banner and settings interface provided on the website.
11. Inquiries concerning personal information
Inquiries concerning personal information shall be accepted and processed by the following contact point.
<Contact（EEA and UK residents）>
As the Group is based outside of the EU/UK, Article 27 GDPR/UK GDPR required that the Group appoints an EU representative/UK representative to handle certain data subject requests and queries. In compliance with this, the Group has appointed DataRep to act as its representative. Any queries requiring the input of its representative, should please be directed to them as follows:
contacting us on its online webform at https://www.datarep.com/data-request, or mailing your inquiry to this address:
DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom
PLEASE NOTE: when mailing inquiries, it is ESSENTIAL that you mark your letters for ′DataRep′ and not ′Hankyu Railway′, or your inquiry may not reach us. Please refer clearly to Hankyu Railway in your correspondence.
<Contact Point（Non EEA and UK residents）>
Group Planning Division, Public Relations Dept. Hankyu Hanshin Holdings, Inc.
12. Ongoing improvements
The Group shall conduct periodic audits and review and improve its internal guidelines and structures on an ongoing basis to ensure that personal information is appropriately protected.