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Recruit Group Media & Solutions SBU
Personal Data Policy

This Personal Data Policy sets forth the principles regarding the way in which employees of Recruit Co., Ltd. and its subsidiaries (hereinafter collectively the "Company") should treat any personal data obtained by the Company. Here, "personal data" includes any personal data of a user beyond the legal definition of "personal information."

Introduction

Arising from the belief in the Company's basic principle of "creating a brighter world where all individuals can live life to the fullest," we are committed to provide maximum options for data use, while respecting the expectations of our users and society.

When we utilize users' sensitive personal data, we are fully aware of our responsibility to not only comply with all laws and regulations but to respect and protect the privacy of our users.

With this mindset, we are committed to sincerely protecting, not only "personal information" as defined by law, but all our users' personal data.

Article 1 Purpose of Use

We use personal data only for the benefit of our users and society.

  • When we are an intermediary, we are committed to providing the maximum convenience and good for our users and enterprise clients. We will not use personal data in a way that benefits only enterprise clients. We will only use personal data in a way that benefits all of our users, increases convenience for them, and contributes positively to society.
  • We will not use personal data in a way that violates human rights, unfairly discriminates, or tends to favor any one social group.

Article 2 Scope of Use

Personal data is collected, used, linked or provided to external parties only to the extent necessary.

  • We will obtain personal data as necessary for the purpose for which we collect it and use it only to the extent necessary.
  • When linking or providing personal data to third parties, we limit such data to a minimum after fully considering the need for doing so. Furthermore, we appropriately identify the target data and its purpose so as to properly design control methodologies, taking into account the risk and impact of sharing such data and taking into account the third parties' data management practices.
  • Information that does not allow personal identification of a user, such as statistical data, is to be distinguished from personal data. However, before using such information, we make sure to confirm whether it is absolutely free from any piece of information that could be personally identifiable.

Article 3 Transparency and Opportunities for Choice

We provide transparency and opportunities for choice to our users when we utilize their personal data.

  • We examine information from a users' point of view and grant maximum data use transparency to the user so the user understands what personal data is collected and how it is utilized before they begin to use our services.
  • We provide users with the opportunity and means to accept or refuse our use of their personal data, where such use is not essential for the delivery of our services, even if we believe such data use would be beneficial for our users and society.

Article 4 Security

We protect personal data securely.

  • We do our utmost to protect the users' sensitive personal information to ensure they can use our services safely.
  • We strive to prevent our users' rights and interests from being damaged by external cyber-attack or internal fraud by appropriately implementing proper technological, procedural, and organizational measures.

Article 5 Internal mechanisms

We ensure we have internal processes in place to protect privacy.

  • We are committed to putting such processes in place to ensure the privacy-friendly use of personal data by our company including but not limited to:
    • appointment of a privacy protection manager and a risk assessment team for each service;
    • implementation of procedures ensuring a prior review before the use of any personal data by an expert privacy team;
    • provision of employee training; and
    • regular audits.
  • We strive in good faith to fulfill the ever-changing expectations of society by inviting external audits from outside experts, when necessary, including detailed verifications of all offered services before and after their launches.

DISCLAIMER
This document has been translated from Japanese original for reference purposes only. In the event of any discrepancy between this translated document and the Japanese original, the original shall prevail. Recruit Holdings Co., Ltd. assumes no responsibility for this translation or for direct, indirect or any other forms of damages arising from the translation.