PRIVACY POLICY

SUNNY SIDE UP GROUP Inc. (hereinafter called the “Company”), believes that dealing with personal information in a proper manner is an important social responsibility and declares that it will strive to protect personal information according to the basic policy set out below.
All directors and employees abide by the Company Risk Compliance Program defining the standard of handling and protection, thereby increasing the trust of the public toward the Company.

The Company shall formulate and comply with the Compliance Program conforming to the Japanese Industrial Standard “Requirements for Compliance Program on Personal Information Protection” (JIS Q 15001) to protect personal information under strict management.
Personal information shall be limited to the scope necessary for business activities of the Company and shall be collected, used and provided accordingly.
The Company shall use collected personal information only for the scope agreed by the person.
The Company shall ensure prevention and correction of problems including unauthorized access, loss, destruction, falsification and leakage of collected personal information, accumulate and store securely under strict management, and take necessary corrective actions.
The Company shall also abide by laws and ordinances on the protection of personal information as well as other relevant norms.
The Company shall constantly review and improve its Compliance Program on the protection of personal information.

Established on January 24, 2005
Revised on January 1, 2020: SUNNY SIDE UP GROUP Inc. Etsuko Tsugihara, Representative Director

＜Contact Information on Personal Information＞: SUNNY SIDE UP GROUP Inc. Administration Division; Telephone: 03-6894-3233

Handling of Personal Information in the Company’s Services

The Company will handle the personal information collected in the Company’s services in the following manner:

In this policy, the personal information shall mean the personal information defined under the Personal Information protection Law, namely the information related to a living individual, and information that could identify a certain individual such as name, date of birth, and other descriptions included in the relevant information (including such that can be easily verified with other information, and by which a certain individual can be identifiable).
Acquisition of Personal Information
1. The Company will acquire personal information in a fair and lawful manner with the customer’s agreement.
2. In the event where personal information is acquired, the Company shall notify or disclose its purpose of use in advance.
The Company shall use the Personal Information within the scope necessary to attain the purpose of use for the following services:
1. Purpose of Use
  1. (１) for the purposes of performance of the rights and obligations under the contracts or laws in regards to the services provided by the Company.
  2. (２) for the purposes of proper and smooth execution of the services provided by the Company.
  3. (３) for the purposes of proper and smooth execution of entrusted services to process Personal Information, in whole or in part, by other enterprises.
  4. (４) for the purposes of research and development for the good and services through implementation of the market research and data analysis as well as questionnaire surveys.
  5. (５) for the purposes to operate and manage the seminars, lecture presentations exhibitions, etc. that are sponsored, co-sponsored, or participated by the Company
  6. (６) for the purposes of providing information for the goods and services offered by the Company through direct mails.
  7. (７) for the purposes of properly and smoothly handling businesses with the Company’s customers including communications and dispatching of greeting letters for the businesses
  8. (８) for the purposes to ensure the security of the Company including the use of its information systems and control of the access to its premises.
  9. (９) for the purposes of notifying and announcing the lecture presentations, and briefing sessions intended for the press, investors and analysts.
  10. (１０) for the Company’s recruitment purposes.
  11. (１１) for the purposes of managing the Company’s employees.
  12. (１２) for the purposes of handing the inquiries and feedback (including surveys) received from the Company’s clients.
  13. (１３) In addition to the above, the purposes for attaining other purposes explicitly provided.
2. Upon obtaining or using Personal Information from you,the Company shall: use such Personal Information to provide better services and responses.
3. The Personal Information provided by you shall not be normally disclosed to or provided to any third parties with the exception of the following cases:
  1. （1）When the Company has obtained your consent in advance;
  2. （2）when the disclosure of the Personal Information is necessary for the protection of human lives, bodies, or the properties, and it is otherwise difficult to obtain your consent;
  3. （3）when presentation of your information to financial institutions is required in order to process your payment via credit cards for the goods/services;
  4. （4）when the disclosure of such Personal Information was requested by orders issued by legal authorities, etc.
4. The Company may, from time to time, entrust Personal Information to its contractors within the scope necessary to attain the purpose of use. The Company shall designate appropriate contractors who are well-equipped with proper personal information protection systems, and it will also enter into an agreement with such contractors in regards to the protection of Personal Information.
5. Disclosure and Correction of Your Personal Information In the event where you desire to disclose or correct your own Personal Information, the Company shall handle such requests promptly, to the extent reasonably practicable. Contact us at our Inquiry Desk for any inquiries or corrections.
6. Other matters
  1. （1）If you do not wish to provide your Personal Information, you may elect so with your own discretion. However, the Company may not be able to provide the Services that Personal Information are essential for the Company to provide such services.
  2. （2）The Company may modify this policy as well as its company regulations in order to provide better protection toward Personal Information as well as in order to comply with changes in the laws and regulations.

＜Contact Information on Personal Information＞: SUNNY SIDE UP GROUP Inc. Administration Division; Telephone: 03-6894-3233

Basic Policy of Information Security

Basic Stance

Information is the most important asset for the Company. To protect information asset managed by the Company securely from the surrounding threats, it is necessary to establish sufficient and well-balanced information security management measures. Information asset can further increase its value by maintenance and commonality and it is essential for the continuity, maintenance and development of business. Positive approach toward establishment, introduction, operation, monitoring, review, maintenance and improvement of information security management measures strengthens a sense of solidarity of the organization internally, and furthermore, compliance with laws and ordinances enforced on businesses including the Act on the Protection of Personal Information enables the Company to gain trust from the public. It is our purpose to ensure through continuation of information security management that the strength of the Company is further enhanced externally for increased competitiveness.

Enhance customer’s sense of security and trust toward the Company by implementing information security measures.
The Company also asks its partner companies to acknowledge and understand the basic policy and stance of the Company to further enhance information security.
The Company holds training and briefing sessions for employees of the Company and its partner companies, carry out information activities and improve information security.

Action Guideline

（1） In daily operations, each and every one of employees clearly appreciates and grasps the importance of the value of information asset entrusted by customers, whether being presented or being made (undisclosed information asset), as well as the magnitude of risks to impede and cause damages to the Company and its business operations should such information be lost or leaked, and take and implement measures for management of information security enabling clear identification of the undisclosed information asset. At the same time, the Company also takes and implements security management measures for information security of the Company on its partner companies and do business under their cooperation.
（2）If there is any improvement necessary for daily business operations, business management regulations describing its countermeasures and rules shall be prepared and implemented.
（3）Furthermore, to ensure compliance with laws, norms and contract matters relating to information security and surrounding advertising industry, the Company carries out training and information activities regularly and from time to time for the employees and those of partner companies.

November 1, 2007: SUNNY SIDE UP Inc. Etsuko Tsugihara, Representative Director