Personal Information Protection Policy

Revised on April 1, 2022

Shochiku Co., Ltd. (“We”, “Us” or “Our”) has prescribed the “Shochiku Personal Information Protection Guidelines” as a company that observes the Personal Information Protection Act and other applicable laws and regulations and gives our customers a sense of security and trust regarding the protection of personal information, and is causing our officers and employees to observe the same. We will endeavor to properly handle your personal information that we receive from you and protect your privacy. Please kindly note that the following subject matter may be changed without notice.

Shochiku Co., Ltd.
4-1-1 Tsukiji, Chuo-ku, Tokyo 104-8422
Junichi Sakomoto
President and CEO, Shochiku Co., Ltd.

Scope of Utilization Purpose of Personal Information

1.Your personal information

As a general rule, we will use your personal information only within the scope of the following utilization purposes. If a certain utilization purpose is not indicated below, we will specify the utilization purpose upon receiving your personal information, and will use your personal information only within the scope of the notified utilization purpose.

• While the provision of your personal information to us is arbitrary, please note in advance that we may refuse your use of our service or admission to membership if you do not provide necessary information.

2.Personal information of shareholders

We will use the personal information of shareholders only within the scope of the following utilization purposes.

1. Exercise of rights or performance of obligations under the Companies Act and other laws and regulations
2. Provision of information related to our business operation
3. Matters related to the shareholder special benefit plan
4. Implementation of various policies for facilitating the relationship between us and our shareholders
5. Management of shareholders such as data creation and statistical processing based on prescribed standards pursuant to various laws and regulations

3.Personal information of job applicants

We will use the personal information of job applicants provided in the course of our recruitment activities only within the scope of the following utilization purposes.

1. Determination related to employment
2. Communication for conducting interviews
3. Notification of hiring decision

Provision of Personal Information to a Third Party

We will not provide your personal information that we receive from you to any third party excluding the following cases.

1. When your prior consent has been obtained
2. When outsourcing the handling of your personal information for achieving the utilization purpose
3. When based on laws and regulations
4. When we determine that a response from a relevant third party would be appropriate in order to reply to your comment or inquiry

Joint Utilization of Personal Information

1. We will jointly utilize the personal data that we receive from you in the following manner.
   （１）Items of personal data to be jointly utilized
   Information related to name, gender, date of birth, address, mobile phone/home phone/FAX number, email address, member ID/member number/password, social media account information, image/video/sound data, purchase history and contracts, access information, and other information provided by you
   （２）Scope of persons to jointly utilize personal data Us and
   our group companies
   （３）Utilization purposes of persons to jointly utilize personal data
   Utilization purposes listed above
   （４）Person / entity　responsible for managing the personal data to be jointly utilized
   Shochiku Co., Ltd.
   (Please click here for the representative and address of Shochiku Co., Ltd.)
2. We may jointly use your personal data that we receive from you with a person other than our group companies for the utilization purposes listed above. In such a case, we will notify you in advance to the effect that we will be jointly utilizing your personal data, items of the personal data to be jointly utilized, scope of persons to jointly utilize your personal data, utilization purposes and chief privacy officer, or make such information readily available to you.

Outsourcing of Handling of Personal Information

We may outsource the handling of your personal information that we receive from you in the following cases.

1. When outsourcing the handling of your personal information for achieving the utilization purpose
2. When we determine that a response from a relevant third party would be appropriate in order to reply to your comment or inquiry

Contact Desk of Personal Information

If you have any inquiries regarding changes to the registration details of your personal information that you provided to us or cessation of membership services, or wish to offer comments or make requests, please contact the following Contact Desks.

Request for Notification of Utilization Purpose and Disclosure of Retained Personal Data and Record of Third Party Provision, Correction, etc. or Cessation of Utilization, etc. of Retained Personal Data, and Cessation of Provision of Retained Personal Data to a Third Party

Please click here regarding the procedures for requesting the notification of utilization purpose of the retained personal data, disclosure of retained personal data and record of third party provision, correction, etc. (correction, addition, deletion) or cessation of utilization, etc. (cessation of utilization, erasure) of retained personal data, or cessation of provision of retained personal data to a third party under laws and regulations. If we are unable to comply with your request, we will explain the reason to you. Furthermore, we may delete your personal information for which the utilization purpose has been achieved after the lapse of a given period. In such a case, please kindly note that we will not be able to comply with your request for disclosure, correction, etc., cessation of utilization, etc., or cessation of provision to a third party.

• Procedures for notification of utilization purpose and request for disclosure, correction, etc., cessation of utilization, etc., and cessation of provision to a third party

Security Control Measures

We are taking the following security control actions in order to properly manage your retained personal data.

■Formulation of Personal Information Protection Policy
•We have formulated our Personal Information Protection Policy based on the Personal Information Protection Act for properly managing your personal data.

■Formulation of rules on the handling of personal data
•We have formulated our “Personal Information Protection Rules” which prescribe the handling of your personal information for each stage of acquisition, utilization, maintenance, provision and disposal.

■Systematic security control measure
•We have appointed a chief privacy officer for the handling of personal data, and established a system for reporting to the chief privacy officer of any fact or indication that is in violation of the Personal Information Protection Act or in breach of the Personal Information Protection Rules.

■Human security control measure
•Matters related to the confidentiality of personal data are described in our Work Rules.

■Physical security control measure
•We are taking measures for restricting the use of equipment and electronic mediums and preventing the theft or loss of documents, etc. in the operation of handling personal data.

■Technical security control measure
•We have introduced a scheme for protecting information systems handling personal data from unauthorized access or malware from the outside.

Handling of Anonymously Processed Information

1. We may create anonymously processed information (referring to information obtained by processing personal information so that it is impossible to identify you and impossible to restore the personal information by taking measures prescribed under laws) based on your personal information that we receive from you, and independently use such anonymously processed information or provide such anonymously processed information to a third party.
2. When we create anonymously processed information, we will publicly announce the items of information related to individuals included in the anonymously processed information. Furthermore, when we are to provide the anonymously processed information to a third party, we will publicly announce the items of information related to individuals included in the anonymously processed information to be provided and the method of providing the anonymously processed information.
3. When we create anonymously processed information, we will take security control measures to prevent the leakage of deleted information or information related to the processing method thereof.
4. Please contact the “Shochiku Personal Information Contact Desk” if you have any questions or complaints regarding our handling of anonymously processed information.

Handling of Pseudonymously Processed Information

1. We may create pseudonymously processed information (referring to information obtained by processing personal information so that it is impossible to identify you unless collated with other information by taking measures prescribed under laws) based your personal information that we receive from you, and use such pseudonymously processed information within the scope of the following utilization purposes. If we change any utilization purpose, we will publicly announce the new utilization purpose.
   ・To analyze your age, gender, address, action history, etc. and plan/develop new products and services and improve existing products and services.
   ・To analyze your age, gender, address, action history, etc. and distribute information and advertisements of products and services that match your hobbies and preferences.
   ・To otherwise use pseudonymously processed information for utilization purposes permitted under laws and regulations.
2. We will not provide pseudonymously processed information to any third party unless permitted under laws and regulations.
3. When we create pseudonymously processed information, we will take security control measures to prevent the leakage of deleted information, etc.
4. Please contact the “Shochiku Personal Information Contact Desk” if you have any questions or complaints regarding our handling of pseudonymously processed information.

Collection of Personal Information at Hyperlink Destinations

While this website includes links to several external sites, privacy information will not be shared. Since we cannot be responsible in any way for the collection of personal information performed in the linked websites, please make sure to read the personal information handling details of the respective linked websites.

Cookies

This website provides services by using Cookies.
Cookies are small text files written with arbitrary characters in substitute for personal information which are exchanged between the website’s web server and your internet browsing software (browser) when you visit the website, and stored on your computer’s hard disk drive. Please note that the information collected from Cookies does not contain any information capable of identifying you.
Cookies are used mainly for the following purposes.

・To improve this website and improve the services to be provided to you.
・To enable us or ad distribution companies such as Google and Yahoo! to distribute optimal advertisements to you.
・To improve your website experience.

If you do not wish to use or receive Cookies, you can refuse the reception of Cookies by setting your browser. You can also confirm the Privacy Policy of the respective companies or invalidate the Cookies function (opt-out) from the following pages.
Google’s opt-out page: https://adssettings.google.com/authenticated
Yahoo!’s opt-out page: https://btoptout.yahoo.co.jp/optout/index.html

・This website uses Google Analytics, which is a service provided by Google, for comprehending the status of use of this website. Google Analytics analyzes the status of use of this website by using Cookies issued by us. We receive the results of such analysis from Google (Google Analytic Report related to user attributes and interest categories), and thereby comprehend the status of your access to this website.

・Your information that is collected, recorded or analyzed by Google Analytics does not include any information capable of specifying a specific individual. Furthermore, the foregoing information is managed by Google based on Google’s Privacy Policy.
【Google Analytics’ Terms of Use】
https://marketingplatform.google.com/about/analytics/terms/jp/
【Google’s Privacy Policy】
https://policies.google.com/privacy?hl=ja

・Google Analytics can be disabled by downloading and installing “Google Analytics Opt-out Add-on” at Google’s Opt-out Add-on download page, and changing the Add-on setting of your browser. If you disable Google Analytics, Google Analytics will also be disabled on websites other than this website that you access, but you can enable Google Analytics once again by setting the Add-on function on your browser.
【Google Analytics Opt-out Add-on】
https://tools.google.com/dlpage/gaoptout?hl=ja

Access Log File

This website records information of your computer that accessed this website as an access log file. We can thereby obtain statistical site use information regarding the pages that you accessed, time that you spent on each page, place where you were immediately before accessing this website, trend of page transfer transition, and your browser and operating system, but we never use the access log files for collecting personal information.
Access log files are used mainly for the following purposes.
・To improve this website and improve the services to be provided to you.
・To use the status of use of this website as statistical information in a state where an individual cannot be identified.

Privacy policy
(for customers residing in the EU)

SHOCHIKU Co., Ltd. (the “Company”) will collect and handle, pursuant to this Privacy Policy (this “Policy”), the personal data of customers residing in the EU member states and Ireland, Lichtenstein and Norway who have executed an EEA Treaty (collectively, the “EU”).

• Contact Information
• Types of Personal Data
• Purpose of Use and Legal Basis for Handling of Data
• Recipients of Personal Data
• Sources for Acquisition of Personal Data
• Transfer to Third-Country Businesses
• Retention Period
• Rights of the Customer
• Right to File Objection to Handling of Data
• Right to Withdraw Consent
• Personal Data Required to Be Provided
• Right to File Complaint with Supervising Authorities

1. Contact Information

The contact information of the Company is as follows:

2. Types of Personal Data

The Company will collect and handle the following personal data in relation to its provision of services:

• Information that can identify the person and contact information
  Including, for example, name, address, telephone number and email address
• Information regarding the person’s attributes
  Including, for example, gender and date of birth
• Information regarding payment
  Including, for example, credit card information
• Information regarding the use of services
  Including, for example, ticket purchase history and website access history

3. Purpose of Use and Legal Basis for Handling of Data

The Company will handle the personal data for the following purposes of use:

• For legitimate interests that will be required by the Company when the Company engages in business (including the following purposes of use):
  (a) To statistically process the customer’s personal data, and use or provide the processed data; and
  (b) Carry out questionnaires regarding the Company’s services and related services.
• To comply with obligations under an agreement or to perform the procedures relating to an agreement (including the following purposes of use):
  (a) Administrative matters relating to an invoice to the customer who has purchased a ticket;
  (b) Management and support of matters regarding the sales of tickets; and
  (c) Delivery of prizes if there are products that have been won.
• To handle personal information in the event the customer gives consent (including the following purposes of use):
  (a) Notices regarding film, theater and various campaigns (where your consent is required in accordance with applicable law); and
  (b) Provision of email magazine distribution services (where your consent is required in accordance with applicable law).
• For purposes set forth in the laws and regulations (including the following purposes of use):
  (a) For use in the event there is a need to maintain or acquire personal information to fulfill a legal obligation borne by the Company; and
  (b) When responding to requests of the government or investigative agencies.

4. Recipients of Personal Data

The Company will provide and handle the customer’s personal data to the following businesses:

• The Company’s parent company and subsidiaries and companies belonging to affiliates (the “Shochiku Group Companies”) The Company will jointly use between each of the Shochiku Group Companies the personal data described above for the aforementioned purposes of use with the Company as the manager of the joint use. Please refer to the List of Group Companies for the Shochiku Group Companies.
• Service providers that will be the Company’s subcontractors The Company will subcontract the handling of personal data after executing memorandums of understanding concerning the entrustment of the handling of personal data with service providers. Service providers include, for example, IT infrastructure service providers, customer management service providers, web hosting vendors, and security service providers.

5. Sources for Acquisition of Personal Data

The Company may collect other personal data directly from the customer, but in certain instances, the Company may collect personal data by receiving personal data from the Shochiku Group Companies or ticket sales subcontracted vendors.

6. Transfer to Third Country Businesses

The Company may transfer the customer’s personal data to countries outside the EU region to provide its services. Such countries may include those that the Committee has not decided as providing a sufficient level of protection with respect to the protection of personal data.
Please be advised that the Company will transfer personal data to such third countries only if proper protective measures such as of the standard data protection provisions set forth in Article 46(2) of the EU General Data Protection Regulation (the “GDPR”) are taken.
To obtain a copy of a document used for the protection of the customer’s information or to obtain detailed information, please send a letter to the Company (Togeki Bldg., 4-1-1 Tsukiji, Chuo-ku, Tokyo) or contact (click here).

7. Retention Period

The Company will retain the customer’s personal data for the period of time required to achieve the purpose of use set forth in this Policy.
The decision on the retention period of personal data is based on (i) whether or not the customer is continuing to use the Company’s services, (ii) whether or not there are legal obligations that the Company must comply with, and (iii) whether or not there is a need to perform an agreement that the customer is a party to.

8. Rights of the Customer

The customer has (i) the right to request a copy of the personal data, (ii) the right to request revisions, (iii) the right to request deletions, (iv) the right to limit the handling (or stop the processing) of personal data, and (v) the right to have the personal data provided to Shochiku for an agreement or under consent be structured and receive it in a form that is machine-readable (right of data portability), against the Company.
In addition thereto, the customer has (vi) the right to object to the handling of personal data, under certain conditions. Please refer to “9. Right to File Objection to Handling of Data” below for details.
These rights may be restricted, for example, if a third party’s personal data is disclosed by complying with the customer’s request, if the rights of someone other than the customer (including the Company’s rights) will be infringed, or if retention is required or deletion of information of which its retention has exigent legitimate interests is required by the laws and regulations. These exceptions to the rights are set forth in both the GDPR and the domestic laws of each EU state regarding privacy.
To exercise any of these rights, please send a letter to the Company (Togeki Bldg., 4-1-1 Tsukiji, Chuo-ku, Tokyo) or contact (click here).

9. Right to File Objection to Handling of Data

The customer always has the right to file an objection against the handling of personal data that is handled on the basis of legitimate interests. The handling of personal data used here includes profiling (which means to analyze and predict the customer’s actions from the customer’s information; the same applies hereafter).
If the customer’s personal data is handled for the purpose of direct marketing, the customer has the absolute right to refuse direct marketing and to refuse the profiling conducted for such purpose.
To exercise any of these rights, please send a letter to the Company (Togeki Bldg., 4-1-1 Tsukiji, Chuo-ku, Tokyo) or contact (click here).

10. Right to Withdraw Consent

If the Company is handling personal information under the customer’s consent, the customer always has the right to withdraw such consent. This withdrawal will not have effect on the legality of any handling that was conducted under the consent granted before then.
To exercise this right, please send a letter to the Company (Togeki Bldg., 4-1-1 Tsukiji, Chuo-ku, Tokyo) or contact (click here).

11. Personal Data Required to Be Provided

The personal data that is required to be provided will be indicated on the form that the customer fills out. If the provision of personal data is required, the Company will not be able to provide its services to the customer unless proper information is provided.

12. Right to File Complaint with Supervising Authorities

The customer has the right to file a complaint against the supervising authorities. The supervising authorities where the complaint can be filed include the supervising authorities of the EU member states where the customer’s place of residence or workplace is located or where the place the petition of the GDPR violation is initiated is located.