■ Hankyu Hanshin Group Common ID Privacy Policy
Enacted: March 27, 2024
Hankyu Hanshin Holdings, Inc. provides various services of the Hankyu Hanshin Group (hereinafter referred to as the “Service”) to its HH cross Members, using the Hankyu Hanshin Group's common account, “HH cross ID” (hereinafter referred to as the “ID”).
In this Privacy Policy (hereinafter referred to as the “Privacy Policy”), “Applicant” means our customers who have applied for the ID registration and “Member” means our customers who have registered for the ID (Applicant and Member are collectively referred to as the “Customer”). Concerned persons including our business clients and Customer are herein together and generally referred to as “you”. This Privacy Policy sets out the basic policy with regard to our handling of your personal information collected when you apply for the ID registration, when you change your registered information, and when you use the Service. We comply with the provisions of this Privacy Policy to which the Member has agreed and properly collect, manage and protect personal information in accordance with the applicable conventions, laws and regulations.
We do utmost effort to manage your personal information in an appropriate manner and without any data breaches. We develop a compliance program, which is constantly reviewed and improved, to handle and protect the personal information, creating an internal framework for that purpose. We also take a reasonable level of security measures against unauthorized access from outside.
This Privacy Policy explains the purposes for which we use your personal information and how we handle it.
This Privacy Policy applies to personal information of overseas residents outside Japan.
In order to achieve the purposes as provided in Article 3 herein, we collect your personal information as follows:
We may handle your personal information collected by us for the following purposes. When we consider handling your personal information beyond the scope necessary for achieving these purposes, we will obtain your prior consent.
In addition to obtaining your consent, to achieve the following purposes of use, we handle your personal information based on one or more of the following legal grounds in the table below: i) when necessary for the execution and performance of a contract; ii) when necessary for compliance with a legal obligation; iii) when necessary to protect essential interests of you and/or other persons; and/or iv) when necessary for the legitimate interests; provided that this item v) does not apply to the cases of residents of China, and in such case, the legal ground would be "your consent".
Purpose | Personal Information to be collected | Legal Ground |
---|---|---|
For registration procedures, including approval of your membership registration, and changes to your registered personal information | Name, gender, date of birth, address, postal code (optional), telephone number and e-mail address | Performance of the contract |
To respond to inquiries from you | Name, gender, date of birth, address, postal code (optional), telephone number and e-mail address | Performance of the contract |
To securely provide you with the ID | Name, phone number and e-mail address | Performance of the contract |
To provide and improve goods and services | Name, gender, date of birth, address, postal code (optional), telephone number and email address | Performance of the contract |
To develop new services and goods/products, conduct market trend analyses relating to the goods and services and customer satisfaction surveys, and to grasp and analyze the usage of the Service | Name, gender, date of birth, address, postal code (optional), telephone number and email address | Legitimate interests (or Your consent in the case of residents in China) |
To provide the information (e.g. advertisements) that reflects your interests, preferences, concerns and lifestyles | Name, gender, date of birth, address, postal code (optional), telephone number, e-mail address, name of company, group or school (optional), name of company department (optional), position/title(optional) and address of workplace (optional) | Legitimate interests (or Your consent in the case of residents in China) |
To deliver products and notices, send a bill for payments, distribute coupons and to give points | Name, gender, date of birth, address, postal code (optional), telephone number and email address | Performance of the contract |
We do not intend or desire to collect personal information directly from minors under the age of 16. If it is found that a minor under 16 has provided his or her personal information without the consent of a person with parental authority, please contact and notify us (See “Contact Information” in Article 9). We will promptly take appropriate measures including deletion of such personal information.
We will delete your personal information without undue delay when it becomes no longer necessary in light of the purpose of use thereof; provided, however, that even after the completion of the Service to you or the termination of the Service due to your withdrawal from the membership or any other reason, we may retain your personal information for as long as necessary, taking into account the nature of personal information and the legal or business need to retain it, such as the cases where we are required to retain your personal information in order to comply with the Laws and Regulations or where we need to respond to the unresolved claims or complaints.
In the course of sharing and disclosing certain personal information pursuant to Article 6, your personal information may be transferred to any country or region other than the country or region where you are located. Such other county or region may have different data protection standards from those applicable in the country or region where you are located. In such a case, we take appropriate measures as required by the Laws and Regulations to ensure that your personal information is safely and reliably handled, by means such as concluding appropriate agreement concerning data processing with the recipient of your personal information. We provide you with information about the justification of the transfer of your personal information to such other country or region upon your request; please contact us at the contact information stated in Article 9.
Since we are based outside the EU/ UK, pursuant to Article 27 of the GDPR/ UK GDPR, we are required to appoint our representative based in the EU/ UK, in order to process inquiries from certain data subjects. We have therefore appointed DataRep as our representative. Should you have any inquiry that needs advice from our representative, please direct your inquiry to DataRep by:
Filling out the online form at https://www.datarep.com/data-request; or
Mailing your inquiry to any of the following addresses:
DataRep, The Cube, Monahan Road, Cork, T12 H1XY, the Irish Republic; or
DataRep, 107-111 Fleet Street, London, EC4A 2AB, the UK
Note: Please direct any inquiry to our representative, DataRep (not to us, Hankyu Hanshin Holdings), while clearly stating that such inquiry is intended for Hankyu Hanshin Holdings.
Please direct any inquiry, request or comment regarding disclosure of personal information, etc. to:
Hankyu Hanshin Holdings, Inc., Group Business Development Division
URL: https://help.hhcross.hankyu-hanshin.jp/hc/us-en/requests/new
We may amend this Privacy Policy as appropriate in response to any amendment to the Laws and Regulations, or for any business need, etc.
Upon such amendment, we will inform you of the timing to enforce the amended Privacy Policy and the content thereof in the following manner: