■ 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.

Article 1 Scope of Application

This Privacy Policy applies to personal information of overseas residents outside Japan.

Article 2 Collection of Personal Information

In order to achieve the purposes as provided in Article 3 herein, we collect your personal information as follows:

  1. Information collected directly from you
    When you enter data on a device, or when you provide us with information directly, or through written or other media, the information collected by us includes:
    • Registration information such as name, gender, date of birth, address, telephone number and e-mail address that are required when you apply for membership registration or request for changes of the registered information;
    • Information provided by you in response to our questionnaires, and information voluntarily sent or provided by you to us for the Service; and
    • Your opinions, requests, and inquiries.
  2. Information collected when the Service is used
    When you use or browse the Service, goods, advertisements or contents on a device, information collected by us includes:
    • Information collected when you access and use websites/apps that provide online services for the Member and other websites/apps, such as cookies, IP addresses, device information/individual identification IDs from mobile device access, type of browsers you use, operating systems, platforms, histories of your use of the Service (e.g. browsing/purchases) and location information.
  3. Information necessary for provision of the Service and management of the Member
    The information collected by us when you use the Service and the information obtained by us as necessary for our management of the Member information include:
    • The IDs, passwords, credit card numbers (including those that have been replaced), images, sounds and other descriptions, or individually assigned numbers, symbols and other codes that can identify a particular individual person; and
    • Registered information for the Service, linkage with other services, status of the Member (e.g. cancellation, suspension or expulsion).
  4. Information obtained by analyzing and estimating data items (1) through (3) above.
  5. Any other information obtained by us in the course of our compliance with the applicable laws and regulations pertaining to personal information protection as well as the related guidelines (collectively, hereinafter referred to as the "Laws and Regulations”). This includes such cases as when the information is lawfully provided by a third party.

Article 3 Purpose of Use of Personal Information

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

Article 4 Personal Information of Minors under 16

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.

Article 5 Retention of 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.

Article 6 Shared Use of Personal Information

  1. As the responsible controller as your personal information, we may share and disclose all or part of the personal information set out in Article 2 with and to the following parties within the scope of the purposes of use as provided in Article 3.
    1. (1) Hankyu Hanshin Holdings Group consisting of our subsidiaries and affiliates
      (Reference) List of Group Companies
      https://www.hankyu-hanshin.co.jp/docs/groupguide_en.pdf#page=8
      (Note) The information may not be updated.
    2. (2) Business contractors/ subcontractors and professional institutions such as law firms
    3. (3) Business partners, company-operated stores and member (or franchised) shops
    4. (4) Business transferees
    5. (5) Public agencies with authority (e.g. police, courts)
  2. Please note that our website contains links to third party websites, but this Privacy Policy does not apply to those third party websites. For a more detailed information and confirmation with regard to how your personal information is handled by such third parties, please refer to their privacy policies and cookie policies.

Article 7 Transfer to Third Countries

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.

Article 8 Your Rights

  1. You and your legal representative may contact us (See “Contact Information” in Article 9) for the purpose of exercising any of the following rights pursuant to the Laws and Regulations.
    1. (1) Right to obtain information on data processing
      You are entitled to obtain from us any and all necessary information concerning our data processing activities that relates to you.
    2. (2) Right to seek access to certain information
      You are entitled to confirm with us whether any personal information relating to you has been processed by us, and if it has been so processed, you are entitled to access such personal information as well as other certain information related thereto.
    3. (3) Right to request correction or deletion
      You are entitled to have us, without undue delay, correct any inaccurate part, complete any incomplete part or (on the condition that you meet the certain requirements) delete any part of personal information relating to you.
    4. (4) Right to demand restriction on data processing
      You are entitled to have us restrict processing of any personal information on the condition that you meet the certain requirements.
    5. (5) Right to data portability
      You are entitled to receive personal information relating to you in a structured, commonly used, machine-readable format and transfer such information to any controller other than us without our interruption, on the condition that you meet the certain requirements.
    6. (6) Right to object to data processing
      You are entitled to object to processing of any personal information relating to you on the condition that you meet the certain requirements.
    7. (7) Right not to be subject to automated decision-making
      You are entitled not to be subject to any decision-making based on automated data processing that has a legal effect or other equally significant effect on you on the condition that you meet the certain requirements.
  2. In a case where any personal information is processed based upon your consent, you are entitled to withdraw such consent at any time. Please note that such withdrawal will take effect for any future processing only, and will not take effect for any past handling as well as its legality.
  3. Please fill out the form on our website if you wish to exercise any of your rights. When you send us your request, please provide us with detailed information to prove your identity (a copy of your public identification, such as an identification card or a passport that shows your family/first names and other identity information), as well as other information required by us to confirm your identity, so as for us to respond to your request in the best possible manner.
  4. We respond to your request as quickly as possible while complying with the Laws and Regulations. We are, however, unable to respond to any request irrelevant to the protection of personal information. Should you have any question, comment or complaint regarding this Privacy Policy, please feel free to contact us at the contact information stated in the following article. You are also entitled to file your objection with any supervisory authority with respect to this Privacy Policy.

Article 9 Contact Information

For persons who live in the EEA (European Economic Area) or the UK:
<Inquiries from the EEA residents and the UK residents>

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.

<Contact detail of the data controller (Inquiries from residents outside the EEA and the UK)>

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

Article 10 Update to Privacy Policy

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:

  • Posting on this website;
  • Notice to the users; and/or
  • Any other appropriate means