■ Personal Information Protection Policy

Recruit Holdings Co., Ltd. ("RECRUIT") provides, through a variety of media, including information magazines, the Internet, mobile devices, events, and service counters, various chances for companies and individuals, in different aspects of their lives, as expressed in its brand message "Meet your opportunity."
In operating its business, RECRUIT handles the personal information of a large number of customers and employees. Therefore, RECRUIT has established this Policy and a personal information management system based on its Code of Ethics, through which RECRUIT, as a company, is committed to realizing the responsible handling of personal information.

RRECRUIT
Masumi Minegishi, President and Representative Director

(Supplementary Provisions)
Established and implemented on April 17, 2002
Revised on April 2, 2003
Revised on April 1, 2004
Revised on December 15, 2005
Revised on June 6, 2007
Revised on March 5, 2008
Effective Date: March 3, 2015

* RECRUIT is accredited by JIPDEC (http://www.jipdec.or.jp/) as a “privacy-mark” licensed operator in Japan.

■ Regarding the handling of personal information

RECRUIT shall post this privacy policy, shall respect the privacy of companies, affiliated companies, associations, etc., that use the services provided in accordance with this privacy policy ("Services") (“Service Using Companies, etc.”) and each person ("User") who uses the Services and shall handle the personal information (as defined below) of all Users with the utmost care in the management thereof.

■ Personal information

For purposes of the Privacy Policy, which is broader than what is required by law, personal information means information concerning a User as an individual, which can identify the User based on the name, address, telephone number, e-mail address, educational institution, or other descriptions, etc. constituting such information. In addition, any information which cannot identify the User solely by itself but can easily be cross-referenced with other information that is public and readily available and, as a result thereof, can identify the User, is also included in the scope of personal information.

■ Purposes of use of personal information

RECRUIT may use personal information only for the following purposes, and will not use any personal information beyond these purposes of use:

Please note that as RECRUIT is located in Japan, any personal information provided to RECRUIT will be sent to RECRUIT’s servers in Japan.

■ Addressee information received from Users

Under the Services, RECRUIT may receive, from a User, addressee information other than the information of such User, in order to send messages, products, etc., on behalf of the User.

Under the Services, addressee information will be used solely for sending messages, products, etc., based on the relevant User’s request, or as otherwise provided in this Policy, and will be properly managed as personal information.

Addressee information shall be registered, changed or deleted at the discretion of the relevant User, and, as a general rule, will not be changed or deleted at the Services’ side. Anyone who wishes to change or delete addressee information is requested to contact the User who has sent the message, products, etc., to the addressee.

If an addressee does not know the sender, please refer to the contact specified in Section 17 in charge of personal information management.

Users warrants and undertakes that where it has disclosed personal information of individuals to the RECRUIT and/or its service providers and agents in connection with the Services, it had obtained the prior consent of such third parties for RECRUIT and its service providers and agents to collect, use and disclose their personal data in the manner described in this privacy policy. Users agrees to indemnify, defend and hold harmless RECRUIT in respect of any penalties, liabilities, claims, demands, losses and damages as a result of its breach of this warranty.

■ Voluntary nature of provision of personal information

Users who fail to enter information in each of the items required for the performance of the respective services constituting the Services may not be able to receive such respective services.

■ Provision of personal information to third parties

RECRUIT, as a general rule, does not provide any third party with any User’s personal information without the consent of such User, except as provided in this Privacy Policy. RECRUIT provides third parties with personal information if it has obtained the User's consent thereto, specifying the party to whom the information is to be disclosed and the content of information to be disclosed. However, User consents to such provision of personal information, in the following situations, and thus, RECRUIT may provide personal information without additional User's consent within the scope not conflicting with related laws and regulations, where any of the following applies:

■ Disclaimer concerning the provision of personal information to third parties

RECRUIT will not be responsible for the acquisition of personal information by a third party where any of the following applies:

■ Outsourcing of personal information processing

RECRUIT may outsource personal information handling work in part or in whole. RECRUIT shall be responsible for the handling of personal information by the party to which such work is outsourced.

■ Use of statistically-processed data

RECRUIT may, based on personal information provided to it, create statistical data which shall be processed in a manner that cannot identify any individual. RECRUIT may, without restriction, use such statistical data that cannot identify individuals.

■ Modifications, etc. to personal information

As a general rule, only the User himself/herself can request notification regarding the “purposes of use of the personal information,” or any disclosure or correction of, addition to, deletion or suspension of his/her registered personal information, or the provision thereof to third parties (“Modification, etc., of Personal Information”). Users can request review of personal information about them and changes to the contact specified in Section 17. However, RECRUIT may not agree to comply with a request for the Modification, etc., of Personal Information where any of the following applies:

Furthermore, RECRUIT may not agree to comply with a request for the Modification, etc., of Personal Information if such Modification, etc., of Personal Information requires excessive cost, or if the performance of such Modification, etc., of Personal Information is otherwise difficult, and instead RECRUIT ensures that necessary alternative measures shall be taken for the protection of the rights and interests of the User.

■ Accuracy of personal information

RECRUIT shall make efforts to accurately data process the personal information provided to it. However, Users shall be responsible for ensuring that the personal information they provide is accurate and up-to-date.

■ Restrictions on acquisition of sensitive personal information

RECRUIT, as a general rule, shall not obtain any User’s personal information which contains any of the following information, unless the personal information has been provided by the User himself/herself:

■ Identification

In the event of the use of the Services by the User, or RECRUIT’s response to a User’s request for the disclosure, correction, deletion, or suspension of use of such User’s personal information, etc., RECRUIT shall verify the relevant individual’s identity based on information that can identify such individual (i.e., name, address, telephone number, date of birth, e-mail address, member ID number, password, etc.). However, RECRUIT shall not be responsible in the event of any third party obtaining and using information that can identify the relevant individual.

■ Acquisition or use of attribute information, terminal information, location information and action history records, etc.

? Cookies, etc., among the attribute information, terminal information, location information and action history records, etc. (“Action History Records, etc.”):
RECRUIT uses Cookies for User privacy protection, increased convenience, distribution of advertisements, and acquisition of statistical data. In addition, RECRUIT may obtain, using Cookies, JavaScript and other technology, attribute information such as age, gender, occupation and residential area, etc., which cannot identify the individual (limited to those attributes which cannot identify the individual by a combination thereof), as well as Users’ action history records within the website of the Services (such as URLs and content accessed and the order in which such URLs and content were viewed) as well as location information based on Users’ consent/application at the time of use of smart phones, etc., among the information provided by the User. However, no personal information shall be included in the Cookies or Action History Records, etc. In addition, the Services use action targeting advertisement services in order to distribute appropriate advertisements to Users.
? Access logs, etc., among Action History Records, etc., in the following case:
When a User uses the Services by logging into the same, RECRUIT may, upon identifying the identity of such User, distribute/display advertisements, contents, etc., and provide the Services by way of using the Action History Records, etc., prior to such log-in by the User. To unsubscribe from such advertisements, etc., please contact the person responsible for management of the personal information, specified below.

■ Person responsible for the management of personal information

RECRUIT
Lifestyle Company,
Corporate Executive Officer

For any inquiries concerning personal information, please contact here:

■ Modifications to Privacy Policy

Unless otherwise prescribed in laws and regulations, etc., RECRUIT shall be entitled to modify this Privacy Policy from time to time. You are encouraged to review the posted Privacy Policy each time you provide personal information. When RECRUIT changes the policy in a material way, RECRUIT will provide the changed policy by posting notices on its website.

■ Do Not Track and Third Party Collection

RECRUIT is not always able to honor “do not track” browser settings, and therefore cannot represent whether these settings are honored at all times, RECRUIT does not authorize third parties to collect personally identifiable information from its websites.

■ Children under Age 13

RECRUIT does not knowingly collect or solicit personal information from anyone under the age of 13 years or knowingly allow such persons to use its online services. If you are under age 13, you should not attempt to provide RECRUIT with your personal information. If you believe that RECRUIT may have any information about a child under age 13 years, please contact here.