Through our Precious Metals Business and Environmental Preservation Business, the ARE Holdings Group is committed to preserving limited natural resources, preserving the global environment, and contributing to the realization of a sustainable world. Regarding the personal information collected during the course of business activities, we understand how important these assets are in today's society of advanced information and communication, recognize that it is our important responsibility to properly handle personal information, and hereby declare that we will strive to protect personal information in accordance with the following policies.
1. Compliance with Laws and Regulations Regarding the Protection of Personal Information
We will comply with laws and other standards regarding the protection of personal information, and will handle personal information properly.
2. Acquisition of Personal Information
When we acquire personal information, we will notify, disclose, or specify the purpose of use, and we will acquire personal information through legal and fair means.
3. Purpose of Use of Personal Information
We will use the personal information we have acquired only to the extent necessary for the performance of our business, within the scope of the following purposes of use. In addition, if we entrust the handling of personal information to a third party, we will supervise the third party to ensure the proper use of personal information.
- (1)Responding to customer inquiries and requests
- (2)Conducting work related to recruitment and screening
- (3)Providing services to shareholders
- (4)Carrying out other activities related or incidental to the above smoothly
4. Provision of Personal Information to Third Parties
We will not provide personal information to third parties unless one of the following is true.
- (1)When the individual agrees in advance
- (2)When entrusted to an external party to the extent necessary to achieve the purpose of use
- (3)When it is demanded based on laws and regulations
- (4)When it is necessary for the protection of a person's life, body, or property and it is difficult to obtain the individual's consent
- (5)When it is necessary to cooperate with a national or local public organization in implementing the work prescribed by laws and regulations, and obtaining the consent of the individual may interfere with the performance of such work
- (6)When statistical data is provided or disclosed (information that cannot identify the individual)
- (7)When it is provided to an entity listed in the scope of joint users as set forth in the following Article
5. Joint Use of Personal Information
We will use personal information jointly as follows.
- (1)Items of personal information to be used jointly
- Address, name, zip code, phone number, fax number, email address, workplace, etc.
- (2)Scope of joint use
- Each company within the ARE Holdings Group (Group Companies)
- (3)Purpose of use
- Within the scope of the purpose of use provided in Article 3
- (4)Name, address, and representative of the company responsible for managing personal information
6. Safety Management Measures for Personal Information
We maintain the accuracy and currency of personal information, manage it securely, and take necessary and appropriate safety management measures to prevent and correct unauthorized access, loss, destruction, tampering, and leakage of personal information. In addition, we will provide the necessary and appropriate supervision of employees and entrustees who handle personal information (including those who are referred to as re-entrustees). Safety management measures are specified separately in the "Personal Information Handling Regulations," but the main contents are as follows.
- •We have formulated the "Personal Information Handling Regulations" for handling procedures, persons in charge and personnel, their duties, etc. at each stage, including acquisition, use, storage, provision, deletion, and disposal.
- •In addition to establishing a person responsible for handling personal data, we have also clarified the scope of personal data handled by employees and those who handle it, and have established a system to report violations or signs of violations of the Personal Information Protection Act and the Personal Information Handling Regulations to the person responsible for handling personal data.
- •We regularly train employees on matters to be aware of regarding the handling of personal data.
- •Matters concerning the confidentiality of personal data are described in the Employment Regulations.
- •Measures are in place to prevent unauthorized persons from viewing personal data in areas where personal data is handled.
- •Measures have been taken to prevent theft or loss of equipment, electronic media, and documents, etc. that contain personal data.
- •Access control is implemented to limit the scope of personnel in charge and personal information databases, etc. handled.
- •A system has been introduced to protect information systems that handle personal data from unauthorized access or software from outside sources.
(Formulation of Personal Information Protection Guidelines)
(Establishment of rules concerning the handling of personal data)
(Systematic Safety Management Measures)
(Individual Safety Management Measures)
(Physical Safety Management Measures)
(Technical Safety Management Measures)
7. Transfer Outside of Japan
We conduct business activities globally and may transfer personal information abroad. However, the countries and regions to which it is transferred may not have the same personal information protection system as in Japan. When we provide personal information to third parties outside of Japan, including entrustees and joint users, we will provide it based on the consent of the individual, unless one of the following is true.
- (1)The third party is located in a country that is designated by law as a country with a personal information protection system on the same level as that of Japan
- (2)When a third party has established the necessary systems for the continued implementation of measures equivalent to those which should be taken by Japanese companies handling personal information
In the case of (2) above, we will take the necessary measures to ensure the continued implementation of such measures by the third party. If you wish to confirm such necessary measures, please contact "9. Personal Information Consultation Desk."
8. Disclosure, Correction, Suspension of Use, and Deletion of Personal Information
In the event of a request from the individual or their agent to disclose personal information or records of provision to third parties, or to correct, delete, or suspend the use of personal information, we will promptly respond to the request in accordance with laws and regulations after confirming their identity, unless one of the following is true.
- (1)When there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party
- (2)When it could significantly interfere with the proper performance of our company group's work
- (3)When it would violate laws or regulations
9. Personal Information Consultation Desk
For requests, complaints, inquiries, and confirmation regarding the disclosure, etc. of personal information, please contact the "Personal Information Consultation Desk" below.
Sapia Tower 11F, 1-7-12 Marunouchi, Chiyoda-ku, Tokyo
ARE Holdings, Inc., Tokyo Head Office
Personal Information Consultation Desk
April 1, 2022
Sapia Tower 11F, 1-7-12 Marunouchi, Chiyoda-ku, Tokyo
ARE Holdings, Inc.
Tomoya Higashiura, Representative Director, President & CEO