Element Rule Co., Ltd. (hereinafter referred to as "our company") fully recognizes that managing personal information is a serious responsibility, and pledges to comply with the Act on the Protection of Personal Information, as well as to establish, implement, and maintain the following privacy policy. We will also ensure reliable management of personal information, providing ongoing peace of mind to customers and other providers of personal information (hereinafter referred to as "providers").

Article 1: Our Approach to Personal Information Protection

We have established a management system to protect personal information appropriate to the actual business situation, such as information about customers, business partners, shareholders, job seekers, and our employees, and we handle personal information appropriately and carefully in accordance with the following internal rules and standards.

Article 2: Collection of Personal Information

When collecting personal information, etc., we will clarify the purpose of use of the personal information, etc. to the provider in advance by notifying or publicly announcing it via the CONTACT form on this website (hereinafter referred to as the "inquiry form"), posting it in this privacy policy, or by other means that we deem appropriate, and will acquire the information using lawful and fair means to the extent necessary to achieve that purpose.

Article 3: Use of Personal Information

1. Customer personal information
When using personal information, we will use it only for the purposes set out below, or for the purposes for which consent has been given by the provider via the inquiry form or other methods that we deem appropriate. Please note that we may outsource the handling of personal information to our subsidiaries, affiliated companies, or other third parties to the extent necessary to achieve these purposes.

① User management, customer support (verifying customer identity and personal authentication, shipping products, invoices, or prizes to winners of campaigns in which customers have participated, responding to, confirming, and recording customer inquiries, consultations, complaints, repairs, and support), campaign planning (provision of advertisements and information on products, services, campaigns, etc. via invitations and emails, distribution of behavioral targeting advertisements using advertising distributors such as Google and Yahoo! *1 *2)

② To conduct surveys, provide our services such as e-commerce sites, etc.

③ Marketing activities after processing the information so that individuals cannot be identified (analysis of attribute information and behavioral history obtained by our company to develop products and improve other services, improve customer experience in digital services provided by our company (websites, mobile apps, etc.), and understand customers' hobbies and preferences, etc. *1 *2)

④ Other purposes notified individually at the time of acquisition

In addition, when sharing personal information with our subsidiaries or affiliates or other third parties, we will clarify the items of personal information to be shared and the purpose of such sharing in advance to the provider via the inquiry form or other method that we deem appropriate.
*1 We analyze information such as website browsing history and purchase history obtained from customers to provide services and deliver advertisements.
*2 We may refer to your cookies and other personal information obtained from third parties and compare it with your personal information held by our company, and use it by linking your hobbies, preferences, browsing history, etc. with your personal information already held by our company. In such cases, we will obtain your consent in advance and use the information within the scope of the purposes of use listed above.
*Cookies are a technology that records and manages information about customers who use our website on their computers or application software. Our website uses cookies to make it more convenient for customers to use, as well as for the purposes listed in ① through ④ above.

2. Personal information about business partners (or, in the case of corporate clients, their officers and employees)
For business-related communications, contract execution, business negotiations, etc.
For managing supplier information

3. Personal information about shareholders (or, if the shareholder is a corporation, its officers and employees)
Exercising rights and fulfilling obligations under the Companies Act
Managing shareholders, including creating records in accordance with various laws and regulations

4. Personal information about job seekers
Please refer to the link at the bottom of this page.

5. Personal information of employees of our company and our group companies
Please refer to the link at the bottom of this page.

Article 4: Provision of Personal Information

When entrusting the handling of personal information to our subsidiaries, affiliates, or other third parties, we will do so only to the extent necessary to achieve the above-mentioned purposes of use. Furthermore, when providing personal information to a third party, we will do so only to the extent that the provider has given consent. If provision is planned, we will obtain prior consent from the provider.

Article 5 Joint use

We will share personal information. Please refer to the link at the bottom of this page regarding the shared use of personal information of job seekers and our employees.

1. Items of personal information to be jointly used
Name, gender, date of birth, address, telephone number, email address, product purchase history, and other information obtained by our company

2. Scope of joint users
Our group companies
Developers and commercial facilities in which our company operates stores, such as department stores
Companies that have stores on the e-commerce site operated by our company

3. Purpose of joint use
The scope of the purpose of use will be as set forth in the preceding paragraph.

4. Person in charge of managing personal information
Our company will be responsible for managing personal information.

Article 6: Disclosure, Correction, Deletion, etc. of Personal Information

If a provider requests the disclosure, correction, deletion, suspension of use, or erasure of their personal information, we will comply with such requests within a reasonable period and scope. For inquiries, please contact the email address at the end of this page.

Article 7: Implementation of Safety Measures

We will take necessary and appropriate security control measures to manage personal data, including preventing leaks, loss, or damage. We will also provide necessary and appropriate supervision to employees and contractors (including subcontractors) who handle personal data. We will strive to properly implement security control measures for personal data in accordance with our separate internal regulations, the main details of which are as follows:

(Establishment of personal information protection guidelines)
・In order to ensure the proper handling of personal data, we have formulated this Privacy Policy regarding "compliance with relevant laws, regulations, guidelines, etc.", "contact point for handling questions and complaints," etc.

(Establishment of rules regarding the handling of personal data)
・We have established internal regulations for each stage of personal information acquisition, use, storage, provision, deletion, disposal, etc., regarding handling methods, responsible persons, staff members, and their duties.

(Organized safety management measures)
・We have appointed an administrative manager for handling personal data, clarified the employees who handle personal data and the scope of personal data handled by those employees, and established a system for reporting to the administrative manager in the event of the discovery of any facts or signs of violations of the Act on the Protection of Personal Information or internal rules.
・Regarding the handling of personal data, we regularly conduct self-inspections and also have audits conducted by other departments and external parties.

(Personal safety management measures)
・We provide regular training to employees on important points to note regarding the handling of personal data.
・Matters regarding confidentiality of personal data are stated in the work regulations.

(Physical safety management measures)
・In areas where personal data is handled, we manage employee entry and exit and restrict the devices that can be brought in, and we also take measures to prevent unauthorized persons from viewing personal data.
・We take measures to prevent theft or loss of devices, electronic media, documents, etc. that handle personal data, and we also take measures to prevent personal data from being easily identified when carrying such devices, electronic media, etc., including when moving within the office.

(Technical safety management measures)
・Access control is implemented to limit the scope of personnel and personal information databases handled.
・We have implemented a system to protect information systems that handle personal data from unauthorized external access or malicious software.

Article 8: Compliance with Laws and Regulations and Improvement

In handling personal information, we will comply with laws, regulations, notices and other rules that apply to the protection of personal information, and will make continuous improvements to ensure that personal information is handled appropriately.

Effective March 2018
Revised and effective in July 2022

Element Rule Co., Ltd.
Representative Director Masayuki Kindo

For inquiries regarding personal information,CONTACT (Inquiry form)Please give me.