Privacy Policy

ANA Systems Co., Ltd. (hereinafter referred to as “the Company”) promotes the protection of personal information by formulating this Privacy Policy regarding the handling of personal information obtained from customers, establishing a system for the protection of personal information, ensuring that all employees recognize the importance of the protection of personal information, and thoroughly implementing these measures.

Article 1 (Application)

This privacy policy (hereinafter referred to as the “Policy”) applies when personal information is provided to the Company. If there are separate terms, rules, precautions, etc. (hereinafter collectively referred to as “Special Terms”) regarding the protection of personal information established aside from this Policy, in the event that there is any discrepancy between the provisions set forth in this Policy and those set forth in the Special Terms, the provisions set forth in the Special Terms are to take precedence unless otherwise specified.

This Policy does not apply to personal information provided by other ANA Group companies in connection with services provided under contract, such as airline ticket information for air transportation services.

Article 2 (Personal Information)

Personal Information refers to “personal information” as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as the “Personal Information Protection Act”), which is information relating to a living individual containing a name, date of birth, or other identifier or the equivalent which can be used to identify a specific individual or that contains an individual identification code.

Article 3 (The Purpose of Use of Personal Information)

The Company collects and uses customers’ Personal Information to the extent necessary for the following purposes; provided, however, that if the Company intends to use Personal Information beyond the scope of the following purposes, the Company is to obtain prior consent from customers in an appropriate manner, and the Company will not use customer Personal Information in a manner that may encourage or induce illegal or improper activities, even when doing so is within the scope of the specified purposes:

1. recruitment services requested by the customer;
2. customer satisfaction surveys on the Company services;
3. security management for customers visiting the Company;
4. provision of information and making proposals regarding the Company business and services;
5. all operations incidental or related to 1. through 4. above; and
6. responding to inquiries, requests, etc.

*Additionally, uses stated in “Article 7 Joint Use of Personal Information.”

Article 4 (Personal Information to be Obtained)

In order to achieve the purposes of use set forth in the preceding article, the Company will acquire the following Personal Information of customers by appropriate and fair means.

1. Individual details, contact information, etc.
   Customer’s name, address, telephone number, fax number, e-mail address, etc.
2. Details of customer inquiries or comments to the Company
   Information contained in interactions between the Company and the customer, the contents of inquiries, requests, and feedback (including the causes and solutions to those inquiries, requests, and feedback). etc.

The Company will not acquire or use sensitive customer information such as race, creed, social status, medical history, criminal history, or the fact that a customer has been a victim of a crime (“Sensitive Information”) unless required by law or the customer has given consent.

Article 5 (Disclosure and Provision to Third Parties)

The Company will strictly manage Personal Information and will not disclose or provide Personal Information to third parties without the consent of the customer except in the following cases; provided, however, that cases involving joint use or provision through outsourcing do not fall under the category of disclosure or provision to a third party:

1. when it is necessary for the protection of a person’s life, body, or property and it is difficult to obtain the customer’s consent;
2. when it is necessary for the enhancement of public health or the promotion of healthy development of a child/children and it is difficult to obtain the customer’s consent;
3. when it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the customer’s consent may interfere with the execution of such affairs;
4. cases in which Personal Information is provided as a result of the succession of business due to merger or other reasons; or
5. other cases permitted by laws and regulations.

Article 6 (Outsourcing of Handling of Personal Information)

The Company may outsource all or part of the handling of Personal Information within the scope necessary to achieve the purpose of use. In doing so, the Company will thoroughly screen contractors for eligibility, stipulate confidentiality obligations in the contract, and provide necessary and appropriate supervision of the contractors.

Article 7 (Joint Use of Personal Information)

The Company may allow joint use of customer Personal Information within the following scope and for the following purposes.

Article 8 (Transfers Outside Japan)

If the Company is to provide customer Personal Information to third parties such as business entities outside of Japan, including subcontractors and joint use partners, the Company will do so based on customer consent, except in the following cases:

1. if the third party is located in a country that is stipulated by law as having a Personal Information protection system of a level equivalent to that of Japan; or
2. if the third party has established a system necessary for the third party to continuously take measures equivalent to those required to be taken by business operators handling Personal Information in Japan.

In the case of 2. above, the Company will take necessary and appropriate measures to ensure the continued implementation of the equivalent by the third party.

Article 9 (Management of Personal Information)

The Company manages its customers’ Personal Information appropriately and takes necessary security control measures to prevent leakage, loss, falsification, etc. In addition to providing internal training to directors and employees regarding the protection and appropriate handling of customers’ Personal Information, the Company will set a retention period for Personal Information in accordance with the purpose of use, and dispose of such information in an appropriate manner when the purpose of use has been achieved.

Article 10 (Claims Regarding Handling of Personal Information)

When the Company receives a request from a customer for disclosure, correction, deletion, addition, suspension of use, erasure, or provision of information on Personal Information protection measures (hereinafter referred to as “Disclosure, etc.”) regarding the said customer’s Personal Information held by the Company, the Company will, after confirming the identity of the customer who made the request, respond as follows in accordance with laws and regulations within a reasonable period and scope.

1. Request for disclosure
   Based on customer request, the Company will disclose items of Personal Information, the purpose of use, or records of provision to third parties.
2. Request for correction, deletion, or addition
   The Company will check the contents of the customer request and correct, delete, or add to the contents of the customer’s Personal Information to the extent appropriate and possible.
3. Request for suspension of use or erasure
   In accordance with the contents of the request, the Company will stop using the items of Personal Information specified by the customer to the extent appropriate and possible, and if the customer so requests, will erase the information.
   Please note that such suspension of use or erasure of Personal Information may make it impossible to provide services that were previously available or services desired by the customer. Please be aware of this possibility in advance before submitting the request.
4. Request for provision of information on Personal Information protection measures
   According to customer request, the Company will provide information regarding the following:
   1.details of security control measures taken by the Company; and
   2.details of the measures taken by the Company in providing customer Personal Information to third parties outside of Japan.

The Company may not be able to respond to a customer’s request if doing so would significantly interfere with the Company’s normal business operations, violate laws or regulations, or harm the life, body, property, or other rights or interests of the customer or a third party.

Article 11 (Privacy Policy Modification Procedure)

The Company will review and improve this Policy when appropriate. The contents of this Policy are subject to change, except as otherwise provided by law or within this Policy. The revised Privacy Policy is to become effective when it is notified to customers or posted on the Company’s website in a manner prescribed by the Company.

Article 12 (Use of Access Analytics and Spam Prevention Tools)

This website uses Google Analytics to monitor site usage and reCAPTCHA to prevent spam. In connection with these services, user information is collected through cookies and similar technologies provided by Google, but no personally identifiable information is obtained. Collected data is managed in accordance with Google’s Privacy Policy and the terms of service for each respective service.
For further details, please refer to the following pages.

Google Privacy Policy：https://policies.google.com/privacy
Google Terms of Service： https://policies.google.com/terms

Article 13 (Customer Service)

For requests or inquiries regarding the Company’s handling of Personal Information, please contact us at the address below or by using the Inquiry Form.
ANA Systems Co., Ltd. Customer Service
[Address] Haneda Innovation City, 1-1-4 Haneda Airport, Ota-ku, Tokyo 144-0041

Revised on July 1, 2024