PRIVACY POLICY PRIVACY PRIVACY POLICY

Keihan Distribution Systems Co., Ltd. (hereinafter referred to as the "Company") is a 100% owned subsidiary of Keihan Holdings Co., Ltd., and manages KUZUHA MALL, Keihan City Mall, Keihan Mall, KYOTO TOWER SANDO.

The Company has established the following policies in order to comply with laws and other norms related to the protection of personal information and to ensure proper use and management of personal information.

The Company complies with the Personal Information Protection Law and related laws and regulations, and establishes and complies with the rules concerning the protection of personal information. In addition, we will review the contents as necessary and make continuous improvements.

Keihan Distribution Systems Co., Ltd.

Please refer to the following for information such as address and representative of Keihan Distribution Systems Co., Ltd.

The Company collects, retains and uses the following personal information:

• Personal information received from customers, business partners, and tenant employees (address, name, gender, age, date of birth, occupation, telephone number, e-mail address, various questionnaires, etc.
  Required items in the application form, campaign, application form, inquiry, contract, job application, etc.)
• Information generated by the purchase of products or the use of various cards
• Information collected legally by other fair means

The Company shall use personal information only within the scope of the following purposes, except with the prior consent of the customer himself.
However, in accordance with laws and regulations, we may use it beyond the scope of the purpose of use without obtaining prior consent.

[Purpose of Use of Personal Information]

Purpose of use of customer's personal information

• To confirm that the registered personal information belongs to the person.
• To respond to inquiries from customers
• To analyze information such as purchase history acquired at facilities operated by the Company, and to advertise store information, events, and services according to hobbies and preferences.
• In order to analyze information such as purchase history acquired at facilities operated by the Company, and to provide benefits and services to members
• To analyze acquired information such as purchase history and the results of questionnaire surveys, and conduct marketing activities related to facilities operated by the Company
• For advertising on various events, products, services, etc. of stores that are opened in facilities operated by the Company according to their hobbies and preferences by analyzing information such as purchase history acquired.
• To send you the prizes you have applied for, the products you purchased, etc.
• For communication in the event of trouble related to products, services, services, etc. purchased in the facility operated by the Company
• For contacting in unexpected situations and administrative procedures

Purpose of use of personal information of business partners and tenant employees

• To issue an admission certificate for tenant employees and confirm entry and exit
• For contacting tenant employees regarding facility operation
• For negotiations, communication, consultation, examination, ordering, settlement and response regarding transactions
• For the transfer of goods or services based on the transaction

Purpose of use of personal information of employees and retired employees

• For business communication, attendance management, salary payment, appropriate staffing, evaluation, capacity development, welfare, health and safety labor management, other labor-related laws, tax-related laws and social welfare-related laws
• Acceptance, performance and management of various procedures stipulated in internal regulations

Purpose of use of personal information of applicants

• For consideration and determination of acceptance
• For the provision of company information, recruitment information, acceptance or rejection and other information, and various communications

The Company will not provide personal information to third parties without obtaining the prior consent of the customer, except in the following cases.

• Based on laws and regulations
• When it is necessary for the protection of the life, body or property of the person or the public, and it is difficult to obtain the consent of the customer.
• In cases where it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the customer.
• In cases where it is necessary to cooperate with national institutions, local governments, or those entrusted by them to carry out affairs stipulated by laws and regulations, and obtaining the consent of the customer may hinder the execution of such affairs.
• To the extent necessary to achieve the purpose of use, when such personal information is provided in connection with outsourcing all or part of the handling of personal information
• When personal information is provided in connection with the succession of business due to merger or other reasons
• When providing information to persons listed in the scope of “6. Shared Use of Personal Information”

The Company may share personal information with Keihan Group companies to the extent necessary to achieve the purpose of use. In that case, the following matters shall be notified to the person in advance, or placed in a state that the person can easily know.

• Items of personal information used jointly
• Scope of those who use jointly
• Purpose of use of the user
• Name or name of the person responsible for the management of such personal data

（1） Formulation of Basic Policy

In order to ensure the proper handling of personal data, we have formulated a basic policy (privacy policy) on compliance with related laws and regulations and response to complaints and consultations.

（2） Developing disciplines related to the handling of personal data

For each stage of acquisition, use, storage, provision, deletion and disposal of personal information, the personal information protection regulations that define handling methods, persons in charge, and their duties, etc.
We have established related regulations.

（3） Organizational Safety Management Measures

We have established a personal information general manager as the chief officer in charge of personal information protection, and a personal information protection officer and personal information manager in each department that handles it.
The person in charge of personal information shall limit the number of persons who can use personal data, properly manage access rights, and create a ledger to understand the handling status.
We conduct self-inspections on a regular basis. In addition, we have established a system to respond to incidents of leakage.

（4） Human safety management measures

We provide regular education and training for employees on information security, including matters to be noted regarding the handling of personal data.
In addition, employees who handle personal data have pledged to maintain confidentiality.

（5） Physical Safety Management Measures

Offices where equipment handling personal data are installed are managed, such as locking and restricting access to persons other than those involved.

（6） Technical Safety Management Measures

In addition to setting and managing access rights for personal data, the scope of users and personal information databases handled is limited.
We take measures such as encrypting personal data as necessary.
In addition, we have established a system to record and analyze the status of access to personal data, and to prevent and detect leakage of personal data by monitoring the system.
We are also taking measures.

（7） Understanding the External Environment

We carry out security management measures after understanding the law on the protection of personal information in Japan where personal data is stored and other related laws and regulations.

With respect to requests for notification, disclosure, correction, addition, deletion, suspension of use, or recording and suspension of provision to third parties, except for exceptional measures stipulated in laws and regulations.
After confirming your identity, we will respond to it within a reasonable range. Please apply in the form prescribed by the Company. In addition, if you request a “Notification of Purpose of Use” or “Disclosure”, a fee of 500 yen (including consumption tax, etc.) will be charged for each request. Also, please note that it may take a few days to respond.

• This website (www.kyoto-tower-sando.jp/ hereinafter) is the official website of KYOTO TOWER SANDO.
• Copyrights for all text materials, image materials, audio and video, and other program data posted on this site belong to KYOTO TOWER SANDO. However, if a material provided by a third party other than KYOTO TOWER SANDO is reprinted, it belongs to the copyright holder of the material to which it is reprinted.
• It is forbidden to copy, process, or redistribute these materials without permission from our company.
• Please browse this site at your own risk.
• We are not responsible for any damage or trouble caused by the use.
• The contents are subject to change without notice. Thank you for your understanding.

This website may have links to other websites, but please check the handling of personal information at the linked sites by yourself.
We do not take any responsibility for any damage caused by the use of various information obtained using your personal information from other websites with links to this website.