Policy for Protection of Personal Information

SILVER LIFE Co., Ltd. (“the Company”), fully recognizing that it has a social mission to protect all personal information handled by the Company, will comply with laws and regulations regarding the protection of the rights and personal information of owners of personal information (principals). Further, the Company has established a management system for the protection of personal information to realize the policies indicated below and hereby declares the entire company’s full commitment to the continuous improvement of that system, while remaining constantly aware of the latest developments in information technology, changes in social demand, and fluctuations in the business environment.

1. 1.The personal information handled by the Company is acquired, used, and provided only to the extent required in the Company’s operations for the reasonable execution of the Company’s business, employment of staff, and personnel management. The Company will not handle personal information beyond the extent necessary for the achievement of specific purposes (use outside purpose). The Company will also take measures to ensure that there is no use of personal information outside purpose.
2. 2.The Company will comply with laws and ordinances, guidelines set forth by the national government, and other codes pertaining to the protection of personal information.
3. 3.The Company will take reasonable safety measures and inject management resources commensurate with the circumstances of the business to prevent risks such as the leaking, loss, or damage of personal information and will continuously improve its personal information security systems. Further, if such a risk eventuates, the Company will take prompt corrective action.
4. 4.The Company will respond swiftly, appropriately, and in good faith to any inquiries, complaints, or requests for advice regarding the handling of personal information.
5. 5.The Company will continuously review and improve the management system for the protection of personal information that it has established appropriately and in a timely manner, based on changes in the environment surrounding the Company.

Takahisa Shimizu
President, CEO
SILVER LIFE Co., Ltd.
4-32-4 Nishishinjuku, Shinjuku-ku, Tokyo

PRIVACY POLICY (Handling of Personal Information)

SILVER LIFE Co., Ltd. (“the Company”), as a personal information handling business operator, will comply with the laws and ordinances related to the protection of personal information and pay the closest attention to its handling of the personal information provided to the Company, based on the Company’s Policy for Protection of Personal Information.

1.Personal Information

Personal information refers to names, addresses, telephone numbers, facsimile numbers, e-mail addresses, age, and other provided information by which, either singly or in combination, an individual can be identified.

2.Purpose of Use of Personal Information

When the Company obtains personal information from customers directly or is sub-contracted to undertake personal information handling operations, it will specify the purpose of use as follows and use the personal information only to the extent of that purpose of use.

(1) Information regarding customers

To provide information about products, services, etc. in the XX business of the Company

To notify and provide information about new businesses, products, services, etc.

To provide products, services, etc. requested by the customer and for confirmation and notifications regarding same

To notify about various events, campaigns, etc. in the XX business of the Company

To conduct and analyze customer surveys

In the event the Company has been sub-contracted by another business operator, etc. to handle customer information, to execute the sub-contracted operations

For procedures pertaining to payments for products, use of services, etc.

For procedures for the exercise of rights and performance of obligations pursuant to contracts, laws, etc.

(2) Information regarding franchisees and prospective franchisees

To accept applications and provide notifications regarding franchise briefing sessions

For franchise agreement procedures

To provide information regarding the operations of franchisees

To respond to inquiries from franchisees

For procedures concerning claims made to franchisees

For procedures for the exercise of rights and performance of obligations pursuant to franchise agreements.

(3) Information regarding transaction counterparties

To provide information and various types of contact pertaining to transactions with the Company

To respond to inquiries from transaction counterparties

To provide products, services, etc. pertaining to orders and for confirmation and notifications regarding same

For procedures for the exercise of rights and performance of obligations pursuant to contracts, laws, etc.

(4) Information regarding applicants for employment at the Company

To notify interview dates and times and the results of screening

To respond to inquiries from applicants

To provide notifications regarding other recruitment activities of the Company

3.Security Measures

Regarding the security measures set forth in Paragraph 3 of the Policy for Protection of Personal Information, the Company will undertake the following actions to prevent leaks, etc.

i. Basic Policy

The Company has established a basic policy to secure the appropriate handling of personal information.

(Policy for Protection of Personal Information and Privacy Policy)

ii. Organizational Security Measures

The Company has established internal regulations and manuals regarding the methods of handling of personal information and has clarified the responsibilities and authorities of workers regarding the security control of personal information.

The Company appoints “Personal Information Protection Managers” and conducts inspections of the state of compliance.

iii. Personal Security Measures

The Company conducts training of workers on the handling of personal information.

When charging workers with the handling of personal information or tasking them with the handling of personal information through sharing as described below, the Company obliges workers to conduct lawful and appropriate handling pursuant to contracts, etc., and otherwise supervises workers.

iv. Physical Security Measures

Entry to and exit from areas of the company where personal information is handled and stored are controlled.

Access to personal information is monitored, including limiting the authority to handle personal information and restricting access by unauthorized persons.

The use of external storage devices is prohibited and the taking of all internal data, including personal information, out of the company is restricted.

v. Technical Security Measures

Measures are taken to protect against unauthorized access from outside the company and from unauthorized software, etc.

vi. Establishment of Discipline Regarding Handling of Personal Information

The Company has formulated rules for the handling of personal data, including handling methods, responsible managers and workers and their duties, at each stage of handling, including acquisition, use, preservation, provision, deletion, and disposal.

4.Disclosure and Provision to Third Parties

The Company will not disclose or provide personal information provided by you to third parties, except in cases that fall under any of the following:

• Where the principal has given consent
• Disclosure or provision in a condition whereby the principal cannot be identified, e.g., as statistical data
• Where disclosure or provision is required by law or ordinance
• Where it is necessary for the protection of human life, body or property and it is difficult to obtain the consent of the principal
• Where it is particularly necessary to improve public health and to promote the sound development of children and it is difficult to obtain the consent of the principal
• Where it is necessary to cooperate with the national government, local government, or a party sub-contracted by same in the execution of administrative procedures set forth in law or ordinance, and there is a risk that obtaining the consent of the principal would impede the execution of said administrative procedures
• When sub-contracting the handling of personal information to a third party to the extent necessary for achieving the purpose of use to which you have given your consent.

5.Disclosure, Amendment, Deletion, Suspension of Use, Etc. of Personal Information

If you wish for the disclosure, amendment, deletion, suspension of use, etc. of personal information acquired by the Company, please lodge a request at the contact details that appear below. Once we have been able to confirm that the request has been made by the principal, we will disclose, amend, delete, or suspend use, etc. of your personal information pursuant to the Act on the Protection of Personal Information, without delay. When lodging your request, please submit documentary evidence that the request is being made by the principal.
Please note that a fee of ¥1,000 is payable for requests for the disclosure or notification of purpose of use of personal information.

6.Sharing

To provide comprehensive services between the Company and franchisees, personal information entrusted to us by customers may be shared to the extent of the purpose of use.

(1) Extent of parties to sharing

The Company and franchisees that have concluded franchise agreements

(2) Purpose of sharing

As per the purposes of use described in “(1) Information regarding customers” under “2. Purpose of Use of Personal Information”

(3) Personal data subject to joint use

Name, address, date of birth, telephone number, and other transaction information, etc. necessary for the purpose of sharing stated in (2) above

(4) Responsible manager of shared personal information

Management Department,
SILVER LIFE Co., Ltd. (President, CEO: Takahisa Shimizu)
Highness Lofty Level 2
4-32-4, Nishishinjuku, Shinjuku-ku, Tokyo, 160-0023
* For inquiries, please refer to “8. Inquiries Regarding Personal Information” below.

7.Handling of Cookies, etc.

To provide customers with better products and services, the Company may use cookies, web beacons, and other similar technologies on its website as described below. In all such cases, no new personal information is contained in the data thus collected, but it may be used in connection with that personal information already received.
Further, to measure the effectiveness of affiliate advertisements, the Company website may use a tool operated by a third party to acquire data (date clicked, website of ad placement, etc.) of the advertisement that you clicked on prior to visiting the Company website and cross-reference it with order information. In all such cases, no new personal information is contained in the data thus collected, but it may be used in connection with that personal information already received.

(1) Cookies

A cookie is a technology that stores information such as your website visit history on your computer. The cookie installed on your computer when you visit the Company’s website is mainly used for your added convenience when using the Company’s website and services. You can use your browser’s functions to select settings such as “Delete cookies” and “Do not accept cookies.” However, if you select a setting that deletes cookies or deactivates their functions, this may limit all or some of the features of the webpages.

(2) Web Beacons

The term “web beacon” refers to technologies that use JavaScript and small image files, etc. embedded in the website or HTML emails to collect and analyze the status of viewing of websites and HTML emails. The main purposes of the use of web beacons are to statistically identify the status of use or access to specific web pages, etc. and to put that information to use in the improvement of services.

8.Inquiries Regarding Personal Information

Management Department,
SILVER LIFE Co., Ltd.
Highness Lofty Level 2
4-32-4, Nishishinjuku, Shinjuku-ku, Tokyo, 160-0023
Tel: 03-6300-5622 (9:00 a.m. to 6:00 p.m. Monday to Friday)
Fax: 03-6300-5626

Formulated on November 25, 2013
Enforced on December 1, 2013
Last revised on March 15, 2022