Privacy Policy

ADK Holdings Inc. and ADK Group companies (hereinafter, the “ADK Group*1) have established the following policies regarding the handling of personal information necessary for the operation of the ADK Group. In addition, in accordance with the following policies, we will endeavor to ensure the appropriate management of personal information by establishing various regulations for the protection of personal information and keeping all managers and employees, etc. informed of such regulations.

*1 In this Policy, the ADK Group companies refer to ADK Marketing Solutions Inc., ADK Creative One Inc., ADK Emotions Inc., ADK Communications Inc., ADK Digital Operations Inc., ADK Digital Communications Inc., CHERRY INC., FACT Inc., A-Bridge Inc., Studio KAI Inc., NIHON AD SYSTEMS INC., and Right Song Music Publishing Co., Ltd.

The ADK Group will comply with all applicable laws, regulations and contractual obligations relating to the protection of personal information in relation to the handling of personal information to be handled in all businesses. We will also strive to comply with other standards and guidelines, etc. related to the protection of personal information.

In handling personal information, the ADK Group will define the purpose of use and will not use personal information beyond the scope of the purpose of use without your prior consent. In addition, we will not collect personal information through deception or other wrongful means. When we collect personal information, we will promptly notify you of the purpose of use or publicly announce the purpose of use on our company website, etc., unless we have publicly announced the purpose of use in advance.
The ADK Group will collect and use the following types of personal information about you in order to achieve the purposes of use listed below. If we have separately given notice of or publicly announced any purpose of use of the following types of personal information about you, we will also collect and use such personal information to achieve such purpose of use.

(1) Personal information that the ADK Group itself collects

Subject of Personal Information	Purpose of Use	Personal Information to be Handled
The ADK Group's business partners (including potential business partners) or their respective employees * Business partners: This includes all individuals or corporations that do business or otherwise collaborate with the ADK Group, including, but not limited to, advertisers, media companies, research companies, vendors, celebrities and other public figures, and copyright or other right holders.	- To communicate with business partners (e.g., communications to request a visit or to arrange a schedule) or to conduct meetings with business partners - To respond to communications from business partners (e.g., communications to request a visit or to arrange a schedule, inquiries about the ADK Group's business and services) - To control access to our offices - To conduct questionnaire surveys and statistical analysis, etc. for the purpose of strengthening and improving the ADK Group's businesses, sales activities and services - To conduct marketing activities such as distributing various types of information (information about the ADK Group's services, events and web content, publications and seasonal announcements, etc.) - To confirm matters necessary to initiate transactions, to make payments related to transactions, and to conduct other management necessary for transactions	- Information such as name, age, address, gender, date of birth, facial photo, telephone number, email address, social media account, company name, department name, and job title - Any and all information contained in documents and electromagnetic records provided by business partners to the ADK Group - Any and all details of inquiries, questions, meetings and other communications in all forms and content between the ADK Group and business partners

Those who have made inquiries to the ADK Group	- To respond appropriately to inquiries to the ADK Group - To manage the details of inquiries for the purpose of strengthening and improving the ADK Group's businesses, sales activities and services - To control access to our offices	- Information such as name, age, address, gender, date of birth, facial photo, telephone number, email address, social media account, company name, department name, job title, and school name - Details of inquiries

Those who wish to join the ADK Group	- To communicate with applicants (e.g., communications to schedule interviews, or to inform applicants of screening results) in the course of recruitment activities - To respond to communications from applicants (e.g., communications to schedule interviews, to ask questions about the screening process, to accept or decline job offers) - To understand the attributes and other basic information of applicants and to evaluate their eligibility (including use in background checks, aptitude tests, and other verification procedures) when screening candidates for employment - To provide applicants with information about the ADK Group's recruitment activities - To manage information about applicants - To conduct medical examinations, and personnel, labor, welfare and other employment management after hiring - To conduct statistical analysis for the purpose of strengthening and improving recruitment and developing human resources - To control access to our offices	- Information such as name, age, address, gender, date of birth, telephone number, and email address - Any and all information contained in resumes, CVs, entry forms, questionnaires, and other documents provided by applicants to the ADK Group for the purpose of applying for employment (e.g., educational background, work experience, qualifications and licenses held, current annual income) - Any and all details of inquiries, interviews, and all other forms of communication between the ADK Group and applicants - Any and all information the ADK Group obtains in any background checks, aptitude tests and other similar verification procedures in connection with screening candidates for employment History of application and participation in recruitment activities and results of screening for employment

All shareholders of the ADK Group	- To exercise rights and perform obligations under the Companies Act and other laws and regulations - To provide various benefits (e.g., various shareholder return measures) from the ADK Group to those with shareholder status - To conduct various measures (e.g., questionnaires) to facilitate the relationship between shareholders and the ADK Group - To conduct various types of management (e.g., preparation of shareholder data and management of the status of exercising voting rights at general meetings of shareholders) for the smooth provision of services to shareholders in accordance with various laws and regulations	- Name, address, number of shares held, and other information

General consumers	- To conduct questionnaire surveys, consumer trend surveys and statistical analysis, etc. for the purpose of implementing, strengthening and improving the ADK Group's businesses, sales activities and services - To provide personalized information based on individual attributes and action history - To provide products and services (e.g., prizes, campaigns, services for members) - To film programs and commercials, etc., and to hold events and seminars, etc. - To control access to our offices - To distribute various information, etc. (on the ADK Group's services, events and programs, etc.)	- Information such as name, age, address, gender, date of birth, facial photo, telephone number, email address, social media account, company name, and school name - Any and all information contained in documents provided to the ADK Group by consumers through questionnaires, and campaign application forms, etc. - Any and all details of all forms of communication between the ADK Group and consumers

(2) Personal information that the ADK Group collects in connection with operations outsourced by advertisers

Subject of Personal Information	Purpose of Use	Personal Information to be Handled
General consumers	- To perform operations related to prizes and campaigns, operations to provide services for members, research operations, personalization and other operations based on individual attributes and action history, operations to film programs and commercials, etc., and operations to host events and seminars, etc. and other operations outsourced by clients to the ADK Group	- Information on general consumers to be collected by the ADK Group in the course of performing the operations described on the left, such as name, age, address, gender, date of birth, facial photo, telephone number, email address, social media account, company name, and school name *

* Such information may include information, such as cookies, that constitutes personal information with which the ADK Group's clients can identify specific individuals although the ADK Group cannot.

The ADK Group will take necessary and appropriate measures for the safe management of its information assets.
- We will keep personal information accurate and up to date to the extent necessary to achieve the purpose of use, and will endeavor to delete it without delay when it becomes no longer necessary to use it.
- We will establish an organizational structure to properly manage the personal information we collect, take organizational, human, physical and technical security control measures, and work to prevent and correct any unauthorized access, falsification, leakage, loss and damage, etc.
- We will educate and raise the awareness of all employees regarding the protection of personal information to ensure that they recognize the importance of protecting personal information and properly manage and handle it.

ADK Holdings, Inc., ADK Marketing Solutions Inc., ADK Creative One Inc., ADK Emotions Inc., and A-Bridge Inc., which are members of the ADK Group, have obtained ISO 27001 (ISMS) certification, the international standard for an information security management system, and our information security management system has been evaluated by a third-party organization as objectively adhering to the strictest information security standards.

In addition to the above, for further information on the ADK Group's personal information management system and the measures it has taken, please contact the contact point listed in "8. Inquiries."

In principle, the ADK Group will not, without your consent, disclose or provide personal information to any third party other than its subcontractors or outside the scope of shared use described in "5. Shared Use". However, this will not apply if it is required by laws and regulations or if it is required to cooperate with public institutions.

The ADK Group may share the personal information it retains as set forth below.

[Items of personal information to be shared]
Same as personal information to be handled listed in "2. Collection and Use of Personal Information" above

[Scope of shared use]
ADK Group companies

[Purpose of shared use]
Same as the purpose of use listed in "2. Collection and Use of Personal Information" above

[Name of the person responsible for the management of personal information to be shared]
ADK Holdings Inc. (Please refer to https://www.adk.jp/en/about/outline/ and representative of ADK Holdings Inc.)

The ADK Group may outsource the handling of personal information to third parties such as subcontractors if it deems it necessary for its business operations. When outsourcing the handling of personal information, we will select a contractor that satisfies a sufficient personal information protection standard, conclude a contract, etc. that stipulates that the contractor shall observe the standard of protection we require, and supervise the contractor appropriately.

If, with respect to any personal information the ADK Group retains, we are requested by an individual, based on the rights of the individual, to give notice of the purpose of use, disclose, correct, add to, delete, discontinue the use, erase, discontinue the provision to a third party, or disclose records of the provision to a third party, we will accept such request via the contact point listed in "8. Inquiries" and promptly respond to the request within a reasonable and appropriate scope after confirming the identity of the individual or his or her agent.
In responding to such request, we may ask you to bear any fees.
If we are unable to accommodate your request in whole or in part, we will explain the reasons.

Office of Corporate Communications, ADK Holdings Inc.
Toranomon Hills Mori Tower 1-23-1 Toranomon, Minato-ku, Tokyo 105-6312 JAPAN
* For inquiries to the ADK Group, please contact us by selecting "Other inquiries regarding this site" found on the "ASK" page of our website. In accordance with the content of your inquiry, we will respond appropriately in cooperation with the ADK Group companies.

The ADK Group will review its management system for the protection of personal information in light of changes in social conditions and the environment, and will continually improve its efforts to protect personal information as necessary.

The ADK Group may change or revise the content of this Policy without prior notice in response to laws and regulations, business necessity or otherwise.
Please carefully review the content of the latest policy posted on this website.

March 1, 2022
Edition 1 (March 3, 2022)