NTT Digital Inc. (hereinafter referred to as “Digital”) may acquire and use your Personal Data (not limited to personal information as set forth in the Act on the Protection of Personal Information and including all data concerning an individual) to provide various services that enable you to enjoy a rich and comfortable life.

Therefore Digital believes that the proper handling of Personal Data in business activities is our important duty, and we have established this Privacy Policy as a policy regarding the handling of Personal Data, while making decisions on the Personal Data handing in accordance with the Principles of Conduct of the “NTT DOCOMO Personal Data Charter” of the NTT DOCOMO Group.

1.Proper handling of Personal Data

Digital will comply with the applicable domestic and foreign laws and regulations, guidelines, etc., and by continuously improving this Privacy Policy, we will make every effort so that our customers can use convenient, safe, and secure services.
In addition, Digital will acquire Personal Data by fair means, establish an appropriate management system and internal rules, and provide necessary education and training to our employees.

2.Acquisition of Personal Data

Digital will acquire Personal Data in the instances such as the following:

• When Personal Data is directly provided by the customer to Digital
  We acquire Personal Data when you fill in information about yourself in writing or when you register and/or send it through your smartphone, etc.
• When Personal Data is automatically recorded as the customer uses our services, etc.
  When you use our services, etc., information such as service usage history on the Internet may be automatically recorded on the blockchain or on our servers, etc., or information recorded on devices may be automatically transmitted to us depending on the settings of the smartphone or other devices.
• When Digital indirectly obtains Personal Data as the customer uses third-party services
  We may obtain information such as shopping and service usage history upon your use of third-party services or transactions on the blockchain or may receive such information from such third parties.

3.Purposes of Use of Personal Data

(1) Digital will use your Personal Data to the extent necessary to achieve the following purposes.

Purpose of Use 1: Providing services, products, etc. and communicating with customers regarding such services, products, etc. as necessary

The following are some examples of Purpose of Use 1:

• Providing various services and functions under the terms of an agreement and executing other terms of an agreement
• Confirming the identity of a person or his/her family members at the time of application and use of the services, etc.
• Confirming whether the application conditions have been satisfied
• Determining credit and managing post-credit
• Calculating and/or invoicing the billing amount (including for collection agencies) and managing points
• Disposing of claims and/or rights acquired against the customer, pledging collateral and for other transactions
• Sending age information notifications at the time of use of services of contents providers corresponding to age determining functions
• Sending notifications of required matters concerning an agreement
• Arranging, sending and after-servicing ordered products
• Communicating with the customer upon the occurrence of fraudulent contracts, unauthorized use and non-payment
• Responding to opinions, requests, inquiries, etc. concerning the services

Purpose of Use 2: Proposing services, products, etc. and communicating with customers regarding such services, products, etc.

The following are some examples of Purpose of Use 2:

• Providing information on various sales promotion campaigns and events of Digital, our partner businesses, etc.
• Drawing winners, sending prizes and gifts and providing notifications for various sales promotion campaigns, etc.
• Providing information on products, services, contents, etc. recommended for the customer
• Displaying and delivering advertisements of Digital or other companies that are appropriate for the customer

Purpose of Use 3: Implementing maintenance and anti-fraud measures necessary for reliable and stable provision of services, products, etc.

The following are some examples of Purpose of Use 3:

• Operating and maintaining networks, applications, systems, etc.
• Preventing and responding to the occurrence of failures, defects, accidents, etc. of products, services, networks, applications, systems, etc.
• Preventing the occurrence of and implementing countermeasures upon the occurrence of fraudulent contracts, unauthorized use and non-payment

Purpose of Use 4: Planning, developing and improving services, products, etc. and conducting research and analysis

The following are some examples of Purpose of Use 4:

• Planning and developing new products, new services and new technologies
• Improving service quality and customer services
• Conducting research and analysis of sales status and usage status
• Conducting research on the awareness and actual state of products and services and various sales promotion campaigns, etc. (including, but not limited to those of Digital, partner businesses, etc.)
• Conducting research and analysis for carrying out various sales promotion campaigns, etc. and measuring the effects thereof.
• Conducting questionnaire surveys

【Customer Analysis】

We will conduct Personal Data analysis within the scope of the purposes of use as set forth in this Privacy Policy. The results of our analysis of Personal Data such as service usage history will be utilized to estimate the interests, preferences, trends, etc. of customers and make proposals and distribute advertisements and developing services and products tailored to such customer interests, preferences and trends, etc.
When analyzing Personal Data, we will consider whether it will benefit customers and contribute to society. We will not use Personal Data in any way that could harm the customer's credibility.
Please see below for specific usage examples.

Examples of purposes of use of customer analysis

• Analyzing Personal Data acquired from each service, such as service usage history, website browsing history, purchase history, location information and contract details and making proposals and distributing advertisements for services and products tailored to customers’ interests, preferences and trends.
• Analyzing customers' Personal Data, aggregating the results into statistics in a way that does not identify individual customers and providing the statistics to third parties such as partner companies.
• Analyzing Personal Data such as service usage history acquired by each service to develop, provide and improve services and products.
• Analyzing the customer's Personal Data and using or providing the results of analysis to partner companies to the extent agreed by the customer after the customer is informed by each service or measure of the purposes of data use and its provision to such third parties.

(2) Digital will not use Personal Data in the following way:

Unfairly discriminate against the customer in determining whether to provide services to the customer

(3) Digital may continue to use Personal Data even after the individual contract for the service provision, etc. terminates.

(4) If Digital uses Personal Data to perform services entrusted from other businesses, etc., Digital will use Personal Data only to the extent necessary to perform such entrusted services.

4.Consent to the handling of Personal Data

Digital may obtain your prior consent to use, provide to third parties (including third parties in foreign countries) or otherwise handle your Personal Data.
In addition, to the extent permitted by the laws and regulations, Personal Data may be used for purposes other than those listed in 3 (1) or may be provided to third parties (including third parties in foreign countries) without the customer’s consent, but also in such instances, Digital will give due consideration to your rights and interests.

5.Claim Procedures regarding Records on Third Party Provisions of Retained Personal Data / Personal Data

Please refer to the link below for “Disclosure Request Procedures regarding Retained Personal Data of Customers” and “Disclosure Request Procedures for Records on Third Party Provisions concerning Personal Data of Customers.”
Claim Procedures regarding Records on Third Party Provisions concerning Retained Personal Data / Personal Data

6.Safety management of Personal Data

To ensure that our customers can use our services with ease, Digital has declared the “Information Security Policy” as our policy for information security initiatives. Digital will take necessary and appropriate measures to prevent leakage, loss or damage of Personal Data and for other safety management of Personal Data.

7.Entrustment of Personal Data handling

Digital may entrust all or part of the handling of Personal Data for sales and reception services, repair services, fee and credit-related services, website and system operation services, event and campaign implementation services, data processing and analysis, and other services. In such cases, we will select those recognized as handling Personal Data properly and implement appropriate supervision.

8. Publication of Other Matters regarding the handling of Personal Data

We publish information on joint use of Personal Data, handling of anonymized processed information and pseudonymized processed information and other matters as necessary under the link: “Publication of Other Matters regarding the handling of Personal Data.”

9.Inquiries regarding the handling of Personal Data

For inquiries regarding our handling of Personal Data, please contact the following inquiry service desk.

[Mail to:]

Service Desk for Personal Information

NTT Digital, Inc.

Sanno Park Tower 10F

2-11-1 Nagata-cho, Chiyoda-ku, Tokyo, 100-6150

[Email us at:]

privacy-info@ml.nttdigital.io

Service Desk for Personal Information, NTT Digital, Inc.

10.Revisions to the Privacy Policy

Digital may revise this Privacy Policy as necessary according to the laws and regulations and for business reasons. Revisions or other changes will be posted on this website.
In addition, Digital will take measures corresponding to the revision pursuant to the laws and regulations.

Established on July 1, 2023
Revised on November 22, 2023

CEO Kenichi Hamana
NTT Digital, Inc.
Sanno Park Tower 10F,
2-11-1 Nagata-cho, Chiyoda-ku, Tokyo, 100-6150