Privacy Policy

Date of Enactment: September 18, 2018 Date of Last Revision: May 19, 2021 Howtelevision, Inc. Representative Director and President Yosuke Otonari

Our Company, fully recognizing its social responsibility regarding the protection of all personal information it handles, complies with laws and regulations concerning personal information and protects the rights of individuals. Furthermore, we have established a personal information protection management system to embody the policies outlined below, and we hereby declare our company-wide commitment to its continuous improvement, while constantly recognizing trends in the latest IT technology, changes in social demands, and fluctuations in the business environment.

Personal information will be acquired, used, and provided by our company, limited to the extent necessary for the legitimate conduct of our career platform operation business, as well as for employee recruitment and human resources management. We will not handle personal information (use for purposes other than those specified) beyond the scope necessary to achieve the specified purpose of use. Furthermore, we will take measures to prevent the use of personal information for purposes other than those specified.
We will comply with laws and regulations concerning personal information protection, national guidelines, and other standards.
To prevent risks such personal information leakage, loss, or damage, we will implement reasonable security measures, allocate management resources appropriate to our business operations, and continuously enhance our personal information security framework. Furthermore, should any issues be identified concerning personal information protection, we will promptly take corrective measures.
We will respond promptly, sincerely, and appropriately to complaints and inquiries regarding the handling of personal information.
The Personal Information Protection Management System will be continuously reviewed and its improvement promoted in a timely and appropriate manner, taking into account changes in the environment surrounding our company.

End

Public Statement on Personal Information

Date of Enactment: September 18, 2018 Last Revised Date: January 31, 2023

Privacy Policy

1. Purposes of Use of Personal Information Handled by the Company

Category	Purpose of Use
① General Customer Information	For responding to inquiries
② Member Information	For managing member information For sending direct mail For scout delivery For user support For managing usage history Introducing Our Services For the sale and provision of products and services by our company and third parties, delivery, and payment processing. For responding to inquiries
③ Business Partner Contact Information	For the performance of contractual rights and obligations To provide information about our products and services For order confirmation (e.g., communication records)
④ Website Inquirer Information	To confirm the details of your inquiry and provide a response.
⑤ Employee Information	For employee employment management, including labor management, payroll management, social insurance management, work attendance management, onboarding and offboarding management, health and safety management, education and training management, and welfare benefits, etc.
⑥ Job applicant information provided to our company (including information obtained from recruitment agencies and recruitment media)	For contacting job applicants and managing our recruitment operations.
⑦ Specific Personal Information	for the purposes of use stipulated in the My Number Act
⑧ Personal information received from customers in the course of performing entrusted services	To appropriately perform the entrusted operations.
⑨ Recruitment Agent Information	To provide our services For responding to inquiries
(10) Web Push notification subscription information	To deliver Web Push notifications about our latest news and IR disclosures (see "About Web Push Notifications" below for details)

2. Handling of Credit Card Information

We entrust credit card payment processing to a payment processing service provider. Credit card information (card number, expiration date, security code) entered by members of our services through our system is held by the payment processing service provider, and we do not retain any credit card information.

Public Notice Regarding Retained Personal Data

Regarding retained personal data or records of provision to third parties held by our company, requests from the individual concerned or their representative for notification of purpose of use, disclosure, correction of content, addition or deletion, suspension of use, erasure, and suspension of provision to third parties (hereinafter referred to as "Requests for Disclosure, etc.") will be handled in accordance with the following procedures.

Name of Business Operator

Howtelevision, Inc. Roppongi Hills Mori Tower 28F 6-10-1 Roppongi, Minato-ku, Tokyo 106-6128 Representative Director and President Yosuke Otonari

Personal Information Protection Administrator

Administrator: Shintaro Shimizu
Department: Corporate Division
Contact: Email: [email protected]　TEL: 03-6427-2862

Purposes of Use of All Retained Personal Data

The purposes of use for retained personal data are those specified in items ① through ⑨ of "1. Purposes of Use for Personal Information Handled by the Company" under "■Handling of Personal Information" above.

Contact for Complaints Regarding the Handling of Retained Personal Data

Howtelevision, Inc. Personal Information Inquiry Desk
Roppongi Hills Mori Tower 28F, 6-10-1 Roppongi, Minato-ku, Tokyo 106-6128, Japan
Email: [email protected]　TEL: 03-6427-2862
(Hours: 10:00-19:00; excluding Saturdays, Sundays, public holidays, the year-end and New Year period, and Golden Week)

Certified Personal Information Protection Organization

Currently, our company is not a member of any Certified Personal Information Protection Organization.

Procedures for Responding to Requests for Disclosure, etc., of Retained Personal Data

Contact for Requests for Disclosure, etc.

For requests concerning disclosure, etc., please contact the Personal Information Inquiry Desk mentioned above.

Procedures for Disclosure Requests

Upon receipt of your request, we will mail you the designated request form, "Request Form for Disclosure, etc., of Retained Personal Data," for your use.
Please mail the completed request form, documents verifying the agent's identity (if the request is made by an agent), and a postal money order for the fee (only for requests for notification of purpose of use and disclosure) to the Personal Information Inquiry Desk mentioned above.
Upon receipt of the above invoice, for identity verification purposes, we will ask you for approximately two items of personal information registered with us that can be used to confirm your identity (e.g., phone number and date of birth).
As a general rule, responses will be provided to the individual concerned in writing (by postal mail).

Documents for verifying the agent's identity/authority, when the request is made by an agent.

If the person requesting disclosure, etc., is a proxy, please enclose documents proving their proxy status and documents identifying the proxy themselves. Any information regarding registered domicile contained in these documents should be limited to the prefecture, with subsequent information redacted (e.g., blacked out). Furthermore, please ensure that these documents do not contain a My Number (Individual Number), or that all digits are redacted (e.g., blacked out).

Document proving agency

＜For agents authorized by the individual to make disclosure requests, etc.＞

Original Letter of Proxy from the Principal

If the agent is the legal representative of a minor: A copy of any of the following

Certified Copy of Family Register
Certificate of Residence (with family relationship details)
Other official documents verifying legal representation authority

If the agent is the legal representative of an adult ward, a copy of any of the following.

Certificate of Registered Matters concerning Guardianship Registration, etc.
Other official documents verifying legal representation authority

② Documents to verify the identity of the proxy

Driver's License
Passport
Health Insurance Card
Certificate of Residence

Fees for Requests for Notification of Purpose of Use or Disclosure

1,000 yen per request (please enclose a postal money order with the invoice or other documents you send).

Details of the System and Measures for Handling Retained Personal Data

Formulation of Basic Policy

To ensure the proper handling of retained personal data, we have formulated a "Privacy Policy" covering "compliance with relevant laws, regulations, and guidelines," "contact points for inquiries and complaints," and other related matters.

Establishment of Rules for the Handling of Retained Personal Data

For retained personal data, we have established Personal Information Protection Regulations detailing handling methods, responsible persons/personnel, and their duties at each stage, including acquisition, use, storage, provision, deletion, and disposal.

Organizational Security Measures

We have appointed a person responsible for handling Retained Personal Data. We also clarify the employees who handle Retained Personal Data and the scope of Retained Personal Data they handle, and we have established a reporting and communication system to the responsible person in the event that facts or signs of violations of laws or internal handling rules are identified.
We regularly conduct self-inspections regarding the handling of personal data we hold, and also undergo audits by other departments and external parties.

Human security measures

We provide regular training to our employees on precautions regarding the handling of retained personal data.
We have received a confidentiality pledge from all employees, which covers retained personal data.

Physical Security Measures

In areas where retained personal data is handled, we control employee access and restrict the bringing in of equipment, and implement measures to prevent unauthorized viewing of retained personal data.
Measures are taken to prevent the theft or loss of equipment, electronic media, documents, etc., that handle retained personal data. In addition, when transporting such equipment, electronic media, etc., including movement within the office, measures are taken to ensure that retained personal data cannot be easily identified.

Technical Security Management Measures

We implement access control, limiting the scope of personnel and the personal information databases, etc., they handle.
We have implemented mechanisms to protect information systems that handle retained personal data from unauthorized external access or malicious software.

End

PrivacyMark

Our company, as a business that has established a system for implementing appropriate protective measures for personal information in compliance with Japanese Industrial Standard "JIS Q 15001 Personal Information Protection Management System - Requirements," has been evaluated by the Japan Institute for Promotion of Digital Economy and Community (JIPDEC) and granted the PrivacyMark.

Use of Cookies and Access Analysis

We use cookies and similar technologies to analyze website usage and improve our services.

1. Web Analytics Tools Used

We have implemented Google Analytics 4 (GA4) via Cloudflare Zaraz (server-side tag management). Your browser sends measurement requests to /cdn-cgi/zaraz/ on the same origin, and our Cloudflare edge sends anonymized measurement data to Google LLC. The front end of this website does not load Google Analytics tags (such as gtag.js) directly and does not communicate directly with Google domains.

2. Information Collected

Page View History (URL, Referrer, View Date and Time)
Browser and OS type, screen resolution
Regional information (IP addresses are processed after being masked and anonymized in accordance with the Cloudflare Zaraz and GA4 settings)
Site actions (e.g., file downloads, external link clicks, contact form submissions)

3. Data Controller and Retention Period

Measurement data is managed by Google LLC (United States), and our data retention period is 14 months. For details on how Google collects and uses information, please see Google Policies and Terms.

4. Use for Advertising Purposes

We do not use the data obtained through GA4 for advertising delivery or advertising optimization. The Google Signals feature is disabled.

5. Customer Choice (Consent Management)

In our cookie consent banner, shown on your first visit, you can choose your consent for the analytics purpose (Purpose: "Analytics") of Cloudflare Zaraz from the options below. At present, the only cookies subject to consent are those used for website analytics.

Allow all: allows cookies used for website analytics
Analytics cookies only: allows only cookies used for website analytics
Decline all: declines cookies used for website analytics (no measurement data is sent to GA4)

Your choice is stored in your browser for 365 days and the banner is not shown again. Before consent is given, and when it is declined, we treat the Zaraz consent state as declined. To change your choice, open your browser's developer tools console on this page and enter window.hwtConsent.reset() , or Click here.

6. Google Analytics Opt-out

If you wish to stop GA4 measurement on this website, select "Decline all" in the cookie consent banner described above. To stop measurement on other websites that load Google Analytics tags directly in the browser, you can also use the Google Analytics Opt-out Add-on. Your browser's "Do Not Track" setting is also respected.

About Web Push Notifications

We provide a "Receive notifications" button on our /news/ and /ir/ pages so that you may optionally subscribe to browser Web Push notifications. This feature is enabled only if you click the button and select "Allow" in your browser's permission dialog.

1. Information We Collect and Store

Push endpoint URL (a browser-specific identifier issued by Google FCM or Apple APNs)
Public key (p256dh) and authentication secret (auth) (encryption keys required by the Web Push specification for message encryption)
Browser User-Agent string (used to analyze delivery success rates)
Subscription date and time, last active date and time, and number of delivery failures

We do not collect information that directly identifies an individual, such as name, email address, or IP address.

2. Purpose of Use

To deliver, as Web Push notifications, content matching the topics you have subscribed to (News / IR) when we publish news or make IR disclosures. We do not use this information for marketing or advertising purposes.

3. Provision to Third Parties

Due to the technical nature of notification delivery, push endpoints are routed through the following services. These are the browser-standard push delivery platforms defined by the Web Push specification (IETF RFC 8030) and are not services we can choose at our discretion.

Google Chrome / Microsoft Edge / Firefox (on some OS configurations): Firebase Cloud Messaging (FCM) servers operated by Google LLC (United States)
Safari (macOS / iOS 16.4 or later): Apple Push Notification service (APNs) servers operated by Apple Inc. (United States)

From our servers we transmit only the encrypted notification body and public key information to the services above, and each company relays that notification to your browser. Because we do not retain your name, email address, or similar information when you subscribe, there is no personal information provided to third parties.

4. Unsubscribing

You may unsubscribe at any time by either of the following methods.

Click the "Subscribed to notifications (click to unsubscribe)" button on the page you subscribed from (/news/ or /ir/)
Revoke this site's permission in your browser settings under "Site permissions" and then "Notifications"

When you unsubscribe, your push endpoint information is deleted from our servers at the same time.

5. Retention Period

We retain subscription information until the subscription is canceled. Endpoints that fail repeatedly (for example, because the browser was uninstalled or site permissions were revoked) are deleted by our automated operational processing once the failure count reaches its limit.

Contact Us

Inquiries concerning our Privacy Policy are accepted at the contact point below.