Privacy Policy

Enacted on April 1^st, 2005
Last Revised on July 1^st, 2023

NTT Communications Corporation

Katsushige Kojima
President & CEO
Representative Member of the Board of the Company

NTT Communications Corporation ("Company") is providing cloud, network, security and consulting services to enhance creation of new values and solving social issues from the global perspective. In various phases of these businesses of Company, we handle personal information, including Specific Personal Information, ("Personal Information"). We consider that ensuring the proper handling and protection of Personal Information in all of our business activities is our responsibility to the society. Personal Information provided by the customer to Company will be managed by CSO, who is responsible for controlling Personal Information.

Appropriate Handling

Company will comply with laws, guidelines and standards concerning the protection of Personal Information, and take all necessary measures to protect the Personal Information of the customer.
Obtainning

Company will properly obtain Personal Information on the customer verbally, in writing, through electronic records, audio recording or video-taping or by other means. (In addition to Company directly obtaining Personal Information from the customer, Company will also obtain Personal Information indirectly from sources other than the customer.)
Please note that Company may record telephone conversations with the customer, in order to ensure accuracy in receiving orders, opinions and requests from the customer and to enhance future services.
The purposes of using Personal Information
Company, as NTT DOCOMO Group, will abide by the spirit of the principles of action set forth in the NTT DOCOMO Personal Data Charter and will utilize Personal Information properly within the following purposes.

(Personal Information registered by Company)
- with respect to the Company’s services, a) for confirmation of the individual’s identity, b) for billing purposes, c) for notification purposes in connection with changes of charges and service conditions, installation dates, service suspension, and contract termination, and d) for any other purpose necessary for the provisioning of the services;
- with respect to the Company’s services, a) to conduct sales promotions, b) to offer proposals, c) to provide consultation, d) to conduct customer surveys, and e) to send promotional materials or gifts, etc. by means including the use of telephone, e-mail and postal services;
- for the purpose of improving Company’s services and for developing new services;
- to answer any questions or provide consultation as may be requested by the customer.
- to analyze the acquired information such as behavior history. In addition, based on the analysis and analysis results, we provide guidance and advertisement regarding our services according to taste.
- to provide information on various campaigns and other sales promotion measures and events of business partners and affiliated stores.
- to display and distribute advertisements of other companies suitable for customers.
(Other Personal Information)
- for purposes of improving Company’s services and for developing new services;
- to answer any questions or provide consultation as may be requested by the customer;
- with respect to the Company’s services, a) to conduct sales promotions b) to offer proposals c) to provide consultation , d) to conduct customer surveys and e) to send promotional materials or gifts, etc. by means including the use of telephone, email and postal services
- to analyze the acquired information such as behavior history. In addition, based on the analysis and analysis results, we provide guidance and advertisement regarding our services according to taste.
- to provide information on various campaigns and other sales promotion measures and events of business partners and affiliated stores.
- to display and distribute advertisements of other companies suitable for customers.
In addition to the purposes for using Personal Information listed above, Company may from time to time specify other use purposes through provisioning of services and customer surveys.

Furthermore, Company may use Personal Information within the above scope of use, even after the telecommunications services contract or other contracts have been terminated with the customer.
Security Control Action

To manage Personal Information properly and avoid unintended use, Company will protect Personal Information provided by the customer through continuous efforts to:

1)Basic policy
In order to ensure the proper handling of Personal Information, we establish basic policies regarding "compliance with relevant laws and guidelines" and "contact point for inquiries" in our internal rules.

2)Establishment of the rule of the handling of Personal Information
We establish the internal rules of Personal Information regarding the handling method of Personal Information, the person in charge and their responsibilities.

3)Institutional security control measures
We appoint a person in charge of handling Personal Information and clearly define the responsibility and authority of employees who handle Personal Information. In addition to supervising employees, we establish a system for reporting and communicating to the person in charge when we become aware of facts or signs that violate laws and internal rules. We carry out regular self-inspections and appropriate audits regarding the handling status of Personal Information.

4)Human security control measures
We provide regular education and training to employees regarding the handling of Personal Information.

5)Physical security control measures
In areas where Personal Information is handled, we manage the entry and exit of employees and take measures to prevent unauthorized persons from viewing Personal Information. We implement restrictions on the means of taking out Personal Information (such as prohibition of recording on external recording media in principle).

6)Technological security control measures
We implement access control to limit the scope of the person in charge and the Personal Information database we handle. We introduce a mechanism to protect the information system that handles Personal Information from unauthorized access or software from the outside.

7)Understanding the external environment
We implement safety management measures after understanding the system regarding the protection of Personal Information in foreign countries where Personal Information is stored.
Disclosure and Provision of Personal Information

1)Company may provide a customer’s information to such a person who answers a Company’s call as a customer’s family, to the extent reasonably necessary to achieve the purposes as identified in Section 3 of this Privacy Policy. We may provide the following information if necessary.
a Customer’s name and address for identification
Contractual relationship with Company for the Company’s services
Outline of other requirements

We only accept inquiries from customer’s family members as well as a customer, and we do not accept inquiries from their friends living together. Whether a person is a family member or not will be determined based on the request, however we may ask a customer's name and address.

2) Company may disclose and provide Personal Information to its subcontractors to the extent reasonably necessary to achieve the purposes as identified in Section 3 of this Privacy Policy.

3) Company will disclose and provide Personal Information to NTT DOCOMO, INC.(“NTT DOCOMO”) and NTT Finance Corporation ("NTT Finance") to the extent reasonably necessary for NTT DOCOMO and NTT Finance to collect claims arising out from telecommunications service provided by Company, on the condition that such claims will be comprehensively transferred and assigned from Company to NTT DOCOMO or NTT Finance in accordance with each service agreement entered into between customers and Company, as well as assignment agreement entered into between Company and NTT DOCOMO or Company and NTT Finance.

4) In respect of 1) and 2) above, subject to the Personal Information Protection Law, the Telecommunications Business Act, and other applicable laws and regulations, Company will verify that each subcontractor and/or NTT Finance to which Personal Information is to be disclosed and provided from Company has implemented the measures necessary to protect Personal Information, and take all appropriate and necessary actions including but not limited to entering into appropriate agreement with such subcontractor and/or NTT Finance to protect Personal Information.

5) Notwithstanding anything to the contrary stated above, Company may disclose and provide Personal Information to government authorities, including but not limited to any court or police if required or requested properly pursuant to any applicable law or order.
Joint use of Personal Information with group companies

Company may jointly use Personal Information with its subsidiaries for the purpose of improving customer satisfaction toward our services in accordance with and to the extent as described below.

1) The items of Personal Information to be used jointly
Name of an individual, contact information (telephone number, e-mail address, etc.) assigned by a corporation to its employee individual, name of the corporation/department, and any other information which can identify specific individual.

2) Joint users
Company and its group companies

3) The purpose for which the Personal Information is used by the joint users
As identified in Section 3 of this Privacy Policy

4) The name, address, and CEO of the business operator responsible for the management of the Personal Information
NTT Communications Corporation
https://www.ntt.com/en/about-us/company-profile.html

5) The means or method of obtaining Personal Information
Electronic or Electromagnetic Means, etc.
Joint use of Personal Information with NTT DOCOMO

Company may jointly use Personal Information with NTT DOCOMO for the purpose of improving customer satisfaction toward our services in accordance with and to the extent as described below.The Joint Use of Personal Information was launched at the timing ofwith the launch of DOCOMO Business generally for the following types of Personal Information and purposes of use.

1) The items of Personal Information to be used jointly
Personal Information obtained by our company through the provision of services, etc., including the following information
- Basic Information
  Name, phone number, email address, customer identifier, attributes, and contact information. Examples include gender, age, family structure, and address.
- Corporate User Information
  Information about the customer's workplace and employee attributes. Examples include company and organization names, company addresses, business types, department names, job titles, email addresses, and other information that can identify specific individuals.
- Usage information
  Information about contracts and usage of various services. Examples include subscription status and usage history of Company services, information about posted articles, images, and videos, information about activities when using the Internet, information about activities when using applications, information about the names, locations, and payments of purchased services and products, and information about survey responses.
- Location information
  Information indicating the location of the holder of the mobile device. Examples include the device's GPS function, Wi-Fi or other near-field communication technology, and location information measured by a mobile base station (including, but not limited to, location registration information).
  Company and NTT DOCOMO use location information only to the extent permitted by law.
- Medical health information
  Medical and health-related information collected when customers using Company services. Examples include information on medical examinations and other examinations by doctors, information on health guidance, medical treatment and prescription by doctors, and the height, weight, and amount of activity of customers.
2) Joint users
Company and NTT DOCOMO

3) The purpose for which the Personal Information is used by the joint users
- To provide services and products, as well as to communicate with customers and provide information necessary for them.
  Examples include:
  To provide various services and functions based on the contract and to implement the contract
  For identity verification or family verification at the time of application, use of services, etc.
  To confirm that your subscription requirements have been met
  For credit judgment and post-credit management
  For calculation and billing of billing amount (including collection agency portion) and management of points
  For the disposal of receivables and rights acquired from customers, posting of collateral, and other transactions
  For notification of age information when using the services of content providers that support the age determination function.
  For notification on necessary information regarding contracts.
  For the arrangement, shipment and after-sales service of the item you ordered.
  For contacting customers in the event of unauthorized contracts, unauthorized use, or non-payment
  To respond to opinions, requests, inquiries, etc. regarding the service
- To propose services and products, and to communicate and inform customers about them
  Examples include:
  To propose a billing plan that is suitable for the customer who requested a billing consultation
  For information about campaigns and other sales promotion measures and events held by our company, affiliated companies and affiliated stores
  Lottery of winners for various campaigns and sales promotion measures, sending of giveaways and gratuities, etc.
  For information on recommended products, services, content, etc.
  To display and deliver customer-appropriate advertising from our company and other companies
- Maintenance and anti-fraud measures necessary for the reliable and stable provision of services and products, etc.
  Examples include:
  For operation and maintenance of network application systems, etc.
  Preventing and responding to failures, malfunctions, and accidents of products, services, networks, applications, systems, etc.
  To prevent the occurrence of unauthorized contracts, unauthorized use and non-payment, and to take measures in the event of such occurrence.
- Planning, development, and improvement of services and products, as well as various surveys and analyses
  Examples include:
  For planning and development of new products, services, and technologies
  To improve service quality and customer service
  For research and analysis of sales and usage status
  To conduct a survey on awareness and actual conditions regarding products and services, various campaigns, and other sales promotion measures (not limited to our company, affiliated companies, franchised stores, etc.)
  For research, analysis, and measurement of the effects of various campaigns and other sales promotion measures
  To conduct a questionnaire survey
4) The name, address, and CEO of the business operator responsible for the management of the Personal Information
NTT Communications Corporation
https://www.ntt.com/en/about-us/company-profile.html

5) The means or method of obtaining Personal Information
Electronic or Electromagnetic Means, etc.
Joint use of information relating to procurement business partners

NTT Group companies may share and jointly use personal information and other information of business partners collected through NTT Group companies as master data in the systems of NTT Group for the purpose of effective management of information relating to business partners etc., and to effectively and appropriately sign contracts, execution of contracts and payments for procurement-related transactions.

1) The items of personal information to be used jointly

[In case of cooperate business partners]
- Company name, business address, name of the person in charge, and contact information (telephone number and e-mail address), bank transfer information of procurement-related transactions
[In case of sole proprietor business partners]
- Company name of the solo proprietorship (including the name of the owner), contact details (phone number, email address), address, bank account details of procurement-related transactions
*"Business partners" includes those who have provided a quotation for the purpose of initiating business but did not reach to an agreement

2) Joint users
Company, NTT Holdings(Nippon Telephone and Telegraph Corporation), and its group companies
(Group companies:https://group.ntt/en/protection/pdf/partners_procure.pdf)

3) The purpose for which the Personal Information is used by the joint users
In order to effectively and appropriately conclude contracts, execute contracts and make payments etc., for procurement-related transactions

4) The name, address, and CEO of the business operator responsible for the management of the Personal Information
Nippon Telephone and Telegraph Corporation
<https://group.ntt/en/corporate/overview/>

5) The means or method of obtaining Personal Information
Collecting data by paper, and electronic and electromagnetic methods, etc.

Distribution of advertisement and other content through advertising distribution platforms

Company uses the services of Google, Yahoo, and Facebook ("Providers") to advertise services that are more suitable for the customers.
Company advertisements are placed on various sites on the Internet by Providers. Providers use browsing history, data provided by Company, and other data to deliver advertisements that match the customer’s interests. For the purpose of distributing advertisements, Company provides Providers located in the United States of America with a hashed data of a portion of personal information and the advertising identifier (AAID, IDFA) associated with the customer . Providers have taken all measures to comply with the eight principles of the OECD Privacy Guidelines.
For information on the protection of personal information in the United States of America (California), please visit:

The hashed data is deleted after it is checked against the user information of Providers. For the items of information to be provided to Providers, see the table below.
If you wish to stop the distribution of advertisements using a service provided by Providers, please refer to the opt-out page of Providers and proceed to disable the service.

Google	Google Customer Match　（Country or zip code is not hashed.） https://support.google.com/google-ads/answer/6334160?hl=ja&authuser=1&ref_topic=6296507 Opt-out page https://support.google.com/campaignmanager/answer/2893966?hl=ja
Yahoo	Yahoo! Display ads https://ads-help.yahoo.co.jp/yahooads/display/articledetail?lan=ja&aid=69234 Opt-out page https://btoptout.yahoo.co.jp/optout/index.html
Facebook	Facebook Custom Audience https://www.facebook.com/business/help/112061095610075 Opt-out page https://www.facebook.com/about/ads

	Google Customer Match	Yahoo! Display ads	Meta Custom Audience
E-mail address	〇	〇	〇
Phone number	〇		〇
First name	〇		〇
Last name	〇		〇
Country	〇		〇
Zip code	〇		〇
Mobile device ID	〇	〇	〇
Municipalities			〇
Prefectures			〇
Date of Birth			〇
Birthday			〇
Age			〇
Gender			〇
Facebook application ID、Facebook page users ID			〇

Helpdesk Services

If you wish to request disclosures (disclosure, amendment, addition, deletion, suspension of usage, or suspension of provision to third parties), complaints and comments of Personal Information provided to us, please see the following website. Company will respond to your request in a timely manner. Please note that with respect to customer requests for disclosure of Personal Information, 1,000 yen (1,100 yen including tax) per subscriber line will be charged as a processing fee. Additional processing fees may be charged if disclosure is requested in an irregular way. For any inquiries regarding protection of Personal Information please see the following website.

(Inquiries via the website)
To process your request, please fill out the inquiry form under "Inquiries on Disclosure of Personal Information via the website" on the privacy policy page on our website (URL:https://www.ntt.com/about-us/hp/privacy.html * In Japanese only)
Qualified Personal Information Protection Organization

Company is a member of Zaidan Hojin Nihon Data Tsushin Kyokai (Japan Data Communications Association), an authorized organization to protect Personal Information. Any thoughts or comments regarding the way Company manages Personal Information can be sent to the contact below.

Denki Tsushin Kojin Joho Hogo Suishin Center (Telecommunications Personal Information Protection Promotion Center)(in Japanese only)
Revision of this Privacy Policy

Company may revise this Privacy Policy a) to protect Personal Information of the customer, b) to follow the amendment of laws, rules and guidelines. Company will announce the revision of this Privacy Policy via Company’s official website.

Company is the certificated business entity for the right to use of Privacy Mark, representing a company that maintains systems for the appropriate handling of personal information.
Company profile
https://www.ntt.com/en/about-us/company-profile.html

Supplementary Provisions (Act No. 00935801of June 24, 2022)
(Implementation Date)
This revised Privacy Policy will be applied from July 1, 2022.
(Transitional Measures)
The following usage purposes apply only to the Services transferred from NTT DOCOMO on July 1, 2022 and the Personal Information of customers acquired after July 1, 2022.

To provide information on various campaigns and other sales promotion measures and events of business partners and affiliated stores.
To display and distribute advertisements of other companies suitable for customers.

Supplementary Provisions (Act No. 01038299 of March 23, 2023)
(Implementation Date)
This revised Privacy Policy will be applied from April 1, 2023.

Supplementary Provisions (Act No. 000400000201-01 of June 29, 2023)
(Implementation Date)
This revised Privacy Policy will be applied from July 1, 2023.

Click here for the information handling policy regarding Specified User Information based on the Telecommunications Business Act.