Privacy Policy

1. Policy Objective:

Adglobal360 India Pvt Ltd. (“Adglobal”) undertakes marketing activities, proposes solutions (both technical and non-technical in nature) and develops and implements those solutions for its clients in order to increase their life value. The basis for all activities is Hakuhodo group’s Sei-katsu-sha Insight and Partnership corporate philosophies. In striving to consistently devise the best marketing proposals, we believe the most important consideration is to know sei-katsu-sha, or “living consumers,” deeply to respond to their needs. Thus sei-katsu-sha data is essential to our corporate activities. We have long recognized the importance to our corporate activities of managing personal data, one source of sei-katsu-sha data. With society's recent interest in the protection of personal data, we have undertaken to clearly express our personal data handling policies internally and externally and make a commitment to ensuring strict adherence to these policies by all executives and employees.

2. Basic policy on handling personal data:-

Adglobal sometimes handles personal data that it collects independently; personal data provided by client companies, media companies and affiliated companies; and personal data about our executives and employees and those of our affiliated companies. We handle such personal data appropriately in line with applicable laws, industry standards and Adglobal's own internal regulations.

3. Personal data utilized by Adglobal:-

Adglobal in principle utilizes statistically processed personal data on need basis. However from time to time, Adglobal also utilizes data such as the following that could potentially identify individuals:

• Data collected from questionnaire surveys, group interviews or other R&D and research activities that could potentially identify individuals.
• Data collected from entrants in promotional campaigns consigned to Adglobal by client companies or media owners that could potentially identify individuals.
• Personal data from Internet-based membership organizations operated by Adglobal.
• Data otherwise collected in conducting our business that could potentially identify individuals.
• Personal data about executives and employees of Adglobal, our affiliates and companies that collaborate with Adglobal.

4. Basic principles for personal data protection

Adglobal has established and adheres to the following basic principles with regards to handling of personal data.

• Adherence to related laws and regulations
  Adglobal observes all ordinances, regulations, agreements, and internal regulations related to personal information.
• Appropriate acquisition and utilization of personal data from individuals
  When acquiring personal information from individuals, Adglobal first explains how the data will be utilized and whether the information may be provided to a third party, as well as how the data will be utilized in that case. Furthermore, should there be any change to the purpose of the data or the entities to which it may be provided, we inform the individual concerned. In case we do not obtain their agreement, utilization of the data is restricted to that which has been agreed to. We comply with all requests not to utilize any or all of the data. We also strive to maintain the accuracy of the data, and comply with all requests to disclose, amend or delete the data.
• Confirmation of the appropriateness of personal data obtained in business dealings and its appropriate utilization and security control
  Adglobal confirms how personal data from client companies or media owners obtained in conducting our business was collected and the scope of use consented to. We utilize the data appropriately in line with the requirements of the business affiliate and our own internal regulations.
• Executive and employee education
  Adglobal promotes appropriate utilization of personal data and adherence to all regulations and rules through regularly conducted educational programs for executives and employees that convey the importance of personal data protection, legal requirements, management systems, regulations for handling the data and measures in case of breach of regulations.
• Establishment of data management systems
  To protect personal data, Adglobal has defined internal management and responsibility systems, and selected staff responsible for the management of personal information.
• Clarification of information handling
  Adglobal has established regulations regarding the safe and appropriate handling of personal data including viewing, utilization, storage, destruction and return of such data, and abides by these through the offices of staff responsible for the management of personal information.
• Measures against unauthorized access
  Adglobal has built appropriate data systems, data management systems and other measures to prevent theft, loss, manipulation, or destruction of personal data due to unauthorized access.
• Ensuring safety of outsourced information processing
  When outsourcing personal data processing, Adglobal selects contractors it has confirmed as able to ensure safe management of information in line with our regulations and provides appropriate supervision of these contractors.
• Establishment of immediate response system in case of problems
  In the unlikely event a problem arises, Adglobal has established structures to detect the problem, make appropriate decisions, and take appropriate action quickly and accurately.
• On-going improvement
  Adglobal makes efforts to constantly improve by monitoring personal information management and responding to changes in the external environment.