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Personal Information Protection Policy

Created: July 1, 2019
(Last updated on March 31, 2023)
NTT Urban Solutions, Inc.
Akihabara UDX, 4-14-1 Sotokanda, Chiyoda-ku, Tokyo
Hiroshi Tsujigami, President and Chief Executive Officer

NTT URBAN SOLUTIONS, INC. will implement company-wide efforts based on the following policies, including compliance with laws and regulations concerning the protection of personal information.

Obtaining Personal Information

  • 1.We will acquire personal information under the following conditions
  • 2.We will acquire personal information only to the extent necessary to achieve the purpose of use.
  • 3.We will use legal and fair means.
    We will clarify the purpose of use.

Use of Personal Information

We will use the personal information we have acquired about our customers only within the scope of the purpose of use.
When entrusting the handling of personal information to a subcontractor to achieve the purpose of use, we will select a subcontractor that meets appropriate standards, including NTT Urban Development Group companies, and take appropriate measures.

However, personal data may be disclosed or provided to third parties without customer consent in the following cases

  • (1)When required by law
  • (2)When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the customer's consent.
  • (3)When disclosure is especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the customer's consent.
  • (4)When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the customer's consent is likely to impede the execution of such affairs.
    Compliance with Laws and Regulations
    We will comply with laws, regulations, and other rules related to the protection of personal information.

Continuous Improvement

We will continuously review and improve our management system through internal audits, etc., and maintain an appropriate personal information protection system (management system).

Customers' Personal Information in Our Possession

1. Purpose of Use of Retained Personal Data

We will use customers' personal information for the following purposes

  • (1)Target Businesses
    Office building business, residential business, commercial business, consulting, planning, design, maintenance, and upkeep of buildings and electric power facilities, and other related businesses
  • (2)Purpose of use
    Related to the businesses listed in Item 1
    To conduct sales activities such as sending DMs, pamphlets, etc., and solicitation through visits, telephone calls, and e-mails
    To execute contracts and provide information and services
    To provide information on services and products related to after-sales service
    To provide information on surveys of customer satisfaction, etc.
    To analyze customer trends as statistical information and to conduct surveys and analysis for product development, etc.
    To respond to accidents and disasters (including emergency contact) and for safety management

2. Shared use of personal information (starting on December 17, 2019)

We will jointly use personal information to improve the convenience of our customer service.

  • (1)Items of personal information to be shared
    Name, contact information (telephone number, e-mail address, etc.), name of organization (company name, organization name, etc.), title, and other information that can identify a specific individual
  • (2)Scope of joint users
    NTT Urban Solutions Group companies
  • (3)Purposes of use by joint users
    Purposes of use as stated in 1. above
  • (4)Name and address of the person responsible for the management of the personal information to be jointly used
    NTT Urban Solutions, Inc.
    Hiroshi Tsujigami, President and Representative Director
    Akihabara UDX, 4-14-1 Sotokanda, Chiyoda-ku, Tokyo

Please refer to the website of Nippon Telegraph and Telephone Corporation for information on the joint use of information related to our procurement with our business partners.
In addition to the above, NTT Urban Development may share personal information with third parties. In such cases, the following items will be notified in advance or announced on our website, etc.

  • (1)The fact that personal information will be jointly used
  • (2)Items of customer personal information to be jointly used
  • (3)Scope of joint use
  • (4)Purpose of use by the joint users
  • (5)Name and address of the person responsible for the management of the relevant customer personal information, and in the case of a corporation, the name of its representative.

3.Inquiries Concerning Personal Information

To submit inquiries and opinions about client`s personal information, please contact the following representative

[The information desk]
Information Security Management Office, NTT Urban Solutions, Inc.
Address: Akihabara UDX, 4-14-1 Sotokanda, Chiyoda-ku, Tokyo 101-0021
E-mail:personal-information@ntt-us.com
Business hours: 9:00 - 17:30 (excluding Saturdays, Sundays and national holidays)

4. requests for disclosure of personal information

We will respond to requests for notification of the purpose of use of retained personal data concerning a customer, requests for disclosure, correction, addition, deletion, suspension of use, or deletion of personal data, requests for disclosure of records of provision of customer personal information to third parties, and requests for suspension of provision of customer personal information to third parties in accordance with the provisions of the Personal Information Protection Law. Requests for disclosure, etc., will be handled by sending the prescribed form by mail, fax, or e-mail. In either case, please contact the above contact point.

For inquiries from customers regarding their own retained personal data, we will ask them to follow our prescribed procedures for "identification" and then to make the request as prescribed by us. In addition, we ask for your understanding and cooperation in paying a handling fee (1,000 yen [consumption tax included] per case).

5. security control measures

In handling customer personal information, we will take appropriate organizational, personnel, physical, and technical safety control measures.

  • (1)Organizational safety control measures
    We have established an organizational management system that includes the establishment of a management system with committees and managers in charge of each organization, the development of internal rules, the preparation of statements such as control ledgers and process control charts, and further continuous improvement.
  • (2) Personnel safety control measures
    All employees who handle personal customer information, including directors, employees, and temporary staff, are informed and educated about the importance of protecting personal customer information, and are required to sign confidentiality agreements and undergo necessary audits and supervision to ensure the effectiveness of such measures.
  • (3) Physical safety control measures
    Measures are taken to control access to buildings and floors where personal customer information is handled, to prevent theft, to prevent damage to personal customer information due to fire, lightning, etc., and to lock systems and documents when they are taken out, transported, or stored.
  • (4)Technical security control measures
    The Company shall take technical control measures such as access control including authentication, authorization management, control, and recording when accessing personal data, measures against unauthorized software and viruses on systems, measures during transfer, transmission, and reception by means of encryption and clarification of responsibilities, and monitoring of information systems.
  • (5)Understanding the external environment
    When handling customers' personal information in a foreign country, we will take appropriate measures based on our understanding of the systems for the protection of personal information in that foreign country.

6.Anonymous Processed Information

We may create anonymized processed information based on customers' personal information and provide it to third parties. In such cases, the following items shall be publicized on the Company's website, etc.

  • (1)Items of information on individuals included in the anonymized processed information created by the Company
  • (2)Items of information on individuals included in the anonymized processed information provided to the third party
  • (3)Method of providing anonymized processed information to third parties
  • (4) Details of security control measures taken
    In handling anonymized processed information, etc., we will take the security control measures described in Section 5 above. In addition, we will exercise necessary and appropriate supervision over our employees and contractors (including subcontractors, etc.) who handle anonymized processed information, etc. We will also exercise necessary and appropriate supervision over employees and contractors (including subcontractors, etc.) who handle anonymized processed information.

7.Pseudonymous Processed Information

We may create pseudonymized information based on your personal information. However, we will not provide such information to any third party, except as required by law. In handling Processed Pseudonym Information, etc., we will take the security control measures described in Section 5 above. In addition, we will exercise necessary and appropriate supervision over our employees and contractors (including subcontractors, etc.) who handle Processed Pseudonym Information, etc. We will also exercise necessary and appropriate supervision over employees and contractors (including subcontractors, etc.) who handle pseudonymized information.

8. personally identifiable information

We handle personally identifiable information (i.e., information about living individuals that does not fall under the categories of personal information, pseudonymized information, or anonymized processed information, and specifically refers to website browsing history, location information, etc.) as follows. (specifically, website browsing history, location information, etc.) will be handled as follows.

  • (1)When we provide personally identifiable information
    When a third party to which we provide personal information is expected to acquire such information as personal data, except in the cases specified in each item of Article 27, Paragraph 1 of the Personal Information Protection Law, we shall obtain the prior consent of the customer (if the third party is located in a foreign country, in obtaining consent, we shall disclose the name of that foreign country, the system for protecting personal information, the measures taken by that third party, and the name of that third party). (If the third party is located in a foreign country, in obtaining the consent, the consent shall include the fact that the name of the foreign country, the system for the protection of personal information, the measures taken by the third party to protect personal information, and other information that should be of reference to the customer shall be provided to the customer). (2) We will not provide personally identifiable information to a third party without first confirming the name of the third party, its system for protecting personal information, the measures taken by the third party to protect personal information, and any other information that should be of reference to the individual concerned.
  • (2)Cases in which we obtain personally identifiable information as personal data
    When acquiring personally identifiable information as personal data, we shall obtain prior consent from the customer. However, if the person to whom the personal data is to be provided has obtained consent from the customer, this may be substituted for obtaining the customer's prior consent.

9. handling of provision of customer personal information or personally identifiable information to a third party in a foreign country

We will not provide your Personal Information or Personal-Related Information to a third party in a foreign country (excluding countries that have a system for the protection of Personal Information that is recognized as equivalent to that of Japan in terms of protecting the rights and interests of individuals). (1) In the event that we provide your personal information or personally identifiable information to a third party located in a foreign country, we will take the following measures.

  • (1)Provision of customer personal information to a third party in a foreign country
    (i) Method of obtaining consent
    We may provide your personal information to a third party in a foreign country after informing you in advance of the following matters and obtaining your consent.
    Name of the foreign country to which the information will be provided
    The system regarding personal information in the foreign country
    Measures taken by the third party to protect personal information
    (ii) Method through the establishment of a system by a third party located in a foreign country
    In addition to (1) above, we may provide customer personal information to a third party located in a foreign country after taking necessary measures to ensure the continuous implementation of the corresponding measures by the third party located in the foreign country.
  • (2)Provision of personally identifiable information to third parties located in foreign countries
    (i)Method by obtaining consent
    We may provide personal information to a third party in a foreign country in accordance with the provisions of Section 8(1) above.
    (ii) Method by establishing a system for the third party in a foreign country
    We may provide personally identifiable information to a third party in a foreign country after taking necessary measures to ensure the continuous implementation of appropriate measures by the third party in the foreign country.