Privacy Policy for General Areas
1. Purpose
The purpose of this policy is to communicate in a comprehensible manner the basic philosophy
and guidelines concerning the protection of the “personal data” that Japan International
Broadcasting Inc. (hereinafter referred to as the “Company,” “we,” “our” and “us”) handles in“general areas”*1 in accordance with our Principles on Personal Data Protection (in Japanese).
*1 The term “general areas” means areas outside of and not in any way pursued for the
purposes of news reporting and writing, or in relation to subscription fees.

2. Name, Address and Representative of Us
Please see the following webpage for our company name, address and representative.
Corporate Profile (jibtv.com)

3. Definitions(1) In this policy, the meanings of the terms “personal information,” “pseudonymously
processed information,” “anonymously processed information,” “information relating to anindividual,” “personal data” and “retained personal data” will be the same as those set forthin the Act on the Protection of Personal Information (hereinafter referred to the as the“APPI”).
(2) In this policy, “personal data” will mean “information about a living individual,” consistingof “personal information,” “pseudonymously processed information,” “anonymously
processed information” and “information relating to an individual” as defined under the
APPI.

4. Application(1) This policy applies to the handling of the personal data we collect in the course of ouroperations in general areas. Any rules we have separately laid down for specific categories
of personal data will also apply. If there is any inconsistency or discrepancy between therules and this policy, the rules will prevail to the extent of such inconsistency or
discrepancy.
(2) The personal data we handle in accordance with this policy will include personal
information, such as addresses, names, telephone numbers and email addresses as wellas personal data about the users of the online services we provide to the generalpublic (hereinafter referred to as the “Online Services”), such as the browsing history of
our websites (hereinafter referred to as the “User Information of the Online Services”).

5. Compliance with Applicable Laws, Guidelines, etc.
We will handle personal data in a proper manner in compliance with the APPI and otherapplicable laws and guidelines, as well as our internal rules concerning the handling of personaldata.

6. Collection of Personal Data
We will collect personal data in general areas by lawful and fair means in various instances,including:(1) When you directly provide personal data to us in writing, via the Internet or other media;(2) When you use our Online Services - We automatically collect your personal data in such
instance; and(3) When we convert publicly available personal data into searchable ones.

7. Notification of the Handling of Personal Data
When we collect any personal information or User Information of the Online Services, we will
provide notice or publicly announce the purposes of use and other matters relating to thehandling of the personal data, at a suitable place and time that is easily recognizable for the
persons concerned and in easy-to-understand language.

8. Viewing History Without Viewer Identification(1) There may be instances when we collect “Viewing History Without Viewer Identification.”*2
Although Viewing History Without Viewer Identification is not personal information, we willhandle it separately from other personal data out of consideration for the privacy of suchinformation which allows us to identify what broadcast programs an individual watched.
(2) We will handle any Viewing History Without Viewer Identification in a careful manner, duly
announce its collection, and give the persons concerned the option to stop or take otheractions against the collection.
*2 “Viewing History Without Viewer Identification” is information that relates to an individual
and is collected during viewing (including online viewing; hereinafter the same applies inthis policy). Viewing History Without Viewer Identification can be used to identify abroadcast program watched by an individual on a specific date and time, butnot the individual.

9. Purposes of Use(1) We use personal data in general areas for specific purposes, including:
(i)

(ii)

Surveys and analysis:(i)-a. To understand and analyze how our broadcast programs are watched(i)-b. To conduct polls and viewer surveys(i)-c. To improve or produce our broadcast programs

Programs and events with live audiences:(ii)-a. To accept applications to view or take part in such programs or events, toconfirm the eligibility of participants, to select viewers and participants by lottery,to send admission passes, to have a communication regarding programviewing or event participation

(iii)

(ii)

-b. To improve or develop programs or events with live audiences(ii)-c. To conduct surveys about programs or events with live audiences

In relation to the Online Services:(iii)-a. To accept applications for services requiring login, identification of persons
concerned, user verification(iii)-b. To improve or develop the Online Services(iii)-c. To stably provide the Online Services(iii)-d. To figure out cause of and solve problems that happened on the Online
Services
(iii)
(iv)

-e. To prevent unauthorized or unlawful use of the Online Services

Business Communications:(iv)-a. To have meetings, exchange information and make other business
communications with our clients, prospective clients and business partners(v)

Other purposes:(v)-a. To conduct studies and research necessary for advances and developments
in broadcasting and broadcasting reception(v)-b. To procure goods and services(v)-c. To accept applications for employment and select and contact applicants(v)-d. To control access to and from facilities managed by us and maintain theirsecurity(v)-e. To respond to inquiries concerning our operations and services(v)-f. To establish, exercise or defend our legal rights

(v)-g. To discharge our legal obligations(2) We will not handle, without the consent of the persons concerned, any personal information
beyond the scope necessary for achieving the specified purposes of use, excluding
instances permitted under the APPI. The Users Information of the Online Services which
does not constitute personal information will also be handled in a proper manneraccordingly.
(3) When analyzing personal data, we will exercise care not to infer the attributes or othercharacteristics of the persons concerned, except we have their individual consent.

10. Provision to Third Parties
We may provide personal data to third parties on your consent as described below.
Categories of personal data
Purposes of disclosure
Recipientsto be disclosed(purposes listed in Section 9)
Responses to our pollsand
surveysSponsors of our(i)-c. To improve or produce

broadcast programs

broadcast programs

Our affiliate company(ies)(iv)-a. To have meetings, exchange
information and make other business
communications with our clients,
prospective clients and business
partners

Opinions on ourbroadcast
programs
Company or organization
Business
with uscommunication

We will ensure any personal data provided to third parties is handled in a proper manner inaccordance with the APPI. Any User Information of the Online Services which does notconstitute personal data will also be handled in a proper manner accordingly.
We may also provide personal data to other third parties by taking necessary and appropriate
measures in accordance with the APPI.

11. Entrustment to Another Entity
When we entrust the handling of personal data to another entity, we will select a contractor that
can handle the personal data in a proper manner and perform necessary supervision to ensurethat it exercises proper security management. We will also perform proper
supervision regarding the User Information of the Online Services which does not constitutepersonal data.

12. Retention Period
We retain your personal data for specific periods we set as consistent with applicable laws orfor as long as it is necessary for the purposes described in Section 9. When the specified period
has expired or we no longer need your personal data, we will delete or anonymize it without
delay in accordance with applicable laws and our established procedures.

13. Opt-out
We allow an individual to opt-out of the automatic collection of user information through our
Online Services or delete the user information by a prescribed method.

14. Security Control Measures(1) We will take necessary and appropriate security control measures for managing personaldata, including the prevention of leakage, loss or damage.
(2) We will, in particular, take the following security control measures for personal data andnon-viewer identifying viewing history (hereinafter referred to as "Personal Data, etc.").
(i)

Establishment of rules concerning the handling of Personal Data, etc.:
Establish internal rules concerning the method of handling Personal Data, etc.,
responsible persons and persons in charge, and their responsibilities, etc.

(ii)

Organizational security control measures:
In addition to appointing persons responsible for the handling of Personal Data,etc., establish a reporting system to the responsible persons for the event that a
violation of the APPI or internal rules or any sign of such a violation is detected.
In addition to conducting regular self-inspections regarding the status of thehandling of Personal Data, etc., the internal audit department conducts audits.

(iii) Human security control measures:
Clarify where responsibility lies for the handling of Personal Data, etc., and provide
employees with necessary training and raise awareness to ensure the security
control of Personal Data, etc., with respect to the proper handling of Personal
Data, etc.
(iv) Physical security control measures:
Take measures to prevent theft or loss of equipment, electronic media, documents,
etc. that process Personal Data, etc., and to ensure that personal
data is not easily identifiable when such equipment, electronic media, etc. arecarried, including when moving within the office.
(v) Technical security control measures:
Control access to Personal Data, etc., including limitation and confirmation of

access authority for Personal Data, etc., and storage of records of such access.
Take necessary measures to prevent unauthorized access to Personal Data, etc.
through telecommunication lines.

15. Requests for Disclosure of Retained Personal Data, etc.
Please contact below for a request for disclosure, rectification including addition and deletion,suspension of use including deletion and suspension of provision to third parties or notificationof purpose of use of retained personal data in accordance with the APPI.
Personal Data Desk, Corporate Planning Division, Japan International Broadcasting Inc.
1-2-20, Shibuya First Tower, Shibuya, Tokyo, Japan
TEL ＋81-3-6805-1084
Open from Mon to Fri(Closed on national holidays, year end and new year holidays)
9:30AM～6:00PM (Closed from 12:00PM to 1:00PM)
You can also click on ‘Contact us’ to reach us at https://www.jibtv.com/en/

16. Point of Contact for Questions and Complaints
We accept questions and complaints concerning our handling of personal data at the contact
point described in Section 15 above.

17. Update of this Policy
We will update this policy as necessary. If we update this policy, we will publicly announce theeffective date and content of the updated policy by publishing it on our website or otherappropriate means.

18. Application of Foreign Laws
If foreign laws apply to handling of personal data held by us, we handle the personal data incompliance with the foreign laws.

19. Additional Information for Residents in European Economic Area, United
Kingdom, and Switzerland
For residents in the European Economic Area (EEA), the United Kingdom (UK), and Switzerland,
we provide additional information in this section in accordance with the General Data Protection
Regulation (“GDPR”). For the UK and Switzerland, please read this as referring to the relevant
provisions of The Data Protection Act 2018 / UK GDPR and the FADP in Switzerland. Terms
used in this section have the same meanings as those in the GDPR unless otherwise stated inthis section. If there is any inconsistency or discrepancy between this section and other sectionsof this policy, this section prevails for residents in the EEA, the UK and Switzerland to the extent
of such inconsistency or discrepancy.
(1)

Controller

We are the controller for the processing of personal data in the meaning of the GDPR.

(2)

Categories of Personal Data We Collet and Use

We collect and use the following categories of personal data in instances described in Section
6 above.
(i)Name, email address, zip code, address, country and phone number(ii)

Company or organization and job title(iii)

Survey participant (“Monitor”) ID(iv)

Responses to our polls and surveys(v)

Opinions on our broadcast programs and the Online Services(vi)

Inquiries and subsequent interactions with us(vii)

Business communications with us(viii) Interaction with the Online Services, including your browsing history, Internet Protocol
address (IP address), location information and device information.

(3)

Lawful Bases

We process your personal data for the purposes described in Section 9 above on the following
lawful bases.
Purpose of Processing Your Data(i) Surveys and analysis:

Lawful Basis
Legitimate interest of us: To understand and(i)-a. To understand and analyze how ouranalyze how our broadcast programs arebroadcast programs are watchedwatched(i)-b. To conduct polls and viewer surveys

Legitimate interest of us: To conduct polls andviewer surveys(i)-c. To improve or produce broadcast

Legitimate interest of us: To improve or produce

programs

broadcast programs(ii) Programs and events with live audiences:

Legitimate interest of us: To hold programs orevents with live audience and carry out

(ii)-a. To accept applications to view or take related operations
part in such programs or events, to confirm
the eligibility of participants, to select viewers
andparticipantsbylottery,tosendadmission passes, to have a communication
regardingprogramviewingor

event

participation(ii)-b. To improve or develop programs orevents with live audiences

Legitimate interest of us: To improve or develop
programs or events with live audiences(ii)-c. To conduct surveys about programs orevents with live audiences

Legitimate interest of us: To improve or develop
programs or events with live audiences(iii) In relation to the Online Services:

Legitimate interest of us: To provide the Online(iii)-a. To accept applications for services Services to appropriate users
requiring login, identification of persons
concerned and user verification(iii)-b. To improve or develop the Online

Legitimate interest of us: To improve or develop

Servicesthe Online Services(iii)-c. To stably

providethe Online

Legitimate interest of us: To stably provide theOnline Services

Services(iii)-d. To figure out cause of and solve Legitimate interest of us: To stably provide theproblems that happened on the Online Online Services
Services(iii)-e. To prevent unauthorized or unlawful Legitimate interest of us: To stably provide theuse of the Online Services

Online Services(iv) Business Communications:(iv)-a.

To

information

have

Legitimate interest of us: To have effective andmeetings,

exchange smoothcommunications

with

our

clients,

and

make

other

business prospective clients and business partners

communications

with

our

clients,prospective clients and business partners(v) Other purposes:

Legitimate interest of us: To improve and(v)-a. To conduct studies and research develop
necessary for advances and developments reception
in broadcasting and broadcasting reception

broadcastingandbroadcastingLegitimate interest of us: To procure goods and(v)-b. To procure goods and services

services(v)-c.

To

acceptemployment

andapplications
selectandfor To take steps prior to entering into an
contact employment contract

applicants(v)-d. To control access to and from facilities
managed by us and maintain their security(v)-e. To respond to inquiries concerning ouroperations and services

Legitimate interest of us: To maintain security of
our facilities

Legitimate interest of us: To respond to inquiries
concerning our operations and services(v)-f. To establish, exercise or defend our Legitimate interest of us: To establish, exercise
legal rights.

or defend our legal rights.

(v)-g. To discharge our legal obligations.

Compliance with legal obligations

Where the lawful basis of the processing is your consent, you can revoke at any time yourconsent with effect for the future. If you would like to revoke your consent, please contact us inaccordance with Paragraph (9) below.

(4) Special Categories of Personal Data
While we usually do not collect special categories of personal data (also known as sensitive
personal data), we may collect special categories of personal data in responses to our surveys
or opinions from viewers. In such instances, we ensure that we process the special categories
of personal data in accordance with the GDPR, including obtaining your consent.
(5) Disclosure to Third Parties
We may disclose certain categories of your personal data to third parties as below.
Categories of personal data
to be disclosed

Purposes of disclosure
Recipients(purposes listed in Section 9)

Responses to our polls

Sponsors of our(i)-c. To improve or produce

and surveys

broadcast programs

broadcast programs

Opinions on our
broadcast programs

Company or

Our affiliate(iv)-a. To have meetings,

organizationcompany(ies)exchange information andBusiness

make

other

business

communication with uscommunications with ourclients, prospective clients andbusiness partners(6) Cross-Border Transfer of Personal Data
Our disclosure of your personal data to our contractors (processors in the meaning of theGDPR) or third parties may constitute cross-border transfer of personal data. When we transfer
your personal data to a country or region other than the EEA member countries or the UK, werely on adequate decisions made by the European Commission or the UK government, use theStandard Contractual Clauses (SCCs) adopted by the European Commission, the International
Data Transfer Agreement (IDTA) or the International Data Transfer Addendum to the European
Commission's SCCs approved by the UK Parliament, or take other necessary measures toprotect your personal data.
(7) Your Rights
You have the following legal rights set out in the GDPR with the processing of your personal
data by us.
Revocation of consent – You can revoke at any time previously given consent to ourprocessing of your personal data.
Right of access - You have the rights to make an inquiry, to review and to request for copiesof your personal data we hold.
Right to rectification - You have the right to request us to correct any of your personal data
we hold which you believe is inaccurate. You also have the right to request us to complete
your personal data we hold which you believe is incomplete.
Right to erasure - You have the right to request that we erase your personal data, undercertain conditions.
Right to restrict processing - You have the right to request that we restrict the processing ofyour personal data, under certain conditions.
Right to object to processing - You have the right to object to our processing of your personaldata, under certain conditions.
If you would like to exercise any of these rights, or if you have any inquiries about your rights,

please contact us in accordance with Paragraph (9) below.
(8) Lodging Complaint with Data Protection Authority
You can lodge complaints about our way of processing your personal data with a data protection
supervisory authority that has a jurisdiction over the region where you reside. Contact
information of data protection supervisory authorities is available at the following URL.
For EEA residents: https://edpb.europa.eu/about-edpb/about-edpb/members_en
For UK residents: https://ico.org.uk/(9) Point of Contact
Please contact our data protection representative for the purposes of GDPR by either of thefollowing methods. Please read the Appendix for how to contact the representative.
Email: datarequest@datarep.com
Webform: www.datarep.com/data-request
Mail: Please mail your inquiry to the representative at the most convenient of the addresses
in the second page of the Appendix.
Established: November 1, 2008,
Revised: November 1, 2023,
October 1, 2024

How to contact
Japan International Broadcasting Inc.
via their Data Protection
Representative

Japan International Broadcasting Inc., which processes the personal data of individuals in the European Union,
European Economic Area and UK, in either the role of ‘data controller’ or ‘data processor’, has appointed
DataRep as its Data Protection Representative for the purposes of GDPR* in the EU/EEA and The Data
Protection Act 2018 / UK GDPR (as amended) in the UK, and FADP** in Switzerland.
If Japan International Broadcasting Inc. has processed or is processing your personal data, you may be entitled
to exercise your rights under GDPR/FADP in respect of that personal data. For more details on the rights you
have in respect of your personal data, please refer to the national Data Protection Authority in your country,
the European Commission in the EU (https://ec.europa.eu/info/law/law-topic/data-protection/dataprotection-eu_en) or the Federal Data Protection and Information Commission in Switzerland(https://www.edoeb.admin.ch/edoeb/en/home.html).
Japan International Broadcasting Inc. takes the protection of personal data seriously, and has appointed
DataRep as their Data Protection Representative in the European Union and Switzerland so that you cancontact them directly in your home country. DataRep has locations in each of the 27 EU countries, the UK, andNorway & Iceland in the European Economic Area (EEA) and Switzerland, so that Japan International
Broadcasting Inc.’s customers can always raise the questions they want with them.
If you want to raise a question to Japan International Broadcasting Inc., or otherwise exercise your rights in
respect of your personal data, you may do so by:•••sending an email to DataRep at datarequest@datarep.com quoting <Japan International BroadcastingInc.> in the subject line,
contacting us on our online webform at www.datarep.com/data-request, or
mailing your inquiry to DataRep at the most convenient of the addresses in the subsequent pages.

PLEASE NOTE: when mailing inquiries, it is ESSENTIAL that you mark your letters for ‘DataRep’ and not ‘Japan
International Broadcasting Inc.’, or your inquiry may not reach us. Please refer clearly to Japan International
Broadcasting Inc. in your correspondence. On receiving your correspondence, Japan International Broadcasting
Inc. is likely to request evidence of your identity, to ensure your personal data and information connected with
it is not provided to anyone other than you.
If you have any concerns over how DataRep will handle the personal data we will require to undertake ourservices, please refer to our privacy notice at www.datarep.com/privacy-policy.

Signed on behalf of the Representative:

Tim Bell, Managing Director* The General Data Protection Regulation, EU 2016/679** Federal Act on Data Protection, AS 2022 491

Please ensure request is addressed to ‘DataRep’ and not Japan International Broadcasting Inc.
Country

Address

Austria

DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria

Belgium

DataRep, Rue des Colonies 11, Brussels, 1000

Bulgaria

DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria

Croatia

DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia

Cyprus

DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus

Czech Republic

DataRep, Platan Office, 28. Října 205/45, Floor 3&4, Ostrava, 70200, Czech Republic

Denmark

DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark

Estonia

DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia

Finland

DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland

France

DataRep, 72 rue de Lessard, Rouen, 76100, France

Germany

DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany

Greece

DataRep, Ippodamias Sq. 8, 4th floor, Piraeus, Attica, Greece

Hungary

DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary

Iceland

DataRep, Kalkofnsvegur 2, 3rd Floor, 101 Reykjavík, Iceland

Ireland

DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland

Italy

DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy

Latvia

DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia

Liechtenstein

DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria

Lithuania

DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania

Luxembourg

DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg

Malta

DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta

Netherlands

DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands

NorwayDataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway

PolandDataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland

Portugal

DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal

Romania

DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania

Slovakia

DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia

Slovenia

DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia

Spain

DataRep, Calle de Manzanares 4, Madrid, 28005, Spain

Sweden

DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE - 211 46, Sweden

Switzerland

DataRep, Leutschenbachstrasse 95, ZURICH, 8050, Switzerland

United Kingdom

DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom