Effort to Protect Privacy at Utilization and Application of Customer Information

[Note]
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    Please note that this document is an unofficial translation and was prepared for reference purpose only. The original release is in Japanese.

1. The purpose of this utilization and application policy

Effort to protect privacy at utilization and application of customer information (hereafter “this guide”) is for defining the fundamental matter when SB (SoftBank Corp.) obtains, holds and uses operational data with complying with laws and regulations and privacy policies SB defines.

2. Definition of terms

Meanings of the terms in this guide are listed below.

term meaning
operational data Personal related information that SB obtained in the process of providing telecommunication services or other services. (except information in relation to the secrecy of communication)
contractor Person who has contract with SB regarding subscription of the service provided by SB.
contractor, etc. Contractor and other independent related to the operational data.
anonymity processing Converting operational data to the form not to identify a living individual by the process written in article 5.
anonymized data Data with anonymity processing for the operational data.

3. Handling of operational data

(1) As operational data, SB obtains the location information of the communication terminal (information of the base station's location, information of Wi-Fi location, etc.) that is used by contractor, etc., contractor's information (name, date of birth, address, etc.), IDs like Cookie-based, and other personal related information such as behavior pattern information, then uses for the purpose defined in article 4 after making anonymity processing.

(2) In advance for providing third parties with operational data or anonymized data, in cases where the following article [1] SB performs security measures such as data encryption, etc. to the operational data, and in cases where the following article [2] and [3] SB performs the deciphering protection to the anonymized data using irreversible conversion method by one-way hash function with key, etc.

  • [1]
    In cases where entrusting anonymity processing of operational data
  • [2]
    In cases where entrusting the job such as analyzation of anonymized data
  • [3]
    In cases where providing third parties with anonymized data complying with the article 4 (2)

4. Purpose of use and provision to third parties

(1) SB uses anonymized data for the following purpose.

  • [1]
    Improvement of convenience and quality improvement of SB services, research and development of new services, and various marketing research and analysis for these purposes
  • [2]
    Preparation of statistical data for management analysis and the use of the results of such analysis
  • [3]
    Planning, developing and providing products, services, information, etc. suitable for contractor, etc.
  • [4]
    Guidance on products, services and campaigns of SB and other companies
  • [5]
    Delivery and indication of advertisement or questionnaire survey of SB and other companies
  • [6]
    Other delivery of information that SB determined to be beneficial for contractor, etc.

(2) SB may provide third parties (in cases where [2], limited to the partner company) with anonymized data for the following purposes.

  • [1]
    Public purposes such as disaster recovery, local development
  • [2]
    Planning, developing and providing of products, services, etc. of partner companies (including capital alliance, business tie-up but not limited to them and hereafter the same) or delivery, indication and optimization of advertisement, questionnaire survey, etc. of partner companies, and other delivery of information that SB determined to be beneficial for contractor, etc.
  • [3]
    Other planning and delivering of measures that SB determined to be beneficial for contractor, etc.

5. Anonymity processing procedure of operational data

(1) SB performs the following data processing or combination of these processing, etc. as an anonymity processing procedure.

  • [Deletion]: To delete entries in operational data (name, phone number, etc.) that can be used for directly specifying individuals.
  • [Pseudonymization]: To replace entries to codes or numbers in operational data (date of birth, address, etc.) that can be used for specifying individuals.
  • [Generalization]: To convert, etc. entries in operational data (date of birth, address, etc.) that can be used for specifying individuals. For instance, convert date of birth to age-group, truncate address excluding house number, etc.

(2) Operational data related to the location information, usage duration of the communication terminal, etc. of contractor's communication terminal shall be modified within a certain scope or duration (area, time, etc.) not to be used for specifying individuals such as contractor. After the modification, if the result contains a few individuals, the information consist of a few individuals shall be omitted not to be provided to third parties.

[Note]

6. Control measures of operational data and entrustment of business

(1) SB assigns appropriate information management supervisor (hereafter “the management supervisor”), and supervise the employees, etc. who manage operational data and anonymized data and perform anonymity processing through the management supervisor to perform the security control measures based on this guide and internal regulations.

(2) In cases where the article 3 (2) [1] and [2], SB conclude required contract with above mentioned outsourcing companies to comply with related laws or regulations such as Personal Information Protection Law, Telecommunications Business Act and supervise above mentioned outsourcing companies through the management supervisor to perform the security control measures based on this guide and internal regulations.

7. Procedure of suspension of use

(1) In cases where the contractor, etc. requested SB the suspension of use regarding use of operational data and anonymized data related to the contractor, etc. based on the procedure of this guide, SB shall suspend to use of operational data and anonymized data related to the contractor, etc. and delete the data within the scope that can be treated by SB.

(2) In cases where the contractor, etc. who made the above mentioned suspension procedure complied with the previous written (1) re-agreed the use of operational data and anonymized data by SB, SB uses the operational data and anonymized data that is related to the contractor, etc. within the scope of purpose of use defined in this guide.

(3) The requirements and procedures of suspension, etc. on (1) and the cancelation procedure of suspension on (2) is defined by each service.

[Note]

(4) It takes days to complete the procedure from when SB accepts the request for the suspension procedure of (1) or cancellation procedure of (2).