Privacy Policy of Kao Group Companies in Japan

Kao group companies in Japan (Kao Group Companies) use personal information collected from our consumers and business partners (collectively, Customers) for various purposes, including the development and promotion of better products and services to satisfy our Customers. Kao Group Companies recognize that properly managing and protecting personal information is an important responsibility, and is necessary for preserving the trust of our Customers who provide their personal information to us. To fulfill this responsibility, Kao Group Companies comply with all laws and regulations concerning protection of personal information (Personal Information Protection Laws), and work to properly manage and protect personal information in accordance with this Policy.

1. Use of Personal Information

Kao Group Companies will use Customers personal information only for the purposes disclosed to Customers at the time such information is collected, and within the scope of use posted on Kao Corporations web site (the Scope of Use), and will not use the information for any other purpose.

2. Proper Management and Protection of Personal Information

Kao Group Companies have implemented the following measures to properly manage and protect Customers personal information:

• Establishment of an organization to promote protection of all personal information held by Kao Group Companies as a whole, and appointment of personal information controllers in each Kao Group Company and each division that handles personal information;
• Establishment of internal company rules based on Personal Information Protection Laws and ministry guidelines concerning the handling of personal information;
• Education of employees and others concerned to ensure that they understand the importance of personal information protection and are thoroughly familiar with all relevant rules and guidelines;
• Establishment of a personal information management register and enforcement of appropriate restrictions on access to personal information; and
• Implementation of appropriate and reasonable security measures to prevent unauthorized access to, or leakage, destruction or alteration of, personal information.

3. Provision and Disclosure to Third Parties

Kao Group Companies will not provide or disclose Customers personal information to third parties except in the following cases:

• Prior consent has been obtained from the Customer whose personal information is to be disclosed;
• Disclosure is required by law;
• The information is provided or disclosed to a service provider in compliance with the Scope of Use (please see Article 4 below);
• In cases of shared use among Kao Group Companies; and
• The personal information is provided in connection with business succession due to merger, spin-off or otherwise.

4. Control of Service Providers

Kao Group Companies occasionally consign the handling of personal information to outside service providers. Only service providers who have been confirmed to have the capability of properly handling personal information will be selected. Moreover, Kao Group Companies provide and disclose Customers personal information to such service providers strictly in compliance with the Scope of Use, and require them, by written contract or similar means, to properly handle personal information, and periodically verify their compliance.

5. Response to Confirmation, Revision and Other Requests Concerning Personal Information

When a Customer requests confirmation, revision (correction, addition or deletion), cessation of use or removal of his/her personal information, Kao Group Companies will, upon verifying such Customers identity, comply with the request, unless there is a reasonable basis to refuse.

6. Response to Comments and Complaints Concerning Handling of Personal Information

We will make every effort to deal with any comment or complaint concerning our use of Customers' personal information in a prompt and appropriate manner.

7. Review and Improvement of Personal Information Handling

This Policy may be revised from time to time as necessary to reflect our continuing improvement of personal information protection. Accordingly, this Policy is subject to change without prior notice.

Kao Corporation
Kao Customer Marketing Co., Ltd.
Nivea-Kao Co., Ltd.
Kao Business Associe Co., Ltd.
Kao Professional Services Co., Ltd.
Kao Logistics Co., Ltd.
Goldwell Japan Co., Ltd.
Molton Brown Japan Ltd.
Ehime Sanitary Products Co., Ltd.
Kao Health Insurance
Kao Group Corporate Pension Fund
The Kao Foundation For Arts And Sciences
Kanebo Cosmetics Inc.
Kanebo Cosmetics Sales Inc.
e’quipe LTD.
Lissage Ltd.
Kanebo Cosmillion Ltd.
Joset Ltd.

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