- 1. Handling of personal information
(1) Purpose of the use
Company will acquire personal information by fair and appropriate means and use it within the scope shown in "Purpose of the use" in Table 1 below.
Company will use personal information other than those indicated in "Types of Personal Information" in Table 1 below only after notifying separately the purpose of the use, or obtaining prior consent from the individual concerned.
(2) Management of personal information as data processor
Based on the contract concluded with our business partners, we will collect and process personal information within the scope of Table 2 "Personal Information acquired by the Company through Contracted Services" below. In the event that we become a contractor for the handling of personal information, we will manage the information in accordance with the following requirements:
- Information is collected and processed under the supervision of a data owner
- Edit, change, or delete information in accordance with the instruction from data owner
- Provide reports or other matters arising from the collection and processing of personal information to the data owner
- Retention of personal information obtained in the course of business
- Return the results from information processing to the data owner at the specified date and time based on contractual obligations or delete the information in an irrecoverable condition.
- We manage the safety control measures essential for the information management at all times and take further improvement measures as necessary.
(3) Management of Subcontractors
As shown in Table 1 and Table 2 "Nature of work subject to outsourcing", the Company can outsource some of the operations related to personal information to subcontractors. The Company considers the management of contractors to be of the utmost importance, and when outsourcing operations, the Company selects companies that are recognized as having a sufficient level of protection for personal information, and includes all required obligations and responsibilities in the contract.
In addition, the Company will require the subcontractor to handle personal information in an appropriate manner and will continuously supervise and audit the entity as necessary for the safe management of personal information. The Company will place an order to subcontractor only after obtaining the consignor's consent to re-consignment.
(4) Provision to Third Parties
Company will not provide or disclose personal information to third parties except as stipulated in Law on Protection of Personal Information. When providing or disclosing information, we will comply with laws and respective regulations.
(5) Shared usage
Company can share Personal Information that is indicated as "Yes" in Table 1 "Shared usage" section with Data Artist Inc., Parent of the Company. In such cases, the name, address and representative of the person responsible for the management of such Personal Information are as follows:
Data Artist Inc.
1-8-1 Hisgashi-Shinbashi, Minato-ku, Tokyo, Japan
Satoru Yamamoto /Chief Executive Officer/
In addition to above, Company can also share personal information with its group companies and business partners for the purpose of holding joint seminars, etc.
In case of shared usage in above, the Company will ensure the security management among the joint users.
- 2. Compliance with Laws and Regulations
Company strictly complies with all relevant laws, regulations, contracts, and other rules regarding the protection of personal information.
- 3. Safety control measures
Company takes safety management measures to prevent leaks of personal information by establishing and improving systems for the protection of personal information, providing training and education to employees, controlling access to company buildings, and implementing information security measures. Personal information that is no longer in use will be securely disposed of or erased in an appropriate manner.
If you would like to confirm the details of the security control measures, please contact through information shown in "5. Response to complaints and consultations" below.
- 4. Continuous improvement
Company will continuously review and improve its personal information protection management structure, including this policy, to maintain the appropriate handling and protection level of personal information in accordance with requests from the business partners and changes in social conditions.
- 5. Response to complaints and consultations
We have established following contact and will promptly respond to complaints and consultations regarding the handling of personal information. We will also strive to improve our personal information protection management structure based on complaints and consultations received.
Dentsu Data Artist Mongol LLC
Personal Information office
[Table 1] Personal information obtained by the Company
Types of Personal Information Purpose of use Method of acquisition Nature of work subject to outsourcing (whether or not outsourced) Shared usage (Yes/No) Personal information regarding customers To provide guidance / contact regarding proposals, services, seminars and questionnaires etc. To obtain directly from the individual (business card, e-mail, etc.) Yes (sending out invitations for events and seminars, etc.) Yes Personal information regarding our business partners To provide guidance / contact regarding proposals, services etc. To obtain directly from the individual (business card, e-mail, etc.) No Yes Personal information regarding visitors to our company To connect to person in charge and access control To obtain directly from the individual No No Personal information regarding our employees Various business operations, development of business promotion systems, and human resource policies To obtain directly from the individual Yes (human resource operations, payroll calculation, etc.) Yes Personal information regarding applicants who want to join our company Various operations and communication associated with application, hiring, and selection activities. Employee resume after recruitment and collection of other human resource related information. To obtain directly from the individual Yes (general recruitment related activities such as selection, scheduling, contact, employee resume collection and summary of results etc.) No Personal information regarding personnel who have made an inquiry to our company Response to inquiries, requests and complaints, etc. To obtain directly from the individual (by telephone, e-mail, fax, letter, etc.) No No
[Table 2] Personal Information acquired by the Company through Contracted Services
Types of Personal Information Details of contracted services (Purpose of use) Nature of work subject to outsourcing (whether or not outsourced) Personal information entrusted to us by our business partners for outsourcing Conducting consumer trend research, personalization (provision of information based on personal attributes and behavioral history), system development (users role setting) and other data analysis services as commissioned work Yes (research, analysis, database server operations, system development etc.)
Approved date: August 2022
Dentsu Data Artists Mongol LLC
Unit 1310-1312, 13th floor, Central Tower
Sukhbaatar Square-2, 8th khoroo, Sukhbaatar District
Ulaanbaatar 14200, Mongolia
Amarsanaa Agchbayar /Chief Executive Officer/