Handling of Customers' Personal Information

1. Definitions

The “Personal Information” in this Announcement refers to information with which a specific individual may be identified or information which includes an individual identification code. Furthermore, the “Person-Related Information” in this Announcement refers to information related to a living individual that does not fall within Personal Information.

The following are examples of the Personal Information and the Person-Related Information that each Asahi Group Company obtains:

Information That Falls within Personal Information:

The Customer’s name, facial images, and address/telephone numbers/e-mail address/date of birth, combined with their name, and the like.

Information that Falls within Person-Related Information in Principle But Falls within Personal Information When Each Asahi Group Company Manages Such Information in a Way That It May Easily Be Collated with Personal Information:

• Cookie data and any information collected using Cookie-like technology;
• Advertising identifiers^*1, including IDFA and Google Play Advertising ID;
• Identifiers on websites;
• URLs of the websites the Customer browses and the time at which the Customer browses such websites;
• Information related to devices or browsers (including IP addresses, types of OS and browser) that the Customer used to browse the websites;
• Referrer information (URL of the last external website that the Customer browsed immediately before the applicable websites); and
• Information from the websites or mobile apps, such as browsing history, searching history, and purchase history, and attribute information, preferences etc., linked to various identifiers, such as cookie IDs and advertising identifiers.

• 1 An advertising identifier here refers to an identifier for the distribution of advertisements assigned to each device, etc., in an environment where cookies are not stored, such as mobile apps. An IDFA is an identifier for the distribution of advertisements assigned for iOS, while a Google Play Advertising ID is an identifier for the distribution of advertisements assigned for Android OS.

Hereinafter, the Personal Information and the Person-Related Information are collectively referred to as the “Personal Information & Person-Related Information”

2. Announcement of Purposes of Use When Obtaining Personal Information & Person-Related Information

(1) Purposes of Use When Obtaining Personal Information & Person-Related Information

Each Asahi Group Company obtains the Customer’s Personal Information & Person-Related Information for the following purposes of use, unless it falls under an exception permitted by the Act.

(a) Purposes of Use

• To hold lotteries (including investigations in the case of double or multiple wins) and ship prizes for campaigns, prize contests, etc.;
• To inform the Customer of, to make reservations for and to report contests, events, exhibitions, seminars, parties, etc., and to address various needs regarding the management and operation of the same;
• To ship ordered goods, to provide services that are applied for, and to provide after-sales services thereof;
• To inform the Customer of, and distribute advertisements of, an Asahi Group Company’s goods and services;
• To survey and analyze the Customer’s preferences, and the like, by using the Customer’s Personal Information & Person-Related Information retained by an Asahi Group Company, such as the Customer’s browsing history, purchase history, usage status of apps and results of questionnaires on the websites (including the usage of the Customer’s Person-Related Information, such as browsing history on another website, that was obtained from other Asahi Group Companies or from Asahi Group Company’s business partners, upon collating the same with the Customer’s Personal Information & Person-Related Information); and to conduct advertising distribution, etc., according to the results thereof;
• For the business activities incidental to payment transactions in respect of the sale of goods or the provision of services;
• To register in, distribute, and make confirmation on, e-mail distribution services and the services on the Asahi Group’s websites (including websites for mobile devices) or on the mobile apps provided by the Asahi Group, and to address various needs with regard to such services;
• To verify the Customers when they are logging onto any content using Asahi Web Service;
• To confirm the contents of and address inquiries or opinions (please note that we are recording the contents thereof for this purpose);
• To conduct questionnaire surveys for the business activities and services of each Asahi Group Company and to provide thank-you gifts and the like;
• To plan, develop and provide goods and services.;
• To make business-related or trading-related contact with business partners (hereinafter, including companies which are potential business partners), to attend to and to manage (including credit management of) the business partners;
• To inform the business partners about goods/services and to propose the same to the business partners;
• To manage the facilities, including factories; to attend to Customers when they are visiting such facilities; and to provide information on the use thereof;
• To perform the subcontracted business activities when an Asahi Group Company is subcontracted to handle the Personal Information.
• To seamlessly provide appropriate information when the Customer uses services with multiple browsers or in multiple environments;
• To resolve any issues that occur in website management, session management or in the servers;
• To manage and inform shareholders under the Companies Act, and the like;
• To provide information on recruiting, and to screen for recruiting;
• To address the labor-related laws and regulations, and to inform and make contact about alumni meetings;
• To create statistical data for the analysis of company management and to use the results of such analysis; and
• For public purposes, including taking precautions for natural disasters and promoting local development.

(b) Other Purposes of Use

In the event that an Asahi Group Company separately notifies or announces to the Customer other purposes of use when obtaining the Personal Information & Person-Related Information in addition to the purposes of use listed above, the Customer’s Personal Information & Person-Related Information will also be used for such additional purposes of use.

(c) Association of Information

The Personal Information registered by the Customer may be associated with other information managed by an Asahi Group Company. For instance, the Personal Information may be collated with the management system for periodicals (such as e-mail newsletters) issued by an Asahi Group Company to determine whether it is registered on the websites.

(d) Creating Statistical Materials

All Personal Information may be used for creating statistical materials (including announcements thereof) in which the items pertaining to common factors are aggregated into each category, upon deleting items through which a specific individual may be identified.

(e) Exceptions under the Act

The exceptions permitted by the Act are as follows:

• Where notifying or announcing the purposes of use to the subject individual may cause harm to the life, body or property, or other rights and interests of the subject individual or any third party;
• Where notifying or announcing the purposes of use to the subject individual may cause harm to the rights or legitimate interests of an Asahi Group Company;
• Where it is necessary to cooperate with the national authorities or local public entities performing administrative work prescribed by the laws and regulations, and where notifying or announcing the purposes of use to the subject individual may impede such performance of the administrative work; and
• Where the purposes of use are acknowledged to be clear in the light of the situation under which the Personal Information is obtained.

(2) Shared Use

“Shared Use” is a regime permitted by the Act under which the Customer’s Personal Information may be shared with specific people and used, subject to notifying the Customer of prescribed matters in advance.

The Asahi Group may put the Customer’s Personal Information into shared use as follows, but it will not put the Customer’s Personal Information into shared use beyond the scope necessary to achieve such purposes of use.

Please also note that, if the Asahi Group puts the Customer’s Personal Information into shared use with any third party outside of the following cases, it will separately, clearly state to the effect of putting such Personal Information into shared use when obtaining such Personal Information.

(a) Items of Personal Information Put into Shared Use

Items falling within the Personal Information listed in “1. Definitions.”

(b) Scope of Shared Users

Asahi Group Japan Ltd. and its subsidiaries within Japan (such as Asahi Breweries, Ltd., Asahi Soft Drinks Co., Ltd., Calpis Co., Ltd., Asahi Group Foods, Ltd., Asahi Food Create, Ltd., and Enoteca Co., Ltd.), as well as Asahi Group Holdings, Ltd., Asahi Quality & Innovations, Ltd., Asahi Biocycle Co., Ltd., and Asahi Group Arts Foundation and Asahi Group Foundation (but excluding Asahi Logi Ltd.).

(c) Purposes of Use for Shared Users

The Personal Information will be put into shared use for the purposes listed in “2. Announcement of Purposes of Use When Obtaining the Personal Information & Person-Related Information – (1) – (a) Purposes of Use When Obtaining the Personal Information & Person-Related Information”. Please note that the Personal Information may be used for creating statistical materials (including announcements thereof) in which the items pertaining to common factors are aggregated into each category, upon deleting items of Personal Information through which a specific individual may be identified.

(d) Name and Address of Company and Representative Thereof that is Responsible for Management of Personal Information for Shared Use

Asahi Group Japan Ltd.
1-23-1 Azumabashi, Sumida-ku, Tokyo
Kenji HAMADA, President and Representative Director, CEO

3. Provision of Personal Information to Third Parties

In the event that an Asahi Group Company provides the Customer’s Personal Information to any third party, it will abide by the following provisions.

No Asahi Group Company will ever provide the Customer’s Personal Information to any third party other than subcontractors without obtaining the Customer’s consent in advance, unless such provision falls under an exception permitted by the Act.

The exceptions permitted by the Act are as follows:

• Where it is permitted pursuant to any laws and regulations;
• Where it is necessary for the protection of the life, body and property of a person (including juridical persons) and it is difficult to obtain the subject individual’s consent;
• Where it is particularly necessary for the improvement of public sanitation or the promotion of the healthy development of a child and it is difficult to obtain the subject individual’s consent; and
• Where it is necessary to cooperate with national authorities or local public entities or those who are subcontracted thereby to perform administrative work prescribed by the laws and regulations, and where obtaining the subject individual’s consent may impede such performance of the administrative work.

Furthermore, some websites provide services such as chat rooms (conversations), forums (conference rooms), online bulletin boards, newsgroups, exchanging of e-mails, etc. Please be fully aware that the information voluntarily disclosed by the Customer on these services becomes public information.

4. Obtaining Person-Related Information

An Asahi Group Company may obtain Person-Related Information obtained regarding the Customers and falling within Items 1 through 7 in “1. Definitions” from other Asahi Group Companies and business partners (hereinafter; including, without limitation, DMP providers, other advertising companies, research and analysis companies, media providers, and database managing companies, etc.), and may use such Person-Related Information for the purposes listed in “2. Announcement of Purposes of Use When Obtaining the Personal Information & Person-Related Information - (1) – (a) Purposes of Use When Obtaining the Personal Information & Person-Related Information,” upon collating the same with the Personal Information regarding the Customers.

5. Procedures in Response to Requests for Disclosure

In the event that the subject individual or their agent make a request, regarding their Personal Information, for: (i) notification of the purposes of use; (ii) disclosure; (iii) modification/addition/deletion of the content; (iv) suspension of the use or deletion; or (v) suspension of the provision to any third party (collectively, “Disclosure”), each Asahi Group Company shall appropriately address such requests in accordance with the Act.

For the avoidance of doubt, any Personal Information in a business activity that each Asahi Group Company is subcontracted to and is not authorized for Disclosure will not be subject to a request for Disclosure.

6. Deletion of Personal Information on Websites

The Asahi Group’s websites may provide a mechanism that allows the Customer themselves to browse, modify, add or delete their registered Personal Information on the websites; provided, however, that the deletion, etc. of the Personal Information may potentially disable the provision of various services on the websites.

In the event that the Customer applies for the deletion of such registered information on the website, such information will be deleted after a certain period of time has elapsed, unless such information needs to be retained under the laws and regulations, etc.

Please be informed that it may take some time for such procedures to be reflected, depending on the time and day of such procedures. The Asahi Group apologizes for any inconvenience caused and thanks you in advance for your understanding.

If you have any questions on the method of the deletion, etc. of the registered information on the websites, please inquire with the administrative office of the Asahi Group Website.

7. Handling of Cookies

Cookies and similar technologies (collectively, “Cookies”) are being used, and the information collected through Cookies is being used on the Asahi Group’s websites. For details regarding the Cookies used by the Asahi Group, please see “Use of Cookies."

8. System of and Measures Taken for Handling Personal Information

Each Asahi Group Company is taking necessary and appropriate measures and exercising necessary and appropriate supervision over its employees in order to ensure the security management of the Personal Information against risks such as the divulgence, loss and detriment of the Personal Information. Furthermore, in the event of subcontracting all or part of the handling of the Personal Information, each Asahi Group Company exercises necessary and appropriate supervision in order to ensure the security management of the Personal Information at such subcontractor.

For the information of the security management measures taken in the Asahi Group, please inquire with the customer service contact points listed in “9. Contact Points for Claims.”

9. Contact Points for Claims

Any comments regarding the handling of the Customers’ Personal Information & Person-Related Information. retained by each Asahi Group Company are welcome at the following contact points. Please kindly understand in advance that we cannot receive your comments in person even if you visit our offices.

As for Asahi Group Holdings Ltd., Asahi Group Japan, Ltd. and the group companies except for the following companies, please inquire with Asahi Breweries, Ltd.’s Customer Service.

Please understand our Customer Service are Only in Japanese available.

10. Others

All or part of the Privacy Policy and the announcements pursuant to the Act are subject to change. If there is any important change, such change will be announced on the website.