Personal Information Protection Policy and Personal Information Management Guidelines of Pigeon Corporation

1. By appointing such executive(s) in charge of whole the process in utilizing the personal information (hereinafter referred to as “Personal Information”) belonged to our customers and employees (hereinafter referred to as “To-Be Covered”), including, but not limited to, acquisition, provision, or disclosure, of Personal Information, for proper management preventing such Personal Information from being unlawfully accessed, leaking, losing, or damaging.
2. On clarifying and prefixing the purpose for usage of Personal Information (hereinafter referred to as “Purpose”), and contact address for inquiry from To-Be Covered, we shall conduct appropriate collection and utilization of such Personal Information within the Purpose.
3. For implementing proper management on Personal Information disclosed by To-Be Covered, beyond the Purpose we shall never utilize, and for any third party, never provide or disclose Personal Information without the consent from To-Be Covered, provided, however, the following cases shall be excluded; (1) when such the provision or disclosure of Personal Information shall be publicly required by authorities under law or statutory; (2) when such the provision or disclosure of Personal Information shall be inevitable for the sake of public welfare, namely, restoring life, health, or property of To-Be Covered or any third party; or (3) when such the provision or disclosure of Personal Information may be especially admitted for us by authorities under law or statutory.
4. For preventing Personal Information from leaking or re-providing to any third party, we shall engaged ourselves in proper management on any companies including manufacturer or logistics companies, with whom we provide such Personal Information on fulfilment of the conditions described in article 3. above.
5. By responding sincerely and promptly to claim or inquiry on Personal Information.
6. By applying ourselves to laws, statutory, guidelines, or any other standards enforced by authorities, on Personal Information.
7. By continuously revising our current Personal Information Protection Management System whenever needed.

Enacted on February 1, 2004
Latest revised edition on April 25, 2019
Proclaimed by Norimasa Kitazawa, President and CEO, Pigeon Corporation

Personal Information Protection Policy

Pigeon Corporation (hereinafter referred to as “Pigeon”), based on its corporate creed “Love”, has been engaged in business focused in providing supportive products and services for all who need such indispensable products and services in their pregnancy, child birth, child rearing, and nursing care. For protection as to personal information belonged to every stakeholders toward Pigeon, from its obvious importance and social significance, we has established “Personal Information Protection Management System” that complies with “Requirements on Personal Information Protection Management System” (namely JIS Q 15001, one of the Japanese Industrial Standards). All executives and employees belonged to Pigeon shall comply with this “Personal Information Protection Management System”, as well as laws, regulations, and other statutory on Personal Information protection. We shall also sustain solid reliability on protecting personal information, through implementation of the following measures:

Executive in charge of the whole process in utilizing Personal Information and contact address for any related matters on Personal Information

Executive in charge of the whole process in utilizing Personal Information	Senior Manager, Administration Department, Pigeon Corporation
Contact address for any related matters on Personal Information	4-4, Nihonbashi-Hisamatsucho, Chuo-ku, Tokyo 103-8480 Japan
Phone	+81-3-3661-4200
Fax	+81-3-3661-4318
E-Mail	pgn-privacy@pigeon.com

Please see below for the contact information for requests for disclosure of personal information related to our internal reporting system, the "Speak Up Desk" (internal reporting system), and for complaints regarding the handling of personal information subject to disclosure.

・Speak Up Desk
Handling of personal information related to the Speak Up Desk

Personal Information Utilizing Guidelines

This “Personal Information Utilizing Guidelines” stipulates our basic ones for Personal Information to be collected and utilized by Pigeon.

As a business entity utilizing Personal Information, in utilizing Personal Information (namely, information including, but not limited to, name, birth date, or all the information contained the related description enable for identifying the person such the information belong to), Pigeon has enacted our original “Personal Information Protection Policy”, simultaneously, shall comply with “The Act on the Protection of Personal Information” or any other laws and statutory, as well as our “Personal Information Utilizing Guidelines”.

Purpose of usage of Personal Information

Pigeon shall, within the following restricted scope of purpose, utilize Personal Information on specifying the purpose of usage allowably; provided, however, when it falls on any of the stipulations in the “Act on the Protection of Personal Information” or any other laws and statutory, or when the consent from the person such the Personal Information belong to, is already obtained, such restriction may not be applied:

In collecting Personal Information directly from that person

(1) Information about customers

　・ For providing information on our products, services, and campaigns

　・ For responding to inquiries, requests for materials, consultation, and other needs of the customer

　・ For processing the registration or cancellation of the website membership

　・ For asking customers to try our products as a monitor or respond to questionnaires, or for product development

　・ For providing information on recalls, defects, and other issues

   ・ For selling and delivering products to customers

(2) Information on shareholders and investors

   ・ For ensuring shareholders’ exercise of rights and for fulfilling our obligations to shareholders in accordance with laws and regulations

　・ For managing shareholders, including the creation of shareholder data as prescribed under the applicable laws and regulations

　・ For providing information and other communications from the Company to shareholders

(3) Information about transactions

　・ For contacting customers for business negotiations and meetings

　・ For the performance of contracts

   ・ To respond to internal reports

(4) Information on job applicants, facility visitors, employees (including former employees and officers and employees of our group companies), and other related parties

　・ For recruiting, screening job applicants, and for completing hiring procedures

　・ For facility management

　・ For hiring employees, personnel and labor management, and contacting employees for business purposes

　・ For communication activities such as public relations and sales promotions, and branding activities

   ・ To respond to internal reports

In the event utilizing Personal Information (except Sensitive Personal Information) beyond the restricted scope of Purpose shall be indispensable, anew consent from that person shall be needed; provided, however, when it falls on any of the stipulations in the “Act on the Protection of Personal Information” or any other laws and statutory, or when the inclusive consent from the person such the Personal Information belong to, is already obtained, such consent may not be applied.

There might be outsource in all of, or apart of, our business to third party contractors, then for their conducting such the outsourced business, also might be disclosure of Personal Information, as necessary; provided, however, we shall conduct proper supervise or management on such contractors, according to standards stipulated in laws or statutory, as well as those of ours.

Regarding measures taken for safe management of personal information

In order to handle personal information more strictly, our company has established personal information protection regulations based on a personal information protection policy that complies with JIS Q 15001, and operates a personal information protection management system based on an understanding of the external environment. Doing. In addition, when actually handling personal information, we take security control measures from four perspectives: organizational, human, physical, and technical.

Related matters on Personal Information

Implementer’s name

Pigeon Corporation

Executive in charge of whole the process in utilizing Personal Information and contact address for any related matters on Personal Information

Disclosure Request Destination	Personal Information Protection Management Systems Secretariat
Contact address for any related matters on Personal Information	4-4, Nihonbashi-Hisamatsucho, Chuo-ku, Tokyo 103-8480 Japan
Phone	+81-3-3661-4200
Fax	+81-3-3661-4318
E-Mail	pgn-privacy@pigeon.com

Purpose of usage of Personal Information

Personal Information managed by Pigeon and to-be-disclosed on certain inquiry from third party, shall be Personal Information on business related to the above-described purpose of usage, Personal Information related to recruitment, and Personal Information belonged to employees. Purpose of usage of such Personal Information shall be referred to those described in the above “Purpose of usage of Personal Information”.

Procedure in response to inquiry for disclosure

In the inquiry for disclosure, there should be following procedures;

1. Acceptance of inquiry for disclosure and confirmation of personal identity of inquirer
   (ⅰ) Inquirer shall designate the concrete contents of to-be-disclosed, as well as inquirer’s name
   (ⅱ) Pigeon shall scrutinize IDs (copies of residential certification or other public certifications issued by authorities, before expiration) inquirer brings, then confirm personal identity of inquirer
   (ⅲ) When inquiry is made by proxy, as well as those described in above (ⅲ), inquiry form made by the original inquirer, and IDs (copies of residential certification or other public certifications issued by authorities, before expiration) for proxy shall be needed.
   (ⅳ) Inquiry made by mail may be available.
2. Notification of results against inquiry for disclosure
   (ⅰ) Results against inquiry for disclosure shall be sent inquirer by registered mail within 5 business days from the next day of acceptance of inquiry for disclosure. The Copies of your resident registration card and copies of official identification documents that you send us will be discarded or the data will be deleted. In cases where we believe that a significant amount of time will be required to prepare the notification method you specified, we may consult with you separately.
   (ⅱ) When it falls on even one of the following conditions, all of, or part of Personal Information inquired for disclosure shall never disclosed;
   (a) Possibility of the inquirer or third party’s life, body, property, or other interests may be damaged
   (b) Possibility of Pigeon’s proper conduct of business may be severely bothered
   (c) Such disclosure shall be violation of any other laws or statutory
3. Measures for correction inquiry
   (ⅰ) When correction inquiry has made on the reasons of such disclosed Personal Information should be incorrect, Pigeon shall promptly engage necessary scrutinization and correction, if any.
   (ⅱ) Results arising from such the scrutinization above described shall be sent inquirer by registered mail within the next business day from the day correction has conducted, or the day it decided not to make correction.

Actual expenses for disclosure

We may charge inquirer actual expense incurred from the inquiry for disclosure.

Contact address for any claim on Personal Information managed by Pigeon and to-be-disclosed on certain inquiry

A Supervisor of Complaint Desk	Senior Manager, Administration Department, Pigeon Corporation
Address	4-4, Nihonbashi-Hisamatsucho, Chuo-ku, Tokyo 103-8480 Japan
Phone	+81-3-3661-4200
Fax	+81-3-3661-4318
E-Mail	pgn-privacy@pigeon.com

Provision to third party

Pigeon shall never provide or disclose any of Personal Information collected by us to any third party (including third parties abroad); provided, however, when it falls on any of the following conditions, such prohibition may not be applied.

• When the consent from the person such the Personal Information belong to, is already obtained
• When needed for protecting third party’s life, body, property, as well as the consent from the person such the Personal Information belong to, may seemed to be difficult to obtain.
• Inquiry for disclosure or provision has made by authorities based on laws or statutory

Use of personal information

Pigeon may share personal data provided by our group companies. When sharing personal information with group companies, we will notify or announce the following matters in advance.

• Items of personal information shared with group companies
• Range of parties who share the information
• Purpose of use of parties who share the information
• Name of the organization or the person responsible for managing the shared personal information

Scope of shared use

•  Pigeon Corporation and its group companies

Disclosure, correction, discontinuation of usage of registered matters

Pigeon shall, to the extent that our proper conduct of business may never be bothered, disclose Personal Information on the inquiry from the person such the Personal Information belong to; provided, however, prior to such disclosure, Pigeon shall confirm personal identity of inquirer by its internally designated methods. When there should be differential in disclosed Personal Information, Pigeon shall promptly correct such the differential; meanwhile Pigeon shall promptly discontinue such the usage, on inquiry for discontinuation of Personal Information from the person such the Personal Information belong to.

Security measures for corporate website

For our customers, in registering Personal Information via website, we shall adopt data encryption technology, SSL, for preventing leaking on network.
SSL is seemed to be the common technology adopted as the measure for ascertaining security for telecommunication on website. SSL shall prevent message from intercepting by encryption of data entered, prior to the transmission.

Though we, Pigeon, shall manage Personal Information with duty of diligence, confidentiality on Personal Information included in internet or e-mail data may not be completely guaranteed from their nature. In usage of any website or e-mail, be attentive for this weakness.

Usage of Personal Information designated for certain products or service

Pigeon shall introduce, for certain products or service, special standards on purpose of usage, provision to third party, security, or contact address as to Personal Information in website, e-mail advertising, or various advertisement or notification. When such the special standards may contradict for “Personal Information Utilizing Guidelines”, such the special standards shall be prevailed, only for certain products or service.

Revised edition

This “Personal Information Utilizing Guidelines” may be revised without prior notice, according to revision of related laws or statutory, as well as our policy amendment.

Membership of authorized organization on personal information protection

Pigeon has been a member of Japan General Foundation Institute of Information and the Economic and Social Promotion Association (hereinafter referred to as “JIPDEC”), founded on Article 37, of The Act on the Protection of Personal Information. JIPDEC may also accept claims on Pigeon’s management of Personal Information.

1. Formal name of authorized organization on personal information protection
   Japan General Foundation Institute of Information and the Economic and Social Promotion Association
2. Contact address for any claim for Personal Information
   Consultation service office on personal information protection, JIPDEC
   12F, Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032 Japan
   Phone:  +81-3-5860-7565

The above contact address shall be never the one for products or services provided by Pigeon. The contact address aims at products or service provided by Pigeon shall be :
Customer consultation room, Pigeon Corporation
Phone: 0120-741-887 

Pigeon shall properly manage Personal Information as well as providing various valuable products and service. From its foundation, Pigeon ought to be for protecting, and improving such the management system of, Personal Information. “The Act on the Protection of Personal Information”, enforced on April 1, 2005, by which Pigeon has managed Personal Information, as well its internal“Personal Information Utilizing Guidelines” and “Personal Information Protection Policy”.

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※Group Companies
Pigeon Home Products Corporation
Pigeon Manufacturing Ibaraki Corporation
Pigeon Manufacturing Hyogo Corporation
Pigeon Tahira Corporation
Pigeon Hearts Corporation
PIGEON SINGAPORE PTE.LTD. (Singapore)
PIGEON MALAYSIA（TRADING）SDN.BHD.(Malaysia)
PT PIGEON INDONESIA〔Indonesia〕
PT PIGEON BABY LAB INDONESIA (Indonesia)
PIGEON（SHANGHAI）CO.,LTD.(China)
PIGEON MANUFACTURING（SHANGHAI）CO.,LTD.(China)
PIGEON INDUSTRIES（CHANGZHOU）CO.,LTD.(China)
LANSINOH LABORATORIES,INC.(USA)
LANSINOH LABORATORIES MEDICAL DEVICES DESIGN INDUSTRY AND COMMERCE LTD.CO.(Turkey)
LANSINOH LABORATORIES BENELU (Belgium)
LANSINOH LABORATORIES SHANGHAI(China)
LANSINOH LABORATORIES (HONGKONG)(Hongkong, China)
LANSINOH LABORATORIES UK (UK)
DoubleHeart Co.Ltd.(Korea)
PIGEON INDIA PVT.LTD.(India)
PIGEON INDUSTRIES（Thailand）CO., LTD.(Thailand)
THAI PIGEON CO., LTD.(Thailand)