PRIVACY POLICY

Privacy Protection Policy Declaration

Nippon Kabaya Ohayo Holdings Group* (hereinafter referred to as “the Group”) handles a significant amount of personal information from customers and employees in the course of its business operations. In accordance with the Group’s Code of Ethics, we have established a Personal Information Protection Policy and a management framework to ensure the responsible handling of personal information as a corporate entity. The key principles of this policy are outlined below. (Please note that Sanyu School Corporation and Sanyu General Education Research Institute Co., Ltd. publish their own individual “Personal Information Protection Policies” and are therefore excluded from this policy.)

*The term “Nippon Kabaya Ohayo Holdings Group” refers collectively to Nippon Kabaya Ohayo Holdings Inc., OHAYO DAIRY PRODUCTS CO., LTD., ExL.Pack-Kabaya Co., Ltd., Square-building Co., Ltd., SETONAIKAI KEIZAI REPORT CO., LTD., Link & Linkage Inc., THE ROYAL GOLF CLUB INC., FUGAKU COUNTRY CLUB INC., Sanyu School Corporation, and Sanyu General Education Research Institute Co., Ltd.*

The Group clarifies internal regulations regarding the handling of personal information and ensures that all employees are thoroughly informed. We also request our business partners to handle personal information appropriately and take necessary measures to prevent use beyond stated purposes.
Personal information shall be obtained through lawful and proper means.
When collecting personal information, we will clearly state the purpose of collection and use in advance, obtain the individual’s consent, and handle the information only within the scope of the agreed purpose.
Personal information will not be provided to third parties without the individual’s consent.
We will strive to ensure that individuals can appropriately participate in the handling of their personal information, maintaining it as accurately and up to date as possible.
Requests from customers to disclose, correct, delete, or suspend the use of their personal information held by the Group will be accepted through the inquiry form below and will be handled in good faith.
Inquiry Form:https://www.kabaya-ohayo.com/contact/
The Group will take necessary measures to prevent incidents such as the leakage of customers’ personal information.
To protect personal information, all personnel engaged in operations under the Group’s supervision will be made aware of the importance of information assets and will receive appropriate education and training.
The Group will undergo audits by external third parties to ensure the proper handling of personal information and will implement any necessary improvements.

Last Revised: November 4th, 2025
Established: January 1, 2017
Nippon Kabaya Ohayo Holdings Inc.
Yamazaki Yoko, CEO

Personal Information Protection Policy

Handling of Personal Information

The Nippon Kabaya Ohayo Holdings Group (“the Group”) publishes this Personal Information Protection Policy to ensure that all services provided in accordance with it (hereinafter referred to as “the Services”) respect the privacy of our business partners, affiliated companies, organizations (collectively, “Partner Companies”), and individuals who use the Services (hereinafter referred to as “Users”). The Group places the highest importance on safeguarding Users’ personal information (as defined below) and handles such information with the utmost care and responsibility.

Definition of Personal Information

“Personal information” refers to information related to an individual User that can identify the User by name, address, telephone number, email address, date of birth, school name, or other such descriptions. Even if a single piece of information cannot identify the User on its own, any data that can be easily cross-referenced with other information to identify the individual—such as service usage history, browsing records, search logs, bookmarks, and other behavioral data—is also considered personal information.

Acquisition of Personal Information

The Group recognizes that collecting, using, providing, or entrusting personal information against the individuals will constitute an infringement of rights and damages corporate trust. Accordingly, we have established clear management rules for the collection, use, provision, and entrustment of personal information to ensure appropriate management. When collecting personal information from customers, we clearly state the purpose of collection and the contact point for inquiries, and we only collect information within the scope necessary to achieve that purpose.

Measures to Prevent Loss, Destruction, Alteration, or Leakage of Personal Information

To prevent the loss, destruction, alteration, or leakage of personal information, the Group implements robust information security measures, including protections against unauthorized access and computer viruses.

Compliance with Laws and Regulations

The Group complies with the Act on the Protection of Personal Information and all other applicable laws, regulations, and guidelines concerning personal information. We also act in accordance with internal regulations and conduct regular education and awareness programs for all employees, including executives.

Purpose of Use of Personal Information

The purposes for which the Group uses personal information are as follows. Personal information will not be used beyond these stated purposes:

User authentication and provision of the Services to Users
Smooth operation of point programs, including issuance, calculation, and redemption of points
Communication related to the Services, including newsletters, direct mail, and notifications
Provision of personal information to Partner Companies based on the User’s consent or application
Delivery and display of advertisements and content, and provision of the Services based on attribute, device, location, and behavioral information
Improvement of the Services, development of new services, research and analysis of point usage, and marketing activities
Implementation of campaigns, surveys, monitoring, and interviews
Distribution of URL information to senders of blank emails
Confirmation and response to opinions, inquiries, and user-submitted reviews related to the Services

Handling of Recipient Information Provided by Users

In the course of providing the Services, the Group may receive recipient information other than that of the User, for the purpose of delivering messages, products, or other items as requested by the User.
Such recipient information is used solely for delivering the requested messages or products and is appropriately managed as personal information. The registration, modification, and deletion of recipient information are the responsibility of the User. As a general rule, the Group does not modify or delete recipient information on behalf of the User. If you wish to request a change or deletion, please contact the User who sent the message or product directly. If you are unable to identify the sender, please contact the personal information inquiry desk listed below.

Voluntary Provision of Personal Information

If you do not provide the required information requested by the Services, you may not be able to use or receive certain features of the Services.

Joint Use of Personal Information

The Group jointly uses personal information as outlined below.

1) Items of Personal Information Subject to Joint Use

Personal information that identifies an individual User by name, address, telephone number, email address, date of birth, school name, or other such descriptions.
Even when a single piece of information cannot identify the User on its own, any data that can be easily cross-referenced with other information to identify the individual—including service usage history, browsing records, search logs, bookmarks, and other behavioral data—will also be included.

2) Scope of Joint Users

Nippon Kabaya Ohayo Holdings Inc., OHAYO DAIRY PRODUCTS CO., LTD., ExL.Pack-Kabaya Co., Ltd., Square-building Co., Ltd., SETONAIKAI KEIZAI REPORT CO., LTD., Link & Linkage Inc., THE ROYAL GOLF CLUB INC., FUGAKU COUNTRY CLUB INC., Sanyu School Corporation, and Sanyu General Education Research Institute Co., Ltd.

3) Purpose of Joint Use

Personal information will be jointly used for the purposes specified in “Purpose of Use of Personal Information.”

4) Entity Responsible for Managing Jointly Used Personal Information:

Nippon Kabaya Ohayo Holdings Inc.

Provision of Personal Information to Third Parties

As a general rule, the Group does not provide personal information to any third party without the consent of the individual User. Personal information will only be provided when both the recipient and the purpose of provision have been clearly identified, and the User has granted consent.

1) Recipients and Purposes of Provision

Personal information may be provided to Partner Companies that use the Services for the purpose of delivering materials, handling applications, reservations, purchases, and other related services.

2) Items of Personal Information Provided

Personal information that identifies an individual User by name, address, telephone number, email address, school name, or other such descriptions.
Even when a single piece of information cannot identify the User on its own, any data that can be easily cross-referenced with other information to identify the individual—including service usage history, browsing records, search logs, bookmarks, and other behavioral data—may be provided within the scope necessary to achieve the stated purpose.

3) Methods of Provision

Personal information may be provided in writing or by electronic means.
However, personal information may be provided without the User’s consent when permitted by relevant laws and regulations, in the following cases:

When it is deemed necessary to prevent harm to a third party
When it is particularly necessary for the improvement of public health or the sound development of children, and obtaining consent from the individual is difficult
When cooperation is required with national or local government organizations, or their contractors, to perform duties prescribed by law, and obtaining consent could impede the execution of those duties
When disclosure is requested by a court, public prosecutor’s office, police, or other authority with equivalent powers
When the User explicitly requests disclosure or provision to a third party
When disclosure or provision is permitted by law
When personal information is transferred in connection with a merger or other business succession, and handled within the scope of the original purpose of use

Disclaimer Regarding Provision to Third Parties

The Group assumes no responsibility for the acquisition of personal information by third parties in the following circumstances:

When the User voluntarily discloses personal information to Partner Companies through the Services or other means
(For details regarding how Partner Companies handle personal information, please contact them directly.)
When the User is inadvertently identified through information entered in the Services
When personal information is provided and used on external websites linked from the Services
When someone other than the User obtains and uses information that can identify the User (such as ID or password)

Outsourcing of Personal Information Processing

The Group may outsource part or all of its personal information processing operations to external service providers. In such cases, the Group remains responsible for ensuring proper handling of personal information by the contractor.

Use of Statistical Data

The Group may create statistical data processed from provided personal information in a form that does not identify individuals.
The Group may use such anonymized statistical data without restriction.

Disclosure, Correction, and Other Requests Concerning Personal Information

In principle, only the individual User may request notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, or suspension of provision to third parties (collectively, “Disclosure, Correction, etc.”).
For details on specific procedures, please refer to “Inquiries Regarding the Handling of Personal Information.”
However, such requests may not be fulfilled in the following cases:

When there is a risk of harm to the life, body, property, or other rights or interests of the User or a third party
When there is a risk of significant disruption to the proper operation of the Services
When fulfillment would violate other laws or regulations
If fulfilling a request would require an excessive cost or is otherwise difficult, and alternative measures are necessary to protect the User’s rights and interests, the Group may decline to make such changes.

Accuracy of Personal Information

The Group strives to accurately process personal information provided by Users. However, Users themselves are responsible for ensuring that the information they provide is accurate and up to date.

Restriction on the Collection of Sensitive Personal Information

As a general rule, the Group does not collect personal information containing the following sensitive details, except when such information is voluntarily provided by the User:

Thoughts, beliefs, or religious affiliation
Race, ethnicity, family origin, domicile (excluding prefecture-level information), physical or mental disability, criminal record, or other matters that may cause social discrimination
Details concerning the exercise of workers’ rights to organize, collective bargaining, or other group actions
Participation in demonstrations, exercise of petition rights, or other political activities
Health or sexual matters

Identity Verification

When Users register for web-based membership services, use the Services, or request disclosure, correction, deletion, or suspension of personal information, the Group verifies their identity using identifiable information such as name, address, telephone number, date of birth, email address, membership number, and password.
However, the Group bears no responsibility if a third party obtains and uses such identifying information.

Personal Information Protection Compliance Program

The Group establishes, implements, maintains, and continuously improves a compliance program related to the protection of personal information.
This program defines behavioral standards and organizational structures to ensure that all executives and employees act in compliance with applicable laws, regulations, and corporate ethics.

Revisions to the Personal Information Protection Policy

Except where otherwise required by law, the Group may revise this Personal Information Protection Policy from time to time.

Inquiries Regarding the Handling of Personal Information

The Group uses customers’ personal information only within the scope of the purposes clearly stated at the time of collection.
We may also provide information about the Group’s services and products by email or post.
If you prefer not to receive such communications, please contact us through the inquiry form below, and we will discontinue further notifications.
For requests regarding the disclosure, correction, or deletion of personal information, please contact us with the following details:

1) Your name
2) Your address
3) Your contact telephone number
4) Your email address
5) The details of your request

Contact for Inquiries:https://www.kabaya-ohayo.com/contact/
(Please note that the inquiry form is available in Japanese only.)

Last Revised: November 4th, 2025
Established: January 1, 2017