Introduction
Cosmo Energy Holdings Co., Ltd. (hereafter, the “Company”), together with the subsidiaries and affiliated companies that comprise the Cosmo Group (hereafter, collectively referred to as the “Group”), recognizes the importance of properly handling personal information in order to realize the Cosmo Energy Group Management Vision (hereafter, the “Group Management Vision”), “Striving for an infinite tomorrow, developing sustainably in harmony with humanity, society, and our planet.”
Accordingly, the Cosmo Energy Group Code of Conduct (hereafter, the “Code of Conduct”) sets out how the Group handles information as a trustworthy corporate group. The following Privacy Policy (hereafter, the “Policy”) has been established to set forth the Group’s basic policy on the handling of personal information in the course of its business activities, in accordance with the Group Management Vision and the Code of Conduct.
If any company within the Group has established and publicly disclosed its own privacy policy, that company’s privacy policy shall take precedence over, and apply in place of, this Policy.
1. Collection of Personal Information
The Group may request that customers provide, register, or submit information that can identify them (hereafter, “personal information”) when conducting business with the Group or using the various services it provides. In such cases, the Group will clearly state the purpose of use and obtain customers’ consent before collecting personal information. The Group will not collect personal information without consent.
2. Purpose of Use of Personal Information
1. The Group will use the personal information it collects solely within the scope of the purposes specified below and will not use it for any other purpose, except as permitted by applicable laws and regulations. In the event that the collected personal information is no longer necessary for its intended use, a serious data breach or similar incident occurs, or there is a risk that the rights or legitimate interests of customers may be impaired, the Group will cease use of or delete such information.
（1）To respond to questions, requests, or inquiries from customers
（2）To respond to orders and applications from customers
（3）To advertise and provide the Group's products and services to customers
（4）To resolve and prevent issues related to products and services provided to customers
（5）To develop products and services that meet customer needs
（6）To conduct surveys related to the Group’s various operations, and to analyze acquired information, including customers’ usage of the Group’s products and services, as well as their attributes, behavior, and interests; to carry out marketing and promotional activities for the Group’s products and services; and to plan and provide new business models, products, and services based on the results of such collection and analysis. In addition, when customers use multiple services provided by the Group data across all such services may be linked or integrated prior to use.
（7）To inform and manage campaigns, exhibitions, events, the provision of IR information, and other sales promotion activities related to the Group's products and new products, as well as to provide services in connection with campaigns
（8）To carry out the Group’s business operations and to handle related matters, including the investigation, selection, and acquisition negotiation for business sites; contract and registration procedures; consultations, filings, and permit or licensing procedures with relevant authorities; and explanations to, and consultations with, stakeholders regarding plans, business activities, and other related matters
2. In addition, the Group may obtain information about customers from advertising-related companies such as ad distribution service providers, affiliate partners, and data management platform operators, as well as from other third parties, and may use this information in conjunction with personal information already possessed by the Group. Such information may include website browsing history, product purchase history, and service usage history; location information, including GPS data; demographic data such as gender, age group, area of residence, income, occupation, and household composition; data on customers’ interests, lifestyles, hobbies, and preferences; device information such as operating systems; and cookie IDs, advertising IDs, IP addresses, and other online identifiers.
3. Provision of Personal Information
The Group will not provide or disclose any personal data provided by customers to third parties without their consent, except in the following cases:
(1) When required by applicable laws and regulations
(2) When responding to inquiries from the police, courts, or other public authorities in accordance with applicable laws and regulations
(3) When it is necessary to protect the life, body, or property of an individual and obtaining consent is difficult
(4) When prior consent has been obtained to provide or disclose personal information to a third party
(5) When personal information is entrusted to a third party to the extent necessary to achieve the purpose of use, under the Group's appropriate supervision
4. Shared Use of Personal Information
The Group may share customers’ personal data with the parties listed in (2) below, within the scope described therein.
(1) Information for shared use
Name, address, telephone number, fax number, email address, affiliation information (such as company name, department name, title), inquiry or request details, information regarding product and service purchases, contract-related information
(2) Scope of shared users
・Please visit the following page on the Company's website for details:
https://www.cosmo-energy.co.jp/en/company/group.html
(3) Purpose of use of shared users
Purposes of use stipulated in 2. above
(4) Party responsible for the management of shared information
The Company. For the Company’s address and representative, please visit the following page on its website:
5. Provision of Personal Information to Third Parties in Foreign Countries
The Group may provide personal data it handles to third parties in foreign countries. As these countries may not provide a level of personal information protection equivalent to that of Japan, the Group will not share customers’ personal data with such third parties unless they have implemented measures required under the Act on the Protection of Personal Information of Japan, except where provision is permitted by law or where the Group has obtained the customer's consent in a manner prescribed by law.
6. Google Analytics
The Group uses Google Analytics, provided by Google LLC, as part of its services, to understand and analyze how such services are used. For information regarding Google Analytics’ terms of service, please refer to Google Marketing Platform. For information on Google's privacy policy, please refer to the following page on its website.
・Google Analytics Terms of Service:
・Google Privacy Policy:
7. Management of Personal Information
The Group implements organizational security measures to protect personal information from unauthorized access, loss, destruction, falsification, or leakage. These measures include technical safeguards such as systems to prevent unauthorized access, the appointment of a personal information management officer, and the establishment of an information handling manual. For details on the personal information handling framework and measures implemented by the Group, please contact us via the form specified in “12. Contact for Inquiries.”
https://www.cosmo-energy.co.jp/ja/contact.html. (available in Japanese only)
8. Compliance with Laws and Regulations and Continuous Improvement of the Personal Information Protection System
1. The Group will comply with laws, regulations, and other rules related to personal information.
In addition, the Group will continuously review its internal rules and related regulations, employee training, security measures, organizations, and systems pertaining to the protection of personal information, as well as the handling of personal information (this Policy) based on these rules and regulations in order to improve the level of personal information protection.
2. The Group may review and revise the handling of this Policy from time to time. In the event revisions are made, the Group will notify customers of the updated policy, either by posting it on this website or by other appropriate means.
9. Procedures for Disclosure, Correction, Suspension of Use, and Other Actions Regarding Personal Information
1. If a customer requests that the Group disclose or take other action regarding their personal information—including notification of the purpose of use, disclosure, correction, addition, or deletion, suspension of use or provision to a third party, and disclosure of records of provision to a third party (the same applies hereafter)—in accordance with the Act on the Protection of Personal Information, the Group will, in accordance with the Act and the following provisions, promptly carry out such disclosure or action after verifying that the request has been made by the customer personally.
(1) Notification of purpose of use or disclosure of retained personal data or records of provision to a third party
If a customer requests that the Group notify them of the purpose of use, or disclose the retained personal data or records of provision to a third party, they may make such a request in accordance with the procedures separately established by the Group, except in the following cases:
a. When disclosure may harm the life, body, property, or other rights or interests of the customer or a third party
b. When disclosure may materially impede the proper execution of the Group’s business operations
c. When disclosure would violate laws and regulations
d. When it cannot be confirmed that the request for disclosure was made by the customer personally
Please note that a disclosure fee may be charged in accordance with procedures separately established by the Group when requesting notification of the purpose of use or disclosure of retained personal data or records of provision to a third party.
(2) Correction, addition, and deletion
Customers may request the correction, addition, or deletion of retained personal data in accordance with procedures separately established by the Group. In such cases, the Group will promptly investigate within the scope necessary to achieve the purpose of use and make the requested corrections, additions, or deletions to the retained personal data based on the results of the investigation.
(3) Suspension of use or provision to a third party
Customers may request the suspension of the use of their personal data or its provision to third parties, in accordance with procedures separately established by the Group. In such cases, the Group will respond appropriately in accordance with the Act on the Protection of Personal Information.
2. When making a request as described in the preceding paragraphs, please provide the following information and materials as stipulated by the Group.
(1) Name, address, telephone number, and email address
(2) Request details
(3) Identity verification documents
10. Handling of Personal Information on Websites
1. Access logs
Information about when customers accessed the Group’s websites, from which domain, and which pages they visited is stored on the Group’s web servers. This is a common practice in web server operations, with the primary purpose of analyzing page popularity. Such information is treated only as statistical data and is not used to identify individual customers.
2. Cookies
(1) The Group's websites use small pieces of data called “cookies” in part to enhance the convenience of Group services. Cookies temporarily store information entered on a page or form on the customer’s computer. For example, if a customer enters information on a given page and wants to use it on another page or during their next visit to a given website, cookies allow this information to be retained, eliminating the need to enter it again.
(2) The Group's websites use cookies for the following purposes:
・To enhance website functionality to make services more convenient
・To analyze customers’ activity on a given website and provide contents and advertisements that align with their interests and preferences
・To collect and analyze access and activity logs to measure and improve website performance
Cookies do not contain personal customer information such as name, address, date of birth, or email address.
(3) The Group respects the privacy of customers who use its websites and has introduced a cookie consent banner in some cases.
Customers can choose to accept or reject the use of cookies that are not essential to the operation of each website or by third parties—such as the Group’s analytics partners or ad distribution service providers—by clicking on the cookie consent banner displayed on the website or the cookie settings link provided in the website footer.
(4) Customers can set their internet browser to reject cookies, but please note that doing so may limit the services provided. Since the method for changing settings varies depending on the browser, please refer to your browser's help section or other documentation.
In addition, the Group uses cookies as well as third-party tools and services. In connection with these, the Group may provide non-personally identifiable customer information to such providers, which will be handled in accordance with each provider’s privacy policy and other applicable rules.
If you wish to disable (opt out of) advertising or other services using third-party cookies, please do so through the relevant provider's website.
Opt-out pages for major service providers:
・Opt out of Facebook ads
・Opt out of Yahoo! JAPAN ads
・Opt out of Google Analytics
・Opt out of Google ads
3. Acquisition and use of activity logs
(1) In order to use ad distribution services provided by third parties, the Group’s websites may collect information such as pages viewed by customers on a given website, the date and time of access, URLs visited, browsing history, browser type and language, IP addresses, location information, and device-specific identifiers.
(2) The collected activity logs are used for the following purpose:
・To provide customers browsing a given website with content and ads that align with their interests and preferences
4. Web beacons
The Group's websites use web beacons, a technology that measures how often specific pages are accessed, on certain pages. The statistical data obtained through web beacons is used to improve such websites.
5. Encryption of communication
To protect customers' personal information, the Group's websites use SSL (Secure Sockets Layer) encrypted communication. SSL is an encryption technology that prevents information exchanged between a browser and a web server from being leaked. By using SSL, customers’ personal information is encrypted during transmission.
6. Some of the Group's websites are developed and operated by contractors and partners. These contractors and partners are limited to companies with which the Group has concluded confidentiality agreements regarding personal information and are required to manage and operate such websites in the same manner as the Group.
11. Audio and Video Recording
To accurately understand and respond to customer requests or needs, the Group may record the content of telephone calls. In addition, the Group may also record images as required by law or for crime prevention and security management purposes. Any personal information captured through audio or video recording will be promptly deleted when it is no longer needed.
12. Contact for Inquiries
For comments, questions, and other inquiries regarding this Policy and the handling of personal information, as well as requests made under “9. Procedures for Disclosure, Correction, Suspension of Use, and Other Actions Regarding Personal Information,” please contact us via the following form:
(available in Japanese only)