Items to be published in accordance with the Act on the Protection of Personal Information

The Skylark Group* (hereinafter referred to as "the Group") will post the following matters that should be published or put in a state where the individual him or herself can easily know them, as set forth under the Act on the Protection of Personal Information. Please read them. When used below, the term "the Company" refers to Skylark Holdings Co., Ltd., which is the representative for the Group.

• *Skylark Group refers to Skylark Holdings Co., Ltd., Skylark Restaurants Co., Ltd., NILAX Inc., FLO Japon Co., Ltd., Tomato and Associates Co., Ltd., Skylark D&M Co., Ltd. and Japan Cargo., Ltd.

1.Matters Regarding Announcement of Purpose of Use of Personal Information

（1）Purpose of use when Personal Information Is Acquired Directly by Telephone or in Writing, etc.
(including electromagnetically stored / electronic data records)

When acquiring Personal Information directly by telephone, or in writing, etc. (including electromagnetically stored / electronic data records), the purpose of use will be clearly indicated for each acquisition. The main contents of Personal Information acquired by the Group are as follows.

Personal Information acquired by telephone or in writing, etc. (including electromagnetically stored / electronic data records)	Purposes of use
Personal Information acquired by registering membership information, etc. of the following service sites or Company apps provided by the Company ▶Home delivery site services (including Personal Information acquired from e-commerce sites where the Company opens stores) ▶ Takeaway / takeout site services ▶ Mail order site services (including Personal Information acquired from e-commerce sites where the Company opens stores)	▶ For delivery of products, communications relating to the delivery of products and after-sales follow-up ▶ To provide information on new products and deals / special offers on the services listed on the left and new information such as information on changes to the site, and to conduct questionnaire surveys relating to products ▶For statistical information and data analysis to make better proposals to introduce the services listed on the left
Personal Information acquired in connection with inquiries to the Company via telephone and inquiry forms, etc.	▶To respond to and contact customers about the contents of inquiries Telephone calls received by the Group may be recorded in order to improve the quality of telephone responses and to accurately confirm the contents of inquiries.

(2) Purposes of use of Retained Personal Data

Among the Personal Information acquired by the Group, the purpose of use of Retained Personal Data* is the same as the purpose of use in the table in (1) above. Personal Information from applicants in recruitment activities for regular / full-time employment is acquired by the Skylark Group Recruitment Business Community, so please check their website.

[Skylark Group Recruitment Business Community website] [Privacy Policy for Job Applicants]

* Retained Personal Data refers to Personal Information data acquired by the Group that is subject to disclosure, correction, addition or deletion of contents, suspension of use, erasure, and suspension of provision to third parties (hereinafter referred to as "disclosure, etc.") by the Group in response to requests from the individual in question, or his or her agent.

2.Creation and Use of Anonymous or Pseudonymous Processed Information

The Group will make joint use of Personal Information obtained from customers only within the scope of the Group for marketing activities to deliver optimal information to customers, by statistically analyzing information processed into a state where specific individuals cannot be identified, in accordance with relevant laws and regulations.

Items of information contained in anonymous or pseudonymous processed information

• Gender
• Date of Birth
• Area of Residence
• Device information (UUID, IP address)
• Stores used and store product purchase history

3. Safety Management Measures

1. （1） Formulation of Basic Policy
   The Group has formulated a basic policy to ensure the proper handling of Retained Personal Data as an organization (see for instance the "Policy on Protection of Personal Information and Specific Personal Information, etc.").
2. （2）Establishment of Discipline
   We have formulated a handling flow manual for each business process regarding handling methods for Retained Personal Data, supervisors and persons in charge of specific business processes, and their duties.
3. （3）Technical and physical safety management measures
   We manage access to Retained Personal Data (limitation of access authority including measures such as immediate invalidation of the accounts of transferred or retired employees; a monitoring system for access status, with long-term storage of access logs, etc.; periodic change of passwords; entry and exit management, etc.)
   We implement restrictions on means by which Retained Personal Data can be taken off premises (prohibiting unauthorized recording to external storage media, monitoring file transmission via emails between persons inside and outside the company, etc.).
   We also implement measures to prevent unauthorized access from the outside (installation of firewalls, etc.)
4. （4） Systematic safety management measures
   In addition to appointing a person responsible for the management of Personal Information separately from the information security officer, we clarify the responsibilities and authority of employees with regard to the safety management of Personal Information.
   In addition to monitoring employees (including non-regular employees), we will establish a system for reporting and communication to supervisors when we identify facts that violate laws and regulations, or internal regulations, or signs of such violations.
   We establish internal rules and manuals, etc., relating to safety management, ensure that employees comply with them, and conduct appropriate audits regarding the state of compliance.
5. （5）Human safety management measures
   We will conduct regular education and training for employees on the safety management of Personal Information.
6. （6）Assessment of external environment
   When handling Retained Personal Data in other countries, we implement necessary and appropriate measures for the safety management of Retained Personal Data based on an understanding of the systems used to protect personal information within that particular foreign country and other external environments.

4.Provision of Personal Information to Third Parties

The Group will properly manage Personal Information acquired and will not provide it to any third parties without the prior consent from the individual to whom it pertains. However, this does not include the following cases.

1. （1）The disclosure is required by laws or regulations.
2. （2）Where the provision is required for protecting human life, body or property and it is difficult to obtain the approval of the individual.
3. （3）Offering to third party is particularly necessary to public health improvement or children's sound development, and it is difficult to obtain consent from the individual.
4. （4）Where it is necessary to help any national organization or a local public organization perform the clerical work prescribed in laws and regulations and the approval of the individual could hinder the performance of the clerical work

5.Matters Regarding Joint Use

The Group will jointly use the Retained Personal Data in the following items <1>–<3> to the extent necessary to achieve the purpose of use indicated for each item, among Group companies indicated in the following item <4>. The management representative responsible for the management of joint use is indicated in the following item <5>. For specific inquiries, please refer to Section 12 (Contacts for inquiries regarding Personal Information).

1. ＜1＞Personal information of owners, other than juridical persons, acquired in connection with the selection of store locations to be used in inter-group reconciliations
   ・Names, addresses, telephone numbers, email addresses
2. ＜2＞The following personal information acquired in connection with recruitment (limited to non-regular employment recruitment activities), in order to adjust and assign the number of new hires among Group companies
   ・Information written on applicant resumes or on resumes as prescribed by the Company (nationality, name, address and other career information)
   ・Information registered by members on recruitment sites (or apps)
3. ＜3＞Personal information acquired in connection with employment used for secondment, transfer, etc., among Group companies
   ・Employment information data (employee code and other information necessary for various notifications at the Labor Standards Inspection Office, etc.)
4. ＜4＞Scope of companies for joint use
   ▼Skylark Holdings Co., Ltd.
   ▼Skylark Restaurants Co., Ltd.
   ▼NILAX Inc.
   ▼FLO Japon Co., Ltd.
   ▼Tomato and Associates Co., Ltd.
   ▼Japan Cargo., Ltd.
   ▼Skylark D&M Co., Ltd.
5. ＜5＞Person responsible for the management of Retained Personal Data for joint use:
   Minoru Kanaya  President and Chief Operating Officer  Skylark Holdings Co., Ltd.

6.Handling of Cookies

Websites and apps operated by the Company use a technology called "cookies" for the purpose of improving convenience when browsing.By using cookies, it is possible to obtain the usage history of website users, but it is not possible to acquire their Personal Information.
Depending on your browser settings, users can refuse to accept cookies at any time, or display a warning when cookies are received.However, please note that by doing so, you may not be able to fully use the functions of this website.
For information on these functions, please refer to the "Help" section of your browser and set these settings.
For information on the use of cookies on this website, please read the site's Web Privacy Policy.

7. Procedures in Response to Requests for Disclosure, etc.

The Group responds to requests from the individual in question, or his or her agent, for notification of the purpose of use, disclosure (including disclosure of records provided to third parties), correction, etc. (correction, addition and deletion), suspension of use, etc. (suspension of use, erasure and suspension of provision to a third party) of Retained Personal Data (hereinafter referred to collectively as "requests for disclosure, etc.").

1. （1）Contact for requesting disclosure, etc.
   Requests for disclosure, etc., should be sent to the address below. Please attach the necessary documents to the prescribed application form, and send it by postal mail. Also, it will be helpful if you clearly write "Request for disclosure, etc. included" on the envelope.
   Mailing address: 1-25-8, Nishikubo, Musashino-shi, Tokyo 180-8580
   　　　 General Affairs Group, Skylark Holdings Co., Ltd.
2. （2）Documents to be submitted when requesting disclosure, etc. (forms, etc.)

In the case of the individual him or herself	When making a request for disclosure, etc., please download the "Application for Disclosure, etc. of Personal Information" [PDF: 116KB], fill in all of the prescribed items, enclose documents for identity verification, and send it by postal mail.
In the case of a legal representative	When making a request for disclosure, etc., please download the "Application for Disclosure, etc. of Personal Information" [PDF: 116KB], fill in all of the prescribed items, enclose documents for identity verification, documents for confirming legal representation rights, and documents to verify the identity of the legal representative, and send it by postal mail.
In the case of a delegated agent or representative	When making a request for disclosure, etc., please download the"Application for Disclosure, etc. of Personal Information" [PDF: 116KB] the "Power of Attorney Concerning Disclosure, etc. of Personal Information" [PDF: 77KB]fill in all of the prescribed items, enclose documents for identity verification, and the seal registration certificate of the individual in question, and send it by postal mail.

8.Fees and Collection Methods for Requests for Disclosure, etc.

Please enclose one 800 yen postage stamp per application.

• *If the fee is insufficient or if no fee is enclosed, we will contact you to that effect. If there is no payment within the prescribed period, we will respond as if no request for disclosure, etc., was made.

9.Method of Response to Requests for Disclosure, etc.

In accordance with the method of request chosen by the applicant, we will respond to the address listed in the application. Please note that if disclosure by electronic means requires a great amount of expense, or if it is otherwise difficult to disclose by the method that you requested, we may ask you to change to disclosure by issue of written documents.

10.Purpose of Use of Personal Information Obtained in Relation to Requests for Disclosure, etc.

Personal Information acquired in connection with requests for disclosure, etc. will be handled only to the extent necessary for handling such requests.
Submitted documents will be retained for three years after the completion of the Company's response to the request for disclosure, etc., and then disposed of.

11.Reasons Why the Company May Be Unable to Comply with Requests for Disclosure, etc.

In the following cases, we will not be able to comply with requests for disclosure, etc. If we are unable to reply with a request for disclosure, etc., we will notify you to that effect, with the reason attached. However, even if we are unable to comply with a request for disclosure, etc., you will be charged a prescribed fee.

1. （1）When it is not possible to confirm the identity of the individual due to discrepancies between the Personal Information stated in the application form and the information on the individual held by the Group
2. （2）When the right of representation cannot be confirmed when a representative applies on behalf of the individual
3. （3）When there are deficiencies in the prescribed application documents
4. （4）When the target of the request for disclosure, etc., does not fall under Retained Personal Data, or when the Personal Information already no longer exists due to disposal or erasure, etc.
5. （5）When it falls under the grounds for exclusion prescribed by the Act on the Protection of Personal Information
6. （6）When disclosure would violate laws or regulations

12. Contacts for Inquiries Regarding Personal Information

For any inquiry on our handling of Personal Information, please contact the following.
Please note that we cannot accept requests from persons who directly visit us in our office.

By Telephone	TEL：0422-37-5223 (weekdays: 09:00–18:00) General Affairs Group, Skylark Holdings Co., Ltd.
By Postal Mail	1-25-8 Nishikubo, Musashino-shi, Tokyo 180-8580, Japan General Affairs Group, Skylark Holdings Co., Ltd.
E-mail	Inquiries

13.Revisions to these announcements

These announcements may be subject to revision without notice. In the event of revisions, we will promptly notify users on this site.

Established on July 1, 2014
Last revised on April 1, 2022