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Personal information protection policy
Handling of Personal Information


We believe that it is our social responsibility to strictly protect any personal information about our clients and our employees. We confirm our Privacy Policy as the standard for handling all personal information, and will implement a company-wide protocol for the protection of personal information, which we seek to continuously monitor and improve.


1.	Definition of Personal Information
Personal information is any information that is acquired from the principal and allows to identify the principal individually through their name, address, telephone number, email address or date of birth. Even when this information in itself is not sufficient to identify the principal, such identification may be possible with the help of further information, therefore the above items will in all cases be considered personal information. 


2. Acquisition and Use of Personal Information
We will acquire and use personal information only for clearly specified purposes necessary for the achievement of our business activities. This includes any personal information acquired through telephone, our online shop or through any personal introduction.  

Purpose of Use in Business Activities:
(1) Providing assessment, purchase, sales of artworks, and related services
(2) Sending details about our artworks, services, exhibitions and events 


3. Shared Use of Personal Information
We will share personal information within the Shibunkaku Group only in the cases outlined below. In such cases, the handling of any personal information will strictly adhere to the regulations outlined in the Personal Information Protection Law and any other law relating to the handling of personal information.
(1)	Scope of sharing information: Shibunkaku Group (Shibunkaku, Co. Ltd., Shibunkaku Bijutsu and Shibunkaku Publishing).
(2)	Purpose of sharing information: as outlined in 2. above.
(3)	Type of personal information to be shared: all personal data including name, affiliation (company name and department name), occupation, address, telephone number, FAX number, email address, purchase history.
(4)	Responsible for management of shared personal information: Shibunkaku, Co. Ltd.
(5)	Means of acquisition: from client (web forms, email, FAX, any electronic data and phone conversations), Shibunkaku internal data sharing, (written communication, electronic data etc.).


4. Entrusting Personal Information
Shibunkaku, Co. Ltd., may within the limits of the purpose of use outlined in 2. entrust personal information to third parties. In such case, we will ensure that data protection by such third parties is ensured and that an appropriate non-disclosure agreement between Shibunkaku, Co. Ltd., and the third party is in place. 


5. Provision of Personal Information to a Third Party
Shibunkaku, Co. Ltd., will not share personal information with third parties without the consent from the principal except in the following cases: 
(1)	If required by the law.
(2)	If required to protect human life, health or property, and the consent of the principal is difficult to obtain.
(3)	If required for to protect public health and the safety of minors, and the consent of the principal is difficult to obtain.
(4)	If required to cooperate with national or local authorities or any entity acting on behalf of such authorities, and if acquiring the consent of the principal impedes these authorities’s ability to complete or perform the tasks concerned.


6. Optionality of Provision of Personal Information
Provision of personal information to us for the purpose of use specified above is voluntary. Please note that incomplete or lack or information may prevent us to provide the full range of our services.


7. Acquisition of Personal Information by Deceptive or Misleading Means 
Shibunkaku, Co. Ltd., will not acquire any personal information by any method that is deceptive or misleading and/or will not allow the principal to immediately recognize the purpose of that acquisition of personal information.


8. Disclosure, Correction or Amendments to Personal Information 
Upon request by the principal, we will disclose or amend all personal information obtained. Such requests may include request for correction, addition of information, cease of use, deletion or cease of sharing to a third party. However, it excludes such information as the minimum information required for maintaining our business operations. In the latter case, we will inform the principal immediately and provide all necessary details. We do accept requests or inquiries concerning the handling and protection of personal information. We will confirm the receipt of such requests or inquiries and respond within appropriate time. All inquiries should be addressed to:

Shibunkaku, Co. Ltd., Personal Information Inquiries
355 Motomachi, Higashiyama-ku, Kyoto 605-0089, Japan
Tel. 075-531-0001		Fax: 075-531-5533



Protection of Personal Information on our Website
Our website encrypts all sending and receiving of data via SSL (Secure Socket Layers) encryption technology. 


Shibunkaku, Co. Ltd.
Responsible for Protection of Personal Information: Irie Manabu, Deputy Director
I have read and agreed to the policy above.
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