Tōtōtō Inc. (hereinafter “the Company”) recognizes the importance of personally identifiable information (“Personal Information”) provided by customers and is committed to protecting the privacy of all individuals who use its services. The Company will continuously review and seek to improve the content of this Policy.
1. Compliance with Laws, Guidelines, and Other Standards
The Company will comply with the Act on the Protection of Personal Information, all related laws and regulations, and applicable guidelines when handling Personal Information.
2. Collection of Personal Information
When collecting Personal Information, the Company will clearly state the purpose of use and collect such information only to the extent necessary to achieve that purpose, through lawful and fair means.
3. Purposes for Use of Personal Information
Personal Information provided by customers at the time of reservation will be used in accordance with the Act on the Protection of Personal Information and related laws, based on the consent of the individual concerned or other legal grounds, and only for the following purposes. In some cases, with the consent of the individual concerned, such information may also be shared with third parties.
- To carry out procedures necessary for the provision of services at shimahaku / shimameshi / shimayu.
- To communicate with customers.
- To handle document delivery, product shipment, responses to inquiries, and other related arrangements.
- To send information regarding events, new products, services, and other announcements.
- To conduct sales activities via mail, telephone, email, or in-person visits, as well as after-sales service and marketing activities (including surveys). (※)
- To conduct market analysis for the development of improved accommodations and service offerings. (※)
- To ship products purchased at facility shops or through the Company.
- For any other purposes separately communicated or disclosed to the individual concerned.
- In any other cases where the Company determines that communication with the individual concerned is necessary.
- To exercise or fulfill rights or obligations under applicable laws.
- For the purposes described in Section 5-3 below.
※ Includes use based on analysis of usage history, browsing history, and similar data.
4. Disclosure of Personal Information to Third Parties
The Company will not provide Personal Information to third parties except in the following circumstances:
- Where prior consent has been obtained from the individual concerned.
- Where required by law.
- Where necessary to protect the life, body, or property of an individual, and obtaining consent from the individual concerned is not practicable.
- Where necessary for the improvement of public health or the sound development of children, and obtaining consent from the individual concerned is not practicable.
- Where it is necessary to cooperate with a national or local government body, or a party entrusted by such a body, in carrying out duties prescribed by law, and obtaining consent from the individual concerned is likely to impede the performance of those duties.
- Where the third party is an academic research institution and needs to handle the personal data for academic research purposes (including cases where part of the purpose is academic research), except where doing so would unduly infringe upon the rights and interests of the individual concerned.
- Where disclosure or provision to a subcontractor is necessary within the scope required to provide services to customers.
- Where provision to a business operator is necessary within the scope required to fulfill service arrangements or product procurement requested by the customer.
5. Joint Use of Personal Information
The Company may share customers’ Personal Information among group companies as follows:
- Categories of Personal Data Subject to Joint Use
- Name, date of birth, address, telephone number, email address, place of employment, gender, transaction details, etc.
- Scope of Joint Users
- All companies within The Ryobi Group
- Purposes of Use by Joint Users
- To provide products and services handled by the Company or group companies.
- To send direct mail and information regarding products and services, and to conduct surveys on behalf of the Company or group companies.
- To relay inquiries, applications, or requests from customers regarding products or services offered by the Company or group companies to the relevant company.
- To manage customer relationships within the Company and group companies.
- To carry out other operations incidental or related to the above.
- Party Responsible for Management of Personal Data
- RYOBI HOLDINGS Co.,Ltd.
- Address: Machi no Machi Grace Office Square 5F, 2-10-12 Shimo-Ishii, Kita-ku, Okayama City, Okayama 700-8518
- Representative: Takeo Miyake
6. Security Management Measures
The Company implements the following security management measures for retained personal data:
- Establishment of Basic Policy
- A basic policy has been established covering compliance with applicable laws and guidelines, and the handling of inquiries and complaints regarding Personal Information.
- Development of Rules for Handling Personal Data
- Regulations governing the handling of Personal Information have been established for each stage of the data lifecycle, including collection, use, storage, provision, deletion, and disposal, specifying handling methods, responsible parties, and their duties.
- Organizational Security Management Measures
- The Company conducts regular internal self-assessments of Personal Information handling practices and has other departments perform audits.
- Human Resource Security Management Measures
- Regular training is provided to employees on matters to be observed when handling Personal Information.
- Physical Security Management Measures
- Measures are in place to prevent theft or loss of devices, electronic media, and documents used to handle Personal Information. When transporting such items, including within the premises, measures are taken to ensure that Personal Information cannot be readily identified.
- Technical Security Management Measures
- Access controls are implemented to limit the personnel and scope of Personal Information databases that may be accessed.
- Understanding of the External Environment
- When handling Personal Information in foreign countries, the Company takes appropriate measures to ensure the security of Personal Information after assessing the relevant personal information protection frameworks in those countries.
7. Retention Period for Personal Information
Upon expiration of any legally mandated retention period, or upon the fulfillment of the purposes for use described in Section 3, the Company will promptly delete the relevant Personal Information.
8. Management of Subcontractors Handling Personal Information
The Company may provide customers’ Personal Information to subcontractors to the extent necessary to achieve the purposes of use. In such cases, the Company will exercise appropriate oversight to ensure confidentiality is maintained. When outsourcing the processing of Personal Information, the Company will contractually prohibit subcontractors from disclosing or re-providing such information and will implement appropriate management measures.
9. Inquiries, Disclosure, Deletion, and Correction of Personal Information
Individuals wishing to request correction, suspension of use, complaint handling, objection, deletion, erasure, or withdrawal of consent regarding Personal Information held by the Company should contact the inquiry desk listed in Section 10, where guidance on the required procedures will be provided. Please note that requests that would significantly impede the proper conduct of the Company’s business operations may not be accommodated. All other requests will be addressed without undue delay in accordance with applicable laws and internal regulations. Where a request cannot be fulfillled in whole or in part, an explanation will be provided.
Individuals wishing to request disclosure of Personal Information or records of third-party provision held by the Company should send the documents listed in [A] below by postal mail to the inquiry desk listed in Section 10. Requests submitted by means other than postal mail will not be accepted. Upon verification of identity, the Company will respond promptly and within a reasonable scope. However, disclosure may be withheld in whole or in part in the following circumstances:
- Where disclosure is likely to harm the life, body, property, or other rights and interests of the individual concerned or a third party.
- Where disclosure is likely to significantly impede the proper conduct of the Company’s business operations.
- Where disclosure would constitute a violation of other laws.
【A】Documents Required for Postal Submission
When requesting as the individual concerned:
- A document clearly stating the purpose of the request.
- A copy of a valid driver’s license, passport, or other official government-issued identification.
- A return envelope with sufficient postage for delivery by registered mail with delivery confirmation.
When requesting through an authorized representative:
- A document clearly stating the purpose of the request.
- For a statutory representative: documents certifying the representative’s authority, such as a family register extract.
- For a voluntary representative: a power of attorney. A certified seal registration certificate (inkan shōmei) of the principal may be attached to verify the seal on the power of attorney.
- A copy of the principal’s valid driver’s license, passport, or other official government-issued identification. (A certified seal registration certificate of the principal may also be accepted as identification.)
- A copy of the representative’s valid driver’s license, passport, or other official government-issued identification.
- If the representative is an attorney or tax accountant, a copy of the relevant certification.
- A return envelope with sufficient postage for delivery by registered mail with delivery confirmation.
10. Contact for Personal Information Inquiries
All inquiries regarding Personal Information should be directed to:
RYOBI HOLDINGS Co.,Ltd., Ryobi Management Support Company, General Affairs Division
Address: Mori no Machi Grace Office Square 5F, 2-10-12 Shimo-Ishii, Kita-ku, Okayama City, Okayama 700-8518
Phone: 086-232-2118
Effective: January 20, 2026