Privacy Policy Notice – Havas Health

1. Havas Life Tokyo is committed to protecting your privacy and personal information

Havas Life Tokyo is committed to protecting your privacy and personal information. This Havas Life Tokyo Policy informs you of our personal information processing practices and how your personal information is collected and used by Havas Life Tokyo Please read it all the way through. This policy is available on our homepage Havas Life Tokyo is committed to protecting the right to privacy and personal information, as well as complying with national and international personal information. protection laws. Havas Life Tokyo is committed to maintaining the confidentiality of any personal information and to strictly limiting its disclosure in accordance with national laws and current regulations.

2. Definitions

The terms below have the following meaning,

・“personal information” means any information relating to an identified or identifiable natural person, directly or indirectly in particular by reference to an identifier or one or more elements unique to his/her physical, physiological, psychological, economic, cultural, or social identity.
・“data subject” means a natural person whose personal information is processed by Havas Life Tokyo
・“regulations” means the regulations in force in Japan, applicable to the processing of personal information, including Act on the Protection of Personal Information (hereinafter referred to as the "Act").
・ “data controller” means a natural or legal person who determines the means and purposes of the processing of personal data (This refers to personal information that constitutes the Personal Information Database, etc. (See Article 16 of the Act.) within the meaning of the Regulations.
・“processor” means a natural or legal person who processes personal data on behalf of the data controller in connection with a service
・Website means the Havas Life Tokyo website accessible at the URL: https://havaslife.co.jp/en/
・“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. How do we process your personal information?

When you browse and interact with the Website and in general during your interactions or exchanges with the Havas Life Tokyo, Havas Life Tokyo may collect and process your personal information in order to manage activities conducted on its own account, as data controller.
Havas Life Tokyo respects the right of each individual, employee, applicant, customer, supplier, partner, administrator, subscriber, prospect or internet user to have their personal data protected. Havas Life Tokyo observes the principles defined by the regulations:

1. Processing your personal information fairly, lawfully and in a transparent manner.
2. Collecting your personal information for explicit, specified and legitimate purposes, and not processing them further in ways incompatible with those purposes.
3. Ensuring that the personal information collected is relevant, proportionate and not excessive with regard to the purposes for which they are collected and processed. Personal data may be anonymised when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses.
4. Keeping your personal data accurate and up to date if necessary. We will take reasonable steps to rectify or delete inaccurate or incomplete data
5. Personal data will be kept for the time necessary for the purposes for which they are collected and processed.
6. Personal data will be processed in accordance with the rights of individuals.
7. Technical, physical and organisational measures are taken to secure your data and prevent unauthorised access, unlawful processing and unauthorised or accidental loss, destruction or damage of personal data.
8. Processing your personal data in accordance with the legal bases for processing, including the collection of consent when required.

4. What types of personal information are collected?

In its capacity as data controller, Havas Life Tokyo collects and processes your personal information after informing you accordingly.
This Policy does not cover data rendered anonymous, i.e., when individuals are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost and labor. If anonymous data becomes identifiable, or if pseudonyms are used and allow individuals to be identified, then this Policy will apply. It is up to you whether or not to disclose personal information to us. However, if you choose not to do so, we reserve the right not to register you as a user or not to provide you with the requested service.
In general, your personal information is collected directly from you, but they may also be collected from third parties.
The types of personal information we process include:

・ your identification data (your first name, last name, pseudonym, gender, email address, postal address, telephone number, if applicable photograph, social media profile)
・ your professional data (your educational and professional background for job applicants, your job title, home company)
・ your login data: your IP address, if applicable, your online ID
・ your browsing data and expressed preference: traffic and browsing history on Havas Life Tokyo websites, data from cookies and trackers on Havas Life Tokyo websites

Except for specific legal obligations, we do not collect so-called Including personal information for consideration as defined in Article 3, Paragraph 3 of the Personal Information Protection Law, “sensitive” personal information or special categories of personal information
In general, and with some exceptions, the use of Havas Life Tokyo websites and Havas Life Tokyo pages on social networks is reserved for adults

5. What is the purpose, the legal basis for the collection of your personal information and the retention period?

In accordance with the regulations, the personal information we collect is used for the purposes for which they have been collected for the period of time indicated in the table below.
The processing operations carried out by Havas Life Tokyo have the following purposes, legal bases and retention periods:

Purposes	Legal basis	Retention period
Customer relationship management	Performance of the contract Legal obligation (accounting/tax/administrative)	Term of the contract plus applicable limitation periods
Partner and supplier relationship management	Performance of the contract Legal obligation (accounting/tax/administrative)	Term of the contract plus applicable limitation periods
Application management	Legitimate interest of Havas Life Tokyo	2 years
Product and institutional communication management (website and social networks)	Legitimate interest of Havas Life Tokyo	Duration of the communication plus applicable limitation periods
Administrative and legal formalities and the fight against fraud	Legal and regulatory obligation	Duration of applicable legal requirements
Subscription to newsletters	Consent	Duration of subscription to the newsletter
Management of cookies and other website trackers	Consent Legitimate interest of Havas Life Tokyo (technical cookies)	Periods specified in the website cookies policy
Management and follow-up of contact requests	Legitimate interest of Havas Life Tokyo	Time required to process the request
Reporting and securing access to websites	Legitimate interest of Havas Life Tokyo	6 months to 1 year maximum
Exercising your personal data rights	Legal and regulatory obligation	1 year or 6 years from the request to exercise the right, according to the right exercised

In the event of litigation/proceedings, particularly legal proceedings, initiated before the end of the above periods and which require the retention of personal data, particularly with a view to the establishment, exercise or defence of rights, such personal data shall be retained for the duration of said proceedings and until the exhaustion of the legal remedies.

6. Who are the recipients of your data?

Your personal data may be disclosed to staff in the following departments, according to their powers and authorizations and only if necessary for their activity, according to the purposes strictly pursued:
Internal recipients: General Secretariat, Communication, Legal, Finance and Accounting, Purchasing, Business Development, Digital, IT, General Services and Human Resources departments.
External recipients: The hosting providers of our websites, our auditors and statutory auditors, our legal advisers, our insurers, our duly authorised partners, service providers and subcontractors which we may use to carry out our activities, tax and social security bodies, public authorities, court officers and ministerial officers where applicable.

7. Data transfer

Havas Life Tokyo prioritizes the transfer of personal data within Japan or Europe in the extent provided in the preceding article, However, your personal data collected and processed for the purposes described above may in certain cases be transmitted to companies outside the European Union.
Some of these countries have an adequate level of data protection.
In other cases, please note that the transfers of your personal data to other entities outside the European Union are governed by the implementation of appropriate safeguards to ensure the confidentiality and security of the transferred data.
Havas Life Tokyo may, in this regard, conclude contractual clauses with the recipients of such data in accordance with the recommendations of the European Commission to ensure that appropriate safeguards are taken regarding the protection of said data. In addition, and where the legislation of the third country does not provide protection equivalent to that offered by the regulations, we shall ensure that additional measures are implemented to guarantee a level of protection of your personal data essentially equivalent to that provided for in the European Union or Japan and to ensure that this protection is effective. You are also advised that transfers of personal information outside the European Union are lawful if in particular (i) the transfer is necessary for the performance of a contract between the information subject and the data controller or for the implementation of pre-contractual measures taken at the request of the data subject, if (ii) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the information subject between the data controller and another natural or legal person, or if (iii) the information subject has given explicit consent to the proposed transfer, after having been informed of the risks that the transfer could entail for him or her due to the absence of an adequacy decision and appropriate safeguards.

8. Security and subcontracting

Havas Life Tokyo places particular importance on the security of your personal data.
Therefore, Havas Life Tokyo has implemented technical and organisational measures tailored to the nature of the personal data, in order to ensure the integrity and confidentiality of such personal data and to protect them against malicious intrusion, loss, alteration or disclosure to unauthorised third parties.
Nevertheless, the security and confidentiality of personal data depend on everyone’s best practices and you are encouraged to remain vigilant regarding this issue.
When Havas Life Tokyo uses a processor, we only disclose personal data to it after having obtained a commitment and guarantees from said processor regarding its ability to meet the security and confidentiality requirements and entered into a written contractual commitment with it.

9. Third-party websites and social networks

Havas Life Tokyo websites or services may provide links to third-party applications, products, services or websites to facilitate your browsing and for your information. If you access these links, you will leave the Website. Havas Life Tokyo does not control these third-party websites or their privacy and data protection practices, which may differ from ours. We do not finance or represent any of these third-party websites and accept no responsibility for their content or their practice in terms of personal data protection. Personal data you choose to provide via such websites, or which are collected by such third parties are not covered by Havas Life Tokyo Privacy Policy. We encourage you to review the privacy policy of any website with which you interact before allowing your personal data to be collected and used. We also provide links to social networks that allow you to share information with your own social networks and interact. When you use these links, information about you may be collected or shared. We encourage you to review the privacy policies of the social networks with which you interact, to find out the information that may be collected, used or shared by these websites. If you post, comment, indicate interests or share personal data in any public forum, social network, blog or any similar forum, please note that any personal information you post may be collected or used by other users of these forums and networks. In any event, Havas Life Tokyo may not be held liable for such third-party uses which are not its responsibility.

10. Cookie management

We use cookies on Havas Life Tokyo websites.
The management of cookies on the Website is the subject of a cookie policy available.

11. What are your personal information rights?

Havas Life Tokyo is particularly concerned about respecting the rights granted to you in connection with the data processing it implements, to guarantee fair and transparent processing with regard to the particular circumstances and context in which your personal information is processed.

Your right of access

In this respect, you have the right to obtain confirmation as to whether or not your personal information is being processed and when it is being processed. You have the right to request a copy of your data and information concerning:

・ the purposes of the processing
・ the categories of personal information concerned
・ the recipients or categories of recipients and, where applicable, if such disclosure were to be made, the international organizations to which the personal data have been or will be disclosed, in particular recipients established in third countries
・ where possible, the envisaged retention period of the Personal Data or, where this is not possible, the criteria used to determine that period
・ the existence of the right to request from the data controller rectification or erasure of your personal data the right to request a restriction of the Processing of your personal data and the right to object to such Processing
・ the right to lodge a complaint with a supervisory authority
・ information relating to the source of the personal information when they are not collected directly from you
・ the existence, where appropriate, of automated decision-making, including profiling, and, in the latter case, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing.

Your right to have your personal data rectified

You can ask us for your personal data to be corrected or completed if they are inaccurate, incomplete, ambiguous and/or outdated, as the case may be.

Your right to have your personal data erased

You can ask us to erase your personal data in the cases provided for by the regulations.
Please note that the right to erasure of personaldata is not a general right and that it can only be granted if one of the reasons provided for in the applicable regulations is present.

Your right to restrict your personal information processing

You may request the processing of your personal information to be restricted in the cases provided for by the regulations.

Your right to object to personal information processing

You have the right to object at any time, on grounds relating to your particular situation, to a processing operation concerning your personal information whose legal basis is the legitimate interest pursued by the data controller.
If you exercise such a right to object, we will ensure that we no longer process your personal data in relation to the processing operation concerned unless we can demonstrate that we can have compelling legitimate grounds for maintaining such processing operation. These grounds must override your interests and rights and freedoms, or the processing must be justified for the establishment, exercise or defence of legal claims.

Your right to data portability

You have the right to data portability with regard to your personal information. Please note that this is not a general right. Indeed, all the data of all processing operations are not prtable, and this right only concerns automated processing, excluding manual or paper processing operations.
This right is limited to processing operations whose legal basis is your consent or the performance of pre-contractual measures or a contract.

Your right to withdraw consent

When the data processing operations we implement are based on your consent, you can withdraw it at any time. We then stop processing your personal data without the previous operations to which you had given your consent being called into question.

Your right to lodge a complaint.

You have the right to lodge a complaint with the supervisory data protection authority in your country of residence, without prejudice to any other administrative or judicial remedy.

How to exercise your rights

You can exercise your right with Havas Life Tokyo:

At the e-mail address: contact-lifetokyo@havas.com
Or by post to: Toranomon Hills Business Tower 15F, 1-17-1 Toranomon, Minatoku, Tokyo, 105-6415 Japan

We will reply as soon as possible and in any event within one month of receipt of the request. We may, as necessary, extend this period by two months, taking into account the complexity and number of requests, and we will specifically inform you of this.

12. Changes to the privacy policy

Havas Life Tokyo reserves the right to amend this policy if necessary, for example, to comply with a change in law, regulations,practices and procedures or requirements imposed by data protection authorities. The new policy will be published on the Website.
Please check it regularly.
If you have any questions or comments about this policy, please contact.
contact-lifetokyo@havas.com whose contact details can be found in Article 11 above.
Last updated: Apr 2023.