Privacy Policy

CLINIC TEN SHIBUYA (hereinafter referred to as the “Clinic”) recognizes the importance of personal information, sensitive personal information and other information relating to users (collectively, the “Personal Information, etc.”) of the medical services it provides, including the provision of medical information (collectively, the “Services”). In order to ensure thorough protection of such Personal Information, etc., the Clinic complies with the Act on the Protection of Personal Information and other related laws and regulations, as well as guidelines issued by the relevant supervisory authorities (collectively, the “Personal Information Protection Laws”). The Clinic hereby establishes this Privacy Policy as follows and strives to appropriately protect the Personal Information, etc.

Personal Information and Sensitive Personal Information

“Personal Information” means information about an individual which can identify a specific individual by name, date of birth, address, identification number, symbol, code, image, voice or other description contained in such information (including information that cannot by itself identify a specific individual but which can be readily collated with other information and thereby identify a specific individual), information contained on an Individual Number Card or notification card, and any other information that is regulated or protected as “personal information” or “specific personal information” under applicable laws and regulations.

“Sensitive Personal Information” means personal information that contains descriptions, etc. designated by cabinet order as requiring special care in its handling so as not to cause unfair discrimination, prejudice or other disadvantages (including, without limitation, medical history recorded in medical records, medical information and dispensing information about the user’s physical condition, symptoms and treatment that the Clinic learns in the course of providing medical care and dispensing, results of health examinations and details of health guidance, information concerning disabilities, and facts regarding damage suffered as a result of crime).

Basic Policy on the Management of Personal Information

The Clinic manages Personal Information, etc. appropriately in accordance with the following basic policy: The collection, use and provision of Personal Information, etc. shall be carried out in an appropriate manner. The Clinic shall take measures to prevent unauthorized access to, loss of, or leakage of Personal Information, etc. The Clinic shall comply with the Personal Information Protection Laws, relevant norms and internal rules concerning Personal Information, etc. The Clinic shall strive for continuous improvement to ensure the protection of Personal Information, etc. If any problem arises in relation to the protection of Personal Information, etc., the Clinic shall promptly implement corrective measures, including making necessary reports to the relevant supervisory authorities.

Purposes of Use

The Clinic uses the collected Personal Information, etc. for the following purposes: [Purposes necessary for providing medical care to users] (1) Uses within the Clinic Provision of medical services to users by the Clinic Medical insurance administration Among the Clinic’s administrative and operational tasks relating to users: Accounting and bookkeeping Reporting of medical accidents and similar incidents Improvement of medical services provided to the relevant user Provision of information to users by email, social networking services, postal mail or other means regarding medical services provided by the Clinic and medical-related products sold by the Clinic (2) Uses involving provision of information to third parties Among the medical services provided to users by the Clinic: Coordination with other hospitals, clinics, midwifery homes, pharmacies, home-visit nursing stations and long-term care service providers Responding to inquiries from other medical institutions, etc. Seeking opinions or advice from external physicians and other professionals in connection with a user’s medical care Outsourcing of specimen testing and other operations Explanations of a user’s medical condition to family members and others Among medical insurance administration: Outsourcing of insurance administration Submission of receipts (claims) to examination and payment organizations Responding to inquiries from examination and payment organizations or insurers Notifying employers and other organizations of the results of health examinations, etc., when such examinations are conducted under commission from such employers or other organizations Consulting with or reporting to professional bodies related to medical care, insurance companies and other parties in connection with medical malpractice liability insurance and similar matters [Other purposes of use] (1) Uses within the Clinic Among the administrative and operational tasks of medical institutions: Preparation of basic data for maintaining and improving medical services and operations Cooperation in clinical training for students conducted within medical institutions Case studies conducted within medical institutions (2) Uses involving provision of information to third parties Among the administrative and operational tasks of medical institutions, provision of information to external audit organizations

Provision of Personal Information to Third Parties

The Clinic may provide Personal Information, etc. to third parties in the following cases: When disclosure is requested by a court, public prosecutor’s office, police, tax office, bar association or other organization having similar authority When disclosing information to financial institutions, credit card companies, collection agencies or other settlement service providers for the purpose of settling medical fees and other payments payable to the Clinic When outsourcing all or part of the Clinic’s operations to a third party When disclosing information to persons who owe a duty of confidentiality to the Clinic When necessary for the exercise of the Clinic’s rights When disclosing information to a successor entity in the event of business succession due to merger, business transfer or other reasons When permitted under the Personal Information Protection Laws or other applicable laws and regulations (including, without limitation, the Medical Care Act, the Long-Term Care Insurance Act and the Act on the Prevention, etc. of Child Abuse)

Provision of Personal Information to Third Parties

1. Except as permitted by the Act on the Protection of Personal Information or other laws and regulations, we will not provide personal information to a third party without obtaining the prior consent of the user, except in the following cases: (1) When it is necessary to protect a person’s life, body or property and it is difficult to obtain the consent of the person. (2) When it is particularly necessary for improving public health or promoting the sound growth of children and obtaining the consent of the person is difficult. (3) When it is necessary to cooperate with a national or local government or its entrusted person to execute the affairs prescribed by laws and regulations and obtaining the consent of the person is likely to hinder the execution of such affairs. (4) When the following matters have been notified or announced in advance and we have submitted a notification to the Personal Information Protection Commission: (i) That the purpose of use includes provision to a third party; (ii) The data items to be provided to the third party; (iii) The means or method of providing to the third party; (iv) That we will stop providing personal information to the third party upon the person’s request; and (v) The method for accepting the person’s request. 2. Notwithstanding the provisions of the preceding paragraph, the following cases shall not fall under provision to a third party: (1) When we outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use; (2) When personal information is provided as a result of business succession due to merger or other reasons; (3) When personal information is jointly used with a specific person, and the Company notifies the person in advance or makes it easy for the person to know to that effect, including the items of personal information to be jointly used, the scope of joint users, the purpose of use of the users and the name of the person responsible for the management of such personal information.

Cookies, etc.

The Clinic may use technologies such as cookies, DoubleClick cookies and web beacons to obtain log files relating to users’ use of the Services, including information such as the model name of the user’s communication device, OS version, language settings, region settings, time zone settings, IDFA (advertising identifier for iOS), IP address, access date and time, browsing history and behavioral history; provided, however, that information that can directly identify a specific individual is excluded.

Changes to this Privacy Policy

The Clinic may revise this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted on the Clinic’s website or otherwise made available for viewing by users. If a user uses the Services after the changes to this Privacy Policy have become effective, the user shall be deemed to have accepted and agreed to the revised Privacy Policy.

Disclosure, Correction, etc. of Personal Information

If the Clinic receives a request from a user for disclosure, correction, addition or deletion of his or her personal information, the Clinic will promptly conduct an investigation and respond appropriately without delay. Requests under the preceding paragraph and other inquiries regarding users’ personal information should be directed to the contact point below:

Contact Details

CLINIC TEN SHIBUYA Address: 2F, Nichiei Building, 2-20-12 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan Contact for inquiries regarding personal information E-mail: info@clinicten.jp