Social Media Privacy Policy
SNS Marketing Privacy Policy
Effective Date: May 28, 2025
Last Updated: June 4, 2025
This Policy applies to the processing of personal data by TOHO Global Co., Ltd. (hereinafter referred to as “TG”) and Toho Entertainment Asia Pte. Ltd. (hereinafter referred to as “TEA”; collectively, ‘we’ or “our”) in accordance with applicable data protection laws, in connection with the collection of personal data through the operation of social media accounts and the conduct of social media campaigns and other marketing activities.
This Policy sets forth the basis for the processing of personal data collected by the Company from social media users (as defined below), applicants for social media campaigns, or those considering applying (collectively referred to as “applicants”) in connection with the operation of the Company's social media accounts and the social media campaigns and other marketing activities conducted by the Company. Please read this Policy carefully and ensure that you fully understand it.
In the event of any conflict between the provisions of this policy and those of our other privacy policies, the provisions of this policy shall prevail to the extent of such conflict.
1. Categories, Methods of Collection, and Purpose of Processing of Collected Personal Data
We directly collect and process the following categories of personal data from Social Media Users or Applicants for our Social Media campaigns or other marketing activities, for the purposes listed below:
(１) For the operation of our Social Media accounts
Social Media account names, full names, gender, date of birth, addresses, profile images, followers, content of posts, comments, replies, likes, mentions, tags, etc. (“Posts”), and the content of interactions with Social Media Users through Posts, in relation to visitors to our Social Media accounts, followers of our Social Media accounts, and Social Media users who make Posts concerning our accounts or posts thereon (collectively “Social Media Users”).
(２) For conducting campaigns related to our products or services and delivering prizes to winners
Social Media account names, full names, gender, date of birth, addresses, phone numbers, and email addresses of Applicants, as well as the content of communication with prize winners.
(３) For conducting other marketing activities related to our products or services
Social Media account names, full names, gender, date of birth, addresses, profile images, followers, and content of Posts of Social Media Users or Applicants, as well as the content of interactions with Social Media Users through Posts, access history to our website, and the content of communication with prize winners.
(４) For responding to inquiries from Social Media Users or Applicants
In addition to the information listed in items (1) through (3) above, information concerning the content of inquiries from Social Media Users or Applicants, as well as our related communication with Social Media Users or Applicants.
(５) For complying with applicable laws or responding to court orders and legal procedures
The information listed in items (1) through (4) above.
In addition, we may collect the personal data listed in items (1) through (5) above using the following methods:
① We may access the profiles and Posts on Social Media accounts of Social Media Users.
② Applicants input their personal data into an application form when applying for a campaign conducted through our Social Media accounts.
③ We send a link to a personal data input form via direct message to the winners of campaigns conducted through our Social Media accounts, who then access the link and enter their personal data into the input form.
④ Social Media Users or Applicants make inquiries to us via direct messages.
⑤ We collect access history of our websites when Applicants access websites linked to the Social Media campaign.
Please note that providing certain personal data may be necessary to apply for our campaigns and receive prizes. While Applicants may refuse to provide us with personal data, this may limit their ability to apply, receipt of prizes, etc.
2. Legal Basis for Processing Personal Data
If we are required to process the personal data of Social Media Users or Applicants on a legal basis (including any other similar concepts recognized under applicable data protection laws; the same shall apply hereunder) under applicable data protection laws, we will process the personal data in accordance with the legal bases set forth below:
(１) Contract: If we need to process the personal data of an Applicant (excluding those considering applying; the same shall apply below in (1)) in order to fulfil a contract entered into with the Applicant or to implement measures in response to the Applicant’s request prior to entering into the contract.
(２) Legitimate interests: If the processing of personal data of Social Media Users or Applicants is necessary for the legitimate interests pursued by us or a third party (e.g., responding to inquiries from Social Media Users or Applicants), and such interests are not overridden by the interests or fundamental rights of the Social Media Users or Applicants.
(３) Consent: If we have obtained the consent of Social Media Users or Applicants to process their personal data.
(４) Legal obligations: If it is necessary to process the personal data of Social Media Users or Applicants to comply with our legal obligations.
The legal basis on which we rely for each purpose of processing the personal data listed in Section 1 above is as follows:
① For the operation of our Social Media accounts: Legitimate interests or consent
② For conducting campaigns related to our products or services and delivering prizes to winners: Contract or consent
③ For conducting other marketing activities related to our products or services: Legitimate interests or consent
④ For responding to inquiries from Social Media Users or Applicants: Contract, legitimate interests, or consent
⑤ For compliance with applicable laws, or in response to court orders and legal procedures: Legitimate interests or legal obligations
3. Disclosure of Personal Data
Within the scope of the processing purposes listed in Section 1 above, we may disclose the personal data of Social Media Users or Applicants to the following recipients:
(１) Service Providers:
We may disclose personal data concerning Social Media Users or Applicants to third-party service providers that perform specific services, such as contractors operating our Social Media accounts or campaigns, IT service providers, and delivery service providers responsible for delivering prizes.
(２) Employees:
We may disclose personal data concerning Social Media Users or Applicants to our employees with the authority and necessity to access to such personal data.
4. Transfer of Personal Data to Foreign Countries
Personal data concerning Social Media Users or Applicants may be transferred to third parties located outside the countries or regions where the Social Media Users or Applicants are located. If we transfer such personal data to such third parties, we will comply with applicable data protection laws by taking measures such as ensuring one of the following or obtaining the consent of the Social Media Users or Applicants:
(１) The country or region to which the personal data is transferred has been designated as ensuring an adequate level of protection for the rights and freedoms of Social Media Users or Applicants with respect to personal data under applicable data protection laws.
(２) The third party has entered into an agreement with us concerning the transfer of personal data, as required by applicable data protection laws.
Social Media Users or Applicants may obtain and confirm further details regarding the protections in place when their personal data is transferred outside the countries or regions where Social Media Users or Applicants are located by contacting us using the contact information provided in Section 11 below.
5. Joint Use of Personal Data
Within the scope of the purposes of use listed in Section 1 above, we may jointly use personal data concerning Social Media Users or Applicants listed in Section 1 above, such as Social Media account names, names, and addresses, with our group companies (listed at: https://www.toho.co.jp/company/group) in accordance with the Act on the Protection of Personal Information of Japan, with TG as the party responsible for managing such joint use.
6. Security Control Measures
(１) We establish internal rules and implement other necessary and appropriate measures to prevent the loss, damage, unauthorized external transfer, leakage, alteration, or other misuse of personal data.
(２) We provide ongoing internal training to our officers and employees to ensure the security control of personal data.
(３) We implement security control measures for personal data, such as internal access restrictions and information security measures, and strive to prevent the leakage of personal data.
(４) We appropriately supervise third-party contractors, officers, and employees who process personal data.
Further details regarding the security control measures we implement for personal data processing can be obtained and confirmed by contacting us using the contact information provided in Section 11 below.
7. Storage Period for Personal Data
We will retain personal data concerning Social Media Users or Applicants only for the period necessary to fulfill the purpose of using such personal data. Specifically, the storage periods are as follows:
(１) For Social Media account names, full names, gender, date of birth, addresses, phone number, email address, profile images, followers, and content of Posts, as well as the content of interactions with Social Media Users, access history to our websites, and the content of communication with prize winners: One (1) year from the date of collection.
(２) For information related to inquiries from Social Media Users or Applicants: One (1) year from the date of receipt.
However, if a longer storage period is required by applicable laws, we will retain the relevant personal data for the period required by such laws.
8. Ensuring Accuracy of Personal Data
(１) We strive to manage the personal data concerning Social Media Users or Applicants accurately and in an up-to-date manner.
(２) If there are any changes to the personal data concerning Social Media Users or Applicants, please complete the relevant procedure for updating personal data by contacting us using the contact information provided in Section 11 below.
(３) Please understand that we cannot be held liable for any inability to provide communication or services due to a failure to complete the procedure for updating personal data.
9. Rights of Social Media Users or Applicants
Social Media users or Applicants have several legal rights concerning the personal data held by us. These rights may vary depending on the data protection laws applicable to the location of the Social Media Users or Applicants and the relationship between Social Media users or Applicants and us, but typically include:
(１) The right to obtain information regarding the processing of personal data concerning Social Media Users or Applicants, and the right to access the personal data that we hold concerning Social Media Users or Applicants.
(２) The right to request that we correct personal data concerning Social Media Users or Applicants if it is inaccurate or incomplete.
(３) The right to request that we delete personal data concerning Social Media Users or Applicants under certain circumstances.
(４) The right to request that we restrict the processing of personal data under certain circumstances.
(５) The right to object to our processing of personal data concerning Social Media Users or Applicants.
(６) The right to receive personal data in a structured, commonly used, and machine-readable format and/or to request that we directly transfer their personal data to a recipient, to the extent technically feasible.
(７)The right to withdraw consent at any time if the processing of personal data concerning Social Media Users or Applicants is based on consent; provided, however, that such withdrawal does not affect the legality of any processing carried out prior to the withdrawal.
Social Media Users or Applicants may exercise the rights set forth above by contacting us using the contact information provided in Section 11 below. If Social Media Users or Applicants believe we have violated their rights, they may also lodge a complaint with the relevant data protection authority.
10. Personal Data of Minors
We may process personal data of minors who are thirteen (13) years of age or older. If consent from a custodial parent or other legal representative of the minor is required under applicable data protection laws for the processing of such personal data, we will verify the age and obtain such consent from the custodial parent or other legal representative when communicating with Social Media Users or Applicants.
11. Our Contact Information
If you have any inquiries regarding this Policy, the rights of Social Media Users or Applicants, or other matters related to personal data protection, please contact us using the contact information below:
TOHO Global Co., Ltd.
Address: 1-2-2 Yurakucho, Chiyoda-ku, Tokyo, Japan
Contact: tg_support_privacy@toho.co.jp
President and Representative Director : Koji Ueda
Toho Entertainment Asia Pte. Ltd.
Address: 1 Marina Boulevard, One Marina Boulevard, #20-00, Singapore 018989
Contact: tea_support_privacy@tohoea.com.sg
CEO: Koji Ueda
12. How This Policy May Be Revised
We may revise this Policy from time to time. The “Date of Establishment” or “Last Revised Date” noted at the head of this Policy indicates the date when it was established or most recently revised. Revisions to matters that require notification or consent under applicable data protection laws will become effective at the time of notification or obtaining consent, while all other revisions will become effective at the time the revised Policy is posted.
