Privacy Policy

Updated as of April 1, 2021

TOHO CO., LTD. (hereinafter referred to as "TOHO") shall handle Personal Information (as defined below) of its customers, shareholders, clients, job applicants and employees appropriately under the following privacy policy (hereinafter referred to as this ''Privacy Policy'').

  1. TOHO shall comply with relevant laws and regulations.

    1. TOHO shall comply with Japan's Act on the Protection of Personal Information (hereinafter referred to as the "APPI") and its rules and guidelines (hereinafter collectively referred to as the "Guidelines") issued by the Personal Information Protection Committee in Japan.
    2. TOHO shall also comply with its internal rules and contracts with clients, and handle Personal Information (the definition shall be subject to Article 2 (1) of the APPI, hereinafter the same) in a lawful and proper fashion.
    3. TOHO shall revise this Privacy Policy as appropriate in accordance with the enactment, revision or abolition of laws and regulations stated in (1) hereinabove in the future, and/or changes in the customary practice regarding the Personal Information inside and outside Japan.
  2. TOHO shall obtain Personal Information in a proper manner and use it only for limited purposes.

    1. TOHO shall use Personal Information within the scope of any of the following purposes:
      1. ①Purposes of use of customers' Personal Information;

        • For the reservation and sale of movie or theatrical tickets and other products, their delivery, and after-sales service thereof;
        • For the introduction and implementation of events such as previews and dress rehearsals
        • For the introduction of new works, new products and new services;
        • For leasing, repair and maintenance, etc. of real estate;
        • For the management of buildings and facilities (including the crime prevention and security thereof);
        • For the review and approval of registrations for membership service system, and providing therefor;
        • For the review and approval of subscriptions to e-mail delivery services, and providing therefor;
        • For responding to inquiries from customers about various products and/or services of TOHO and its affiliates, etc.;
        • For analysis, examination, improvement and development of various products and/or services; and/or
        • For the operation of various other products and/or services of TOHO.
      2. ②Purposes of use of shareholders' Personal Information;

        • For the exercise of their rights and fulfillment of shareholder's obligations under the Japan's Companies Act, etc.;
        • For providing for information on the business management of TOHO and its affiliates;
        • For providing for services such as shareholder benefits, etc.;
        • For the preparation and statistical processing of shareholders' data, according to accepted standards based on laws and regulations; and/or
        • For responding to inquiries from shareholders.
      3. ③Purpose of use of job applicants' Personal Information;

        • For recruitment activities, selection and various correspondence with job applicants.
      4. ④Purposes of use of Personal Information of employees (including retirees); and

        • For activities related to employment management (including such management of family members of employees, secondees and loan employees):
        • For activities related to payment of salaries, etc.;
        • For activities related to welfare benefits, etc.;
        • For activities related to health management, etc.;
        • For various procedures after retirement; and/or
        • For other procedures and various communications necessary in accordance with other laws and regulations.
      5. ⑤Purposes of use of Personal Information of any and all individuals stated in (i) through (v) above.

        • For business analysis and market research concerning TOHO's and its affiliates' movies, plays, real estate and other business.
        • For processing of statistical data that cannot identify individuals (and that does not fall into the "Anonymously Processed Information" as defined in Article 2 (9) of the APPI) and its analysis, etc.
        • For activities related to corporate social responsibility (CSR) of TOHO.
    2. In the case of using Personal Information for purposes not listed in (1) hereinabove, the purposes shall be announced separately or notified to the Principal (the definition shall be subject to Article 2 (8) of the APPI, hereinafter the same), and the Personal Information shall be handled within such purposes.
    3. If TOHO intends to use Personal Information beyond the scope of (1) and (2) hereinabove, TOHO shall obtain the consent from such Principal in advance. The Principal have the right to withdraw the consent at any time by the method separately designated by TOHO; provided, however, that the withdrawal of consent shall not affect the legality of processing conducted based on the consent before such withdrawal.
  3. TOHO shall comprehensively manage the safety of Personal Information.

    1. In order to prevent the loss, damage, illegal removal, outflow, falsification of Personal Information, TOHO shall establish internal regulations and take necessary and appropriate measures for safety management thereof.
    2. In order to ensure the safety of Personal Information, TOHO shall regularly conduct internal educations of officers and employees as well as conducting appropriate supervision thereof on a daily basis.
    3. TOHO shall take measures to prevent Personal Information from being leaked, by taking measures to restrict access to the company premises and information security measures.
    4. Personal Information that TOHO no longer needs to retain shall be deleted by disposing of documents containing Personal Data (the definition shall be subject to Article 2 (6) of the APPI, hereinafter the same) in an appropriate manner or by deletion by a method that may not be easily restored on the medium on which information is recorded.
  4. TOHO shall properly supervise outsourcing parties that TOHO provides Personal Information.

    When necessary, TOHO may delegate all or part of the work involving the handling of Personal Information to a third party. In this case, TOHO shall enter into a contract regarding appropriate handling of Personal Information with the third party, and then provide such Personal Information therewith to the extent that it is deemed necessary for the performance of the delegated work. In the event that the handling of Personal Information is so delegated, TOHO shall supervise such third party to ensure its proper handling of such Personal Information.

  5. TOHO may joint-use Personal Information.

    1. Within the scope of the purposes of use listed in Section 2 above, TOHO may utilize Personal Data such as name, sex, date of birth, address, telephone/fax number, e-mail address, purchase history, contract information, photographs and access information, jointly with its affiliates (http://www.TOHO.co.jp/company/group/index.html). In this case, TOHO shall be responsible for controlling said Personal Data.
    2. In addition to the above, TOHO may use Personal Information jointly with joint ventures or business partners (including, but not limited to, the movie production committees) when TOHO conducts its business in joint projects or with business partners. In these cases, TOHO shall in advance notify the Principal of (a) the categories of Personal Data to be jointly used, (b) the scope of the joint users, (c) the purposes for which the Personal Data is used by them and (d) the name of the individual or business operator responsible for the management of said Personal Data (or put these information in a place where the Principal can easily know thereto). If TOHO becomes the entity in charge of the management thereof, TOHO strives for the safe management of Personal Information by applying mutatis mutandis to the provisions of this Privacy Policy.
  6. Personal Information shall not be provided to third parties in principle.

    TOHO shall not disclose or provide Personal Information to any third party in a state in which the Principal may be identified, except in the following cases:

    1. ①Cases when providing to such third party as stipulated in Section 4 above;

    2. ②Cases in which the Principal has provided its consent;

    3. ③Cases of receiving a disclosure order from a court or other public institution; or

    4. ④Other cases as stipulated by laws and regulations.

  7. To ensure the accuracy of Personal Information.

    1. TOHO shall strive to keep Personal Information accurate and up to date.
    2. If there is a change in the Principal's Personal Information, the Principal should take a change procedure according to the method herein set forth as necessary.
    3. TOHO shall not be responsible for any inconveniences of communication from, or provision of services by, TOHO, due to a Principal's failure to take such change procedure.
  8. TOHO shall respond to requests for disclosure and correction of Retained Personal Data.

    1. When a Principal requests the disclosure of its own Retained Personal Data (the definition shall be subject to Article 2 (7) of the APPI, hereinafter the same), TOHO shall confirm whether the applicant is the Principal or not by requesting identity confirmation documents such as a driver's license, and then respond to such request; provided, however, that TOHO shall not disclose a whole or part thereof in the following cases:
      1. ①Cases in which there is a possibility of harming the Principal or third party's life, body, fortune or other rights and interests;

      2. ②Cases in which there is a possibility of interfering seriously with TOHO's implementing its business properly; and/or

      3. ③Cases of violating other laws or regulations than APPI

    2. When requested by a Principal's agent (legal representative or appointed agent) to disclose Retained Personal Data of the Principal, TOHO shall follow the same procedure as that for requests in Section 8 (1) above with respect to the agent. In this case, TOHO shall confirm the identity of the agent itself, and then respond to such request after confirming that the agent has legal authority as the Principal's agent by a letter of proxy etc.
    3. When a Principal or his/her agent requests the correction, addition or deletion of the Retained Personal Data (hereinafter collectively referred to as "Correction etc.") or the suspension or deletion thereof (hereinafter collectively referred to as "Suspension of Use etc."), the same procedure as described in Section 8 (1) or (2) above shall be followed and then TOHO shall carry out the Correction etc. or the Suspension of Use etc. within a reasonable period pursuant to the provisions of the APPI and Guidelines. Where such Correction etc. or Suspension of Use etc. is made pursuant hereto, TOHO may no longer be able to provide its services or products according to the Principal's request.
  9. Inquiries.

    1. TOHO shall accept inquiries regarding the handling of Personal Information, such as requests for the disclosure, Correction etc. or Suspension of Use etc. of the Retained Personal Data pursuant hereto, using the "inquiry" window at the top page.
    2. TOHO has stipulated individual terms and conditions or privacy policies (hereinafter collectively referred to as "Individual Policies") for each type of services to be provided and products to be sold. Key services and products offered or sold by TOHO are as follows:
      1. ①GODZILLA Brand Site

      2. ②TOHO Theatrical Dept. (purchase of theater tickets)

      3. ③Chanter Card (providing for services using membership card issued by "Hibiya Chanter," a shopping mall in Hibiya, Tokyo)

    3. In addition, each of TOHO's affiliate may establish separate Individual Policies depending on the purposes of use of Personal Information acquired from its customers. Please be sure to check the content of these Individual Policies according to the service to be used by customers.
    4. In the event of any conflict between the terms of this Privacy Policy and any terms of Individual Policies, the provisions of the Individual Policies shall prevail.
  10. Miscellaneous.

    1. This Privacy Policy shall be enacted in texts using both English language and Japanese language. In the event that there arise any doubts or controversies between English and Japanese expression, the Japanese texts shall prevail.
    2. This Privacy Policy shall be governed by and construed in accordance with the laws of Japan.
    3. All disputes and claims arising out of or relating to this Privacy Policy, the Website or Individual Policies shall be subject to the exclusive jurisdiction of the Tokyo District Court for the first instance.

Privacy Policy for California Residents

This Privacy Policy applies to all communications and business transactions by TOHO CO., LTD. (hereinafter referred to as "TOHO" or "we", "us"), that involve any individual’s resident in California (hereinafter referred to as "consumers" or "you"). We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (hereinafter referred to as “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Policy.

Information TOHO Collects

TOHO collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (hereinafter referred to as "personal information"). Personal information does not include:

  1. Publicly available information from government records.
  2. Deidentified or aggregated consumer information.
  3. Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, TOHO has collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected

A.Identifiers.

a)A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address.

[YES]

b)Account name, Social Security number, driver's license number, passport number, or other similar identifiers.

[NO]

B.Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.
[NO]

C.Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). [NO]

D.Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. [NO]

E.Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
[NO]

F.Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. [YES]

G.Geolocation data.

Physical location or movements. [YES]

H.Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information. [NO]

I.Professional or employment- related information.

Current or past job history or performance evaluations. [NO]

J.Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. [NO]

K.Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. [NO]

TOHO obtains the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms or documents you complete or products and services you purchase or websites you access.

TOHO shall use Personal Information only for limited purposes.

TOHO may use or disclose the personal information within the scope of any of the following purposes:

  • To fulfill or meet the reason you provided the information.
    For example, if you share your name and contact information to request a price quote or ask a question about our products or services, TOHO will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, TOHO will use that information to process your payment and facilitate delivery. TOHO may also save your information to facilitate new product orders or process returns.
  • To visualize the consumer figure in our website and analyze their motive in our services through the use of the third-party analytical tool, Google Analytics.
    TOHO uses Google Analytics cookies to collect information specified above for better understanding our customers. The data TOHO collects is anonymized not to identify any individuals. To see an overview of privacy at Google and how this applies to Google Analytics, visit Google Privacy and Terms and Google Analytics Terms of Service. You can use your browser settings to withdraw your consent to TOHO’s use of cookies at any time and delete cookies that have already been set.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TOHO’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about TOHO’s consumers is among the assets transferred.

TOHO will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

TOHO may joint-use Personal Information

TOHO may disclose your personal information to a third party for a business purpose. When TOHO discloses personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

TOHO shares your personal information with the following categories of third parties:

  • Service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, TOHO has disclosed the following categories of personal information for a business purpose:

  • Category A(a): Identifiers.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.

TOHO discloses your personal information for a business purpose to the following categories of third parties:

  • Service providers.

Sales of Personal Information

In the preceding twelve (12) months, TOHO has not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that TOHO discloses certain information to you about our collection and use of your personal information over the past 12 months. Once TOHO receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information TOHO collected about you.
  • The categories of sources for the personal information TOHO collected about you.
  • TOHO’s business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom TOHO shares that personal information.
  • The specific pieces of personal information TOHO collected about you (also called a data portability request).
  • If TOHO sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    ◾️ sales, identifying the personal information categories that each category of recipient purchased; and

    ◾️ disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

TOHO does not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

You have the right to request that TOHO deletes any of your personal information that we collected from you and retained, subject to certain exceptions. Once TOHO receives and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

TOHO may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which TOHO collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  3. Debug products to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with TOHO.

  8. Comply with a legal obligation.

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

TOHO does not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to the service provider TOHO International, Inc on the behalf of TOHO by either:

  • Calling us at 855-611-0426
  • Emailing us at privacy@tohointl.com
  • Writing to us at:
    Toho International, Inc.
    Attn: Ms. Masako Takahashi
    2029 Century Park East, Suite 1140
    Los Angeles, California 90067

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, TOHO must have received a written verifiable request from you designating that agent by name. Such a request may be sent by email.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows TOHO to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:

    ◾️ Two items of information about you, other than your name, which may include your address, telephone number, email address.

  • Describe your request with sufficient detail that allows TOHO to properly understand, evaluate, and respond to it.

TOHO cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with TOHO.

TOHO will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

TOHO endeavors to respond to a verifiable consumer request within forty-five (45) days of its receipt. If TOHO requires more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with TOHO, we will deliver our written response to that account. If you do not have an account with TOHO, we will deliver our written response by e-mail.

Any disclosures TOHO provides will only cover the 12-month period preceding the verifiable consumer request's receipt. The response TOHO provides will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, TOHO will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

TOHO does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If TOHO determines that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the legal right to direct businesses to not sell your personal information at any time (the "right to opt-out"). As stated earlier in this Policy, TOHO does not sell any personal data to third parties so the legal right to opt-out does not apply to our Company.

Non-Discrimination

TOHO will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, TOHO will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

TOHO reserves the right to amend this Policy at our discretion and at any time. When TOHO makes changes to this Policy, we will post the updated Policy on our website and update the Policy's effective date.

Inquiries

If you have any questions or comments about this Policy, the ways in which TOHO collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as below. TOHO International, Inc will receive your inquiry as a service provider and transfer it to TOHO.

  • Calling us at 855-611-0426
  • Emailing us at privacy@tohointl.com
  • Writing to us at:
    Toho International, Inc.
    Attn: Ms. Masako Takahashi
    2029 Century Park East, Suite 1140
    Los Angeles, California 90067

Miscellaneous

This Privacy Policy shall be enacted in texts using both English language and Japanese language. In the event that there arise any doubts or controversies between English and Japanese expression, the Japanese texts shall prevail.