PRIVACY POLICY
Corporate Policy
SMITE PICTURES LLC. (hereinafter referred to as the "Company") recognizes that the protection of personal information is an important social responsibility as a business engaged in the planning, direction, and production of television programs and other audiovisual content.
The Company has established this Privacy Policy regarding personal information obtained from its customers, business partners, performers, interviewees and filming collaborators, job applicants, officers and employees, and other related parties, and is committed to the appropriate collection, use, management, and protection of such personal information.
01 Scope
This Privacy Policy applies to personal information handled in connection with the Company's business activities and through the websites and other services operated by the Company.
02 Legal Compliance and Collection
The Company shall comply with the Act on the Protection of Personal Information of Japan, as well as all other applicable laws, regulations, guidelines, contractual obligations, and internal rules relating to the protection of personal information.
When collecting personal information, the Company shall specify the purpose of use to the greatest extent possible and shall collect such information lawfully, fairly, and only to the extent necessary for its business operations.
The Company shall not acquire personal information through deception or any other wrongful means, nor shall it use personal information in any manner that facilitates or encourages unlawful or improper conduct.
Except where otherwise permitted by applicable law, the Company shall not acquire Special Care-Required Personal Information without obtaining the prior consent of the individual concerned.
03 Use of Personal Information
The Company shall use the personal information it acquires only to the extent necessary to achieve the following purposes.
(1) Operations Related to Audiovisual and Content Production
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Planning, research, investigation, interviews, location scouting, filming, recording, editing, broadcasting, distribution, and promotion of television programs, online videos, advertisements, music videos, and other audiovisual content.
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Requesting and communicating regarding appearances, interviews, filming, and other forms of cooperation.
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Communicating with performers, interview subjects, filming collaborators, production staff, and other related parties, and managing production progress.
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Arranging filming locations, equipment, transportation, accommodations, and other resources necessary for production.
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Confirming rights, obtaining permissions, administering contracts, and processing rights related to production works.
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Introducing the Company's production achievements on the Company's website, social media accounts, sales materials, and similar media within the scope of the permissions obtained.
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Other operations incidental to audiovisual and content production.
(2) Responses to Customers and Business Partners
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Responding to inquiries, consultations, and requests.
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Providing proposals, quotations, materials, and conducting meetings.
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Entering into and performing contracts.
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Communicating as necessary for business operations.
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Managing invoicing, payments, remuneration, and other commercial transactions.
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Maintaining and administering business relationships.
(3) Recruitment Activities
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Accepting employment applications.
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Communicating with applicants.
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Conducting document screening, interviews, and other recruitment selection procedures.
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Determining and notifying recruitment results.
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Completing onboarding procedures.
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Reviewing and improving recruitment activities.
(4) Management of Officers and Employees
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Personnel administration, labor management, payroll, employee benefits, occupational health and safety, and other employment-related administration.
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Business communications and emergency response.
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Procedures required by applicable laws and regulations.
(5) Business Operations and Legal Compliance
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Improving the Company's services and business operations.
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Preventing and responding to fraud, nuisance acts, infringement of rights, and other misconduct.
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Responding to complaints, disputes, and legal claims.
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Responding to requests from laws and regulations, administrative authorities, courts, and other public authorities.
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Other actions necessary for the proper operation of the Company's business.
Where separate purposes of use or conditions of use are specified in an individual contract, consent form, recruitment guidelines, or other written document, the Company shall handle personal information in accordance with such provisions.
If the Company intends to use personal information beyond the purposes set forth above, it shall obtain the prior consent of the individual concerned unless otherwise permitted by applicable law.
04 Management of Personal Information and Security Measures
The Company shall endeavor to keep the personal information it handles accurate and up to date to the extent necessary for achieving the purposes of use.
To prevent the leakage, loss, damage, alteration, unauthorized access, unauthorized use, or any other incident involving personal information, the Company shall implement necessary and appropriate security control measures commensurate with the scale of its business and the manner in which personal information is handled.
The security control measures implemented by the Company include, but are not limited to, the following:
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Establishing a person responsible for the handling of personal information and an appropriate management framework.
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Limiting the persons authorized to handle personal information and defining the scope of such handling.
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Providing education and supervision to officers and employees regarding the protection of personal information.
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Properly managing the storage, removal, and disposal of documents, devices, recording media, and other materials containing personal information.
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Appropriately managing access authority, authentication methods, passwords, and related security controls.
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Implementing measures against unauthorized access, malware, and other external threats.
Retaining personal information only for the period necessary to achieve the purposes of use and, when such information is no longer required, promptly deleting or disposing of it by means that make restoration difficult, unless retention is required by applicable laws, regulations, or contractual obligations.
05 Supervision of Employees and Service Providers
Where the Company permits its directors, officers, employees, or any other persons engaged in its business operations to handle personal information, the Company shall provide the necessary education and supervision to ensure that such personal information is managed appropriately.
The Company may outsource all or part of its operations, including audiovisual production, filming, editing, data storage, system administration, payment processing, and other related services, to external service providers, and may entrust them with the handling of personal information to the extent necessary for the performance of such operations.
In such cases, the Company shall carefully select service providers capable of handling personal information appropriately, enter into the necessary contractual arrangements with them, and exercise necessary and appropriate supervision over such service providers.
06 Provision of Personal Data to Third Parties
The Company shall not provide personal data to any third party without obtaining the prior consent of the individual concerned, except where any of the following applies:
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Where required by applicable laws or regulations.
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Where it is necessary to protect the life, body, or property of an individual and obtaining the consent of the individual is difficult.
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Where it is particularly necessary for the improvement of public health or the sound development of children, and obtaining the consent of the individual is difficult.
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Where it is necessary to cooperate with a national government agency, a local government, or a person entrusted by such agency or government in carrying out duties prescribed by law, and obtaining the consent of the individual is likely to impede the performance of such duties.
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Where personal data is provided in connection with the succession of the Company's business.
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Where otherwise permitted by applicable laws or regulations.
Where it is necessary to provide personal data to broadcasters, clients, distribution platform operators, or other related parties for the purposes of production, broadcasting, distribution, or similar activities, the Company shall, except where such provision constitutes outsourcing or is otherwise permitted by applicable law, obtain the prior consent of the individual concerned after clearly informing the individual of the purpose of the provision and other necessary matters.
07 Requests Regarding Personal Data
The individual concerned or his or her legally authorized representative may, in accordance with applicable laws and regulations, request the Company to take any of the following actions with respect to the individual's personal information retained by the Company:
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Notification of the purpose of use.
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Disclosure of retained personal data.
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Disclosure of records concerning provision to third parties.
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Correction, addition, or deletion of personal data.
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Suspension of use or erasure of personal data.
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Suspension of the provision of personal data to third parties.
If you wish to make any such request, please contact the inquiry desk set forth at the end of this Privacy Policy.
Upon confirming that the request has been made by the individual concerned or his or her legally authorized representative, the Company shall respond within a reasonable period and to a reasonable extent in accordance with applicable laws and regulations.
Details regarding identity verification procedures, required documentation, and other procedural requirements will be provided when the request is received.
Please note that the Company may be unable to comply with a request where it is not legally obligated to make a disclosure or take the requested action. In such cases, unless notification is not required by applicable law, the Company will inform the requester of that fact and the reason therefor.
08 Responses to Complaints and Personal Data Incidents
The Company shall endeavor to respond appropriately and promptly to complaints and inquiries regarding the handling of personal information.
In the event of any leakage, loss, damage, or other incident involving personal data, the Company shall take the necessary measures to prevent the expansion of damage, investigate the facts and causes, identify the scope of the impact, and implement measures to prevent recurrence.
Where reporting or notification is required under applicable laws and regulations, the Company shall appropriately report such incident to the Personal Information Protection Commission and other relevant authorities, and notify the individual concerned as required.
09 Personal Information Handled for Journalism and Literary Purposes
With respect to the Company's operations involving the handling of personal information for journalistic or literary purposes, the Company shall give due consideration to freedom of expression and the free flow of information, while taking necessary measures to ensure the proper acquisition of personal information, the implementation of appropriate security controls, the handling of complaints, and other necessary measures so as not to unjustifiably infringe upon the rights and interests of individuals.
10 Amendments to this Privacy Policy
The Company may amend this Privacy Policy from time to time in response to amendments to applicable laws and regulations, changes in its business operations, changes in the methods of handling personal information, or other relevant circumstances.
Any revised Privacy Policy shall become effective upon being published on the Company's website or otherwise announced by an appropriate method.
11 Contact Information Regarding Personal Information
For inquiries regarding the handling of personal information, requests for disclosure or other rights, complaints, or consultations, please contact:
Business Name
SMITE PICTURES LLC.
Representative Member
Kenji Fujishiro
Address
Intellix Aoyama-dori Building 301
2-9-11 Shibuya, Shibuya-ku, Tokyo 150-0002
Japan
Effective Date: July 10, 2026
SMITE PICTURES LLC.