Privacy Policy for DNP ID Service Provider Business
This Privacy Policy for the DNP ID Service Provider Business (the "Privacy Policy") explains how Dai Nippon Printing Co., Ltd. (the "Company"), whose registered address is 1-1-1 Ichigaya-Kagacho, Shinjuku-ku, Tokyo 162-8001, Japan, registration number 5011101012069, and whose direct contact channel is the inquiry form available at https://alldnp.my.site.com/CaseManagement/?id=IFM-01089, collects, uses, shares, retains and protects Personal Data in connection with the identity-linkage, identifier-issuance and statistical-analysis services that it provides as an independent identity service provider between ID Wallets and connected services (the "Service"). The Company acts as a controller of personal data in connection with the Service.
"Personal Data" means any information relating to an identified or identifiable individual that constitutes personal information or personal data under applicable data protection laws.
1. Application
This Privacy Policy applies, regardless of the User’s place of residence, to the Company’s processing of Personal Data in connection with the Service. An applicable regional annex may supplement or amend this Privacy Policy. If there is any inconsistency between this Privacy Policy and an applicable regional annex, the regional annex will prevail to the extent of the inconsistency.
2. Personal Data We Collect
The Company may collect the following Personal Data directly from Users or from ID Wallet providers, connected-service providers and other parties involved in providing the Service. The Personal Data actually collected varies depending on the ID Wallet and connected service used by the User, the functions of the Service and the User’s settings.
(1) Information derived from digital credentials obtained from an ID Wallet: CNF claims including public-key information, passport expiry date, passport issuing country, nationality, date of birth and gender, as necessary to verify the authenticity, validity and attributes of a digital credential or digital passport.
(2) Information not obtained from an ID Wallet: the Company does not obtain from the ID Wallet the User’s name, passport number, passport issue date, facial image, signature, email address, phone number or other information that directly identifies the User, unless otherwise specifically disclosed for an individual service and supported by an appropriate legal basis under applicable law.
(3) Identifiers and linkage data issued or generated by the Company: session IDs, system linkage IDs, identifiers relating to authentication and linkage, authentication results, consent status, linkage date and time, and records of linkage between systems.
(4) Service-usage data obtained from connected services: information concerning the purchase, application, use or cancellation of products, tickets, reservations, coupons or other services, including the date, time, place and status of use and other service-usage information.
(5) Location and mobility data: where the User permits the use of location data or where such data is provided by a connected service, location, latitude/longitude, acquisition date and time, current-location display information, travel route and other information relating to location or movement.
(6) Inquiry-related data: information provided in inquiries, complaints, data-subject requests or other communications with the Company, and records of the Company’s responses.
(7) Data processed for analytics: system linkage IDs, limited attribute data, service-usage data, location and mobility data, and the dates and times associated with those data, which the Company may combine to the extent necessary for each service for statistical analysis and service improvement.
Where Personal Data is identified as necessary for a particular function, failure to provide it may prevent the Company from providing all or part of the Service. Other Personal Data is optional unless otherwise indicated at the time of collection.
3. Purpose of Use of Personal Information
The Company processes the Personal Data described above for the following purposes:
(1) To provide and operate the Service, connect with ID Wallets, authenticate Users, verify attributes, manage sessions, issue and manage system linkage IDs and securely link connected services.
(2) To use limited attributes derived from a digital passport for authentication, eligibility or attribute verification and fraud prevention.
(3) To create and use statistics, analyze usage trends, improve and assure the quality of the Service and plan or develop new functions using connected-service usage data and location or mobility data.
(4) To respond to inquiries, complaints and incidents, maintain the Service, and notify Users of important matters or changes to this Privacy Policy.
(5) To secure the Service, detect and prevent fraud or abuse, conduct audits, establish, exercise or defend legal claims and comply with applicable laws and lawful requests.
(6) To share Personal Data and transmit information externally as described in Sections 4 and 5.
The Company does not make decisions based solely on automated processing, including profiling, that produce legal effects concerning Users or similarly significantly affect Users.
Where the Company intends to further process Personal Data for a purpose other than that for which the Personal Data was collected, the Company will, prior to such further processing, provide the User with information regarding that other purpose and any other information required under applicable law. Where consent is required under applicable law, the Company will obtain such consent.
4. Sharing of Personal Data
The Company may share Personal Data as follows:
(1) With connected-service providers, to the extent necessary to provide and operate the Service. In principle, the Company provides only a session ID and a system linkage ID issued by the Company. For my route, the Company provides Toyota Financial Services Corporation in Japan with a session ID and system linkage ID for service integration and provision of my route.
(2) With professional advisers, public authorities or parties to a proposed or completed business reorganization or transfer, where reasonably necessary or required by law.
(3) With other persons where the User has consented or the sharing is otherwise permitted under applicable law.
5. External Services and External Transmission
The Service uses the following external service. Information may be transmitted to the relevant provider for the stated purpose. Where consent is required by applicable law, the Company obtains consent.
External Service | Information Transmitted or Processed | Provider | Purpose |
Terminal3 analytics platform (GCP Japan Region) | System linkage ID, passport issuing country, nationality, year of birth and gender | Terminal3 Ltd. (hosted on Google Cloud Platform) | Creation of statistical information |
Terminal3 analytics platform (GCP US Multi-Region) | System linkage ID, location acquisition time, product or ticket name, latitude/longitude, current-location display name and usage status | Terminal3 Ltd. (hosted on Google Cloud Platform) | Creation of statistical information |
6. Outsourcing
The Company may engage service providers located in or outside Japan to process Personal Data on its behalf, to the extent necessary for the purposes in Section 3. The Company selects and appropriately supervises its service providers and requires them to protect Personal Data in accordance with applicable law.
7. International Transfers
The Company may transfer Personal Data it collects to countries other than the User’s country of residence, including Japan and the United States. Such countries may not have the same data protection laws and regulations as the User’s country of residence. When transferring Personal Data internationally, the Company will implement safeguards required under applicable laws and regulations.
8. Security
The Company implements appropriate organizational, personnel, physical and technical measures to protect Personal Data against unauthorized access, alteration, disclosure, loss and destruction. These measures may include access controls, authentication, encryption, pseudonymization, management of authentication and linkage records generated by the Company, vulnerability management, incident response and supervision of personnel and processors.
9. Retention
The Company retains Personal Data only for the period necessary to achieve the purposes of use or as required by law or contract, and thereafter deletes or anonymizes it using methods designed to prevent restoration.
Data Category
|
Retention Period or Criteria |
Session ID | The Session ID is renewed at least once every month when the User is required to re-authenticate. The previous Session ID is retained thereafter only for as long as necessary to investigate and respond to security incidents, authentication errors or other issues relating to the relevant session. |
System linkage ID | For the duration of the identity linkage and thereafter only for as long as necessary to manage or verify the termination of the linkage, investigate incidents relating to the linkage, or comply with applicable legal or contractual requirements. |
Attribute data | For as long as necessary for authentication or attribute verification and, where the data is used for statistical analysis, until completion of the relevant statistical analysis or termination of the Service, as applicable. |
Location and ticket data | For as long as necessary to conduct the relevant statistical analysis and to support the operation, improvement and quality assurance of the Service. The data is deleted or anonymized when it is no longer necessary for those purposes, unless a longer retention period is required by applicable law or contract. |
Authentication and linkage logs | For as long as necessary to conduct security audits, investigate authentication or linkage incidents, prevent or investigate fraud, and complete any related follow-up actions. |
Inquiry records | For as long as necessary to respond to and resolve the relevant inquiry, complaint or incident and thereafter for any additional period reasonably necessary to handle related disputes or comply with applicable legal or contractual requirements. |
10. Users’ Rights
Subject to applicable law, Users may have rights in relation to their Personal Data, including rights to request access, correction, deletion, restriction or cessation of use, to object to processing, to receive data in a portable form, to withdraw consent and to lodge a complaint with a competent authority. The availability and scope of these rights depend on applicable law.
Requests may be submitted using the contact details in Section 11. The Company may verify the identity or authority of the requester and will respond in accordance with applicable law.
11. Contact
For inquiries regarding this Privacy Policy, the processing of Personal Data, requests concerning Personal Data or complaints, please contact the Company through the following inquiry form:
Controller: Dai Nippon Printing Co., Ltd.
Registered Address: 1-1-1 Ichigaya-Kagacho, Shinjuku-ku, Tokyo 162-8001, Japan
Registration Number: 5011101012069
Person Responsible for Personal Data and Data Protection Officer (DPO): General Manager, Digital Trust Business Development Unit, AB Center
Inquiry Form: https://alldnp.my.site.com/CaseManagement/?id=IFM-01089
The Company may amend this Privacy Policy from time to time. The revised version will be made available through the Service or the Company’s website, and the Company will provide any additional notice or obtain consent where required by applicable law.
Effective or revision dates : Effective Date: October 15, 2026
Revision History : Initial version
Regional Annex for the European Economic Area and the United Kingdom
1. Application
This Regional Annex applies where Regulation (EU) 2016/679 (the “GDPR”) or the UK General Data Protection Regulation (the “UK GDPR”) applies to the Company’s processing of Personal Data. This Regional Annex supplements the Privacy Policy. If there is any inconsistency between this Regional Annex and the Privacy Policy, this Regional Annex prevails to the extent of the inconsistency in matters governed by the GDPR or UK GDPR.
2. Representatives in the European Economic Area and the United Kingdom
EEA Representative (Article 27 GDPR)
Meeco Groep NV
Ajuinlei 1, 9000 Gent, Belgium
Company Number: BE07330.996.651
UK Representative (Article 27 UK GDPR)
Meeco Group Ltd
10 John Street, London WC1N 2EB, United Kingdom
Company Number: 10272583
3. Purposes of Use and Legal Bases
The Company relies on the following legal bases for the purposes described in Section 3 of the Privacy Policy:
Purpose | Categories of Personal Data Processed | Legal Basis |
Providing and operating the Service, including connection with ID Wallets, authentication, attribute verification, session management, identifier issuance and secure linkage with connected services. | Company-issued user identifier; CNF claim (public-key information); and, where necessary for User authentication or attribute verification, limited attributes derived from a digital passport, including passport issuing country, nationality, date of birth, gender, and passport expiry date. | Performance of a contract or steps taken at the User’s request before entering into a contract. |
Using limited attributes derived from a digital passport for authentication, eligibility or attribute verification and fraud prevention. | CNF claim (public-key information); passport issuing country; nationality; date of birth; gender; and passport expiry date. | Performance of a contract, compliance with legal obligations, and legitimate interests in secure service operation and fraud prevention. |
Creating and using statistics, analyzing usage trends, improving and assuring the quality of the Service and planning or developing new functions. | System linkage ID / Company-issued user identifier; passport issuing country; nationality; year of birth; gender; location acquisition date and time; product or ticket name; latitude and longitude; current-location display name; and usage status of the relevant service or ticket. | Legitimate interests in understanding and improving the Service and, where required, consent. |
Responding to inquiries, complaints and incidents, maintaining the Service and providing important communications. | Contact information and inquiry details provided by the User; system linkage ID / Company-issued user identifier; session ID; and other Service usage or technical information necessary to investigate and respond to the relevant inquiry, complaint, or incident.
| Performance of a contract, compliance with legal obligations, and legitimate interests in supporting and administering the Service. |
Security, fraud or abuse prevention, audits, legal claims and legal compliance. | System linkage ID / Company-issued user identifier; session ID; CNF claim (public-key information); relevant authentication information, access information, usage information, security information, and technical log information; and, where strictly necessary, limited digital-passport attributes. | Compliance with legal obligations and legitimate interests in protecting the Service, Users and the Company’s rights. In the UK, where it is necessary to process personal data to prevent, detect, or investigate a crime, the Company relies on its recognised legitimate interests. |
Sharing Personal Data and transmitting information externally as described in Sections 4 and 5 of the Privacy Policy. | Categories of Personal Data necessary for the relevant underlying purpose. In particular, where information is shared with connected services, it is generally limited to the session ID and system linkage ID / Company-issued user identifier. Where information is transmitted to the Company’s analytics environment, the categories may include the system linkage ID / Company-issued user identifier, passport issuing country, nationality, year of birth, gender, location acquisition date and time, product or ticket name, latitude and longitude, current-location display name, and usage status. | The legal basis applicable to the relevant underlying purpose and, where required, consent. |
Where the Company relies on legitimate interests, those interests include providing and improving a secure and reliable Service, preventing fraud, measuring the effectiveness of the Service and protecting the Company’s and Users’ legal rights.
Where processing is based on consent, the User may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
4. International Transfers
Personal Data may be transferred to Japan, the United States and other countries as described in Section 7 of the Privacy Policy.
Where the GDPR or UK GDPR rules on international transfers apply, the Company relies on an applicable adequacy decision or adequacy regulations, the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, or another valid transfer mechanism under applicable law. Users may request information regarding the applicable safeguards, including how to obtain a copy, using the contact details in Section 11 of the Privacy Policy.
5. Users’ Rights
Under the GDPR or UK GDPR, Users have the rights described in Section 10 of the Privacy Policy, subject to applicable conditions and exceptions. These include, in particular:
(1) Right of access (Article 15 GDPR / Article 15 UK GDPR).
Users have the right to obtain confirmation of whether their Personal Data is being processed and, if so, to receive a copy of that Personal Data together with supplementary information including the purposes of processing, the categories of data concerned, the recipients or categories of recipients, the envisaged retention period, the existence of other relevant rights and the right to lodge a complaint with a supervisory authority.
(2) Right to rectification (Article 16 GDPR / Article 16 UK GDPR).
Users have the right to obtain rectification of inaccurate Personal Data and completion of incomplete Personal Data without undue delay.
(3) Right to erasure (Article 17 GDPR / Article 17 UK GDPR).
Users have the right to obtain erasure of their Personal Data without undue delay where one of the grounds in Article 17(1) applies (for example, where the data is no longer necessary, where consent is withdrawn and no other legal basis applies, or where the data has been unlawfully processed). This right is subject to the exceptions in Article 17(3), including where processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.
(4) Right to restriction of processing (Article 18 GDPR / Article 18 UK GDPR).
Users have the right to obtain restriction of processing where, for example, the accuracy of the Personal Data is contested, the processing is unlawful but the User opposes erasure, or the User has objected to processing pending verification of whether the Company's legitimate grounds override the User's interests.
(5) Right to data portability (Article 20 GDPR / Article 20 UK GDPR).
Where processing is based on consent or on the performance of a contract and is carried out by automated means, Users have the right to receive their Personal Data in a structured, commonly used and machine-readable format and, where technically feasible, to have that data transmitted directly to another controller.
(6) Right to withdraw consent (Article 7(3) GDPR / Article 7(3) UK GDPR). Where processing is based on consent, Users may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal. Consent may be withdrawn by contacting the Company using the inquiry form specified in Section 11 of the Privacy Policy.
(7) Right to object (Article 21 GDPR / Article 21 UK GDPR). Where the Company processes Personal Data on the basis of legitimate interests (as identified in Section 3 of this Regional Annex), Users have the right to object to that processing at any time on grounds relating to their particular situation. The Company will cease processing unless it can demonstrate compelling legitimate grounds which override the User's interests, rights and freedoms, or unless the processing is necessary for the establishment, exercise or defence of legal claims.
Users also have the right to object at any time to processing of their Personal Data for direct-marketing purposes, including profiling related to such direct marketing. Where a User exercises this right, the Company will cease such processing without undue delay and without requiring justification.
To exercise the right to object, please contact the Company using the details in Section 11 of the Privacy Policy.
(8) Right to lodge a complaint (Article 77 GDPR / Article 77 UK GDPR).
Users have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement.
·For EEA Users:
Users have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EEA country of their habitual residence, place of work or the place of the alleged infringement. A list of EEA supervisory authorities and their contact details is available on the European Data Protection Board (EDPB) website: https://www.edpb.europa.eu/about-edpb/our-members_en
· For UK users:
you have the right to make a complaint to the Company and to the Information Commissioner's Office (ico.org.uk).
·Requests to exercise any of the above rights may be submitted using the contact details in Section 11 of the Privacy Policy. The Company may ask Users to verify their identity before processing a request, in accordance with Article 12(6) GDPR. The Company will respond within one month of receipt of a request. Where a request is complex or the Company receives a number of requests, this period may be extended by a further two months, in which case the Company will inform the User within one month of receipt of the request, together with the reasons for the delay.
·Where the Company does not take action on a request, it will inform the User within one month of receipt of the reasons for not acting and of the User's right to lodge a complaint with a supervisory authority and to seek a judicial remedy.