Privacy Policy

1. Observance of relevant laws and guidelines, etc．

The Company will comply with the Act on the Protection of Personal Information and other applicable laws, regulations, guidelines, etc. regarding the handling of personal information.

2. Proper Collection of Personal Information

When collecting personal information, the Company will state the purpose of collection and use in advance, within the scope necessary to achieve the purpose, and collect personal information in a proper manner and by fair means.

3. Purposes of Use of Personal Information

• i. The Company will use collected personal information only for the following purposes and never use it for other purposes. The personal information beyond the scope of the following purposes will not be used, unless prior consent is obtained in the proper manner from the individual concerned. To perform business administration of the Group companies;
  ii. To provide integrated common services among the Group companies
  iii. To provide and administer any information on the Company business
  iv. To inform the Company’s shareholders, to provide various items of information, and to manage the Company’s shareholder information;
  v. To execute rights or obligations based on laws and ordinances
  vi. To respond to inquiries and requests from individuals about their personal information
  vii. To perform personnel management and welfare of the Company’s employees, etc.
  viii. To engage in activities concerning the Company’s CSR (Corporate Social Responsibility)
  ix. To provide information about events, campaigns, services/products of the Group companies and to conduct surveys
  x. To perform other businesses incidental to the items mentioned above
  xi. In addition to the above, for purposes listed in “6. Shared Use of Personal Information.”

4. Proper Handling of Personal Information

The Company will strictly handle personal information and take the necessary and proper measures to prevent all risks including loss, damage, falsification, divulgence, and unauthorized access. Furthermore, the Company will establish concrete rules to properly handle and use personal information, and appoint responsible persons.

5. Providing Personal Information to Third Parties

5.1 The Company will not provide personal information to third parties except in the following cases:

• i. When prior consent of the individual concerned is obtained;
  ii. When it is required by laws or ordinances;
  iii. When it is necessary to protect lives, physical bodies, and/or property and it is difficult to obtain consent of the individual concerned;
  iv. When it is especially required for improvement of public health or for promotion of sound growth of children and it is difficult to obtain consent of the individual concerned;
  v. When there is a need to cooperate with a national or local government body or a person commissioned by such a body for the execution of a matter that is stipulated in laws or ordinances and obtaining consent of the individual concerned is likely to become a hindrance to the execution of the matter;
  vi. Other cases in which providing personal information is authorized in the Act on the Protection of Personal Information.

5.2 Notwithstanding the above, the Company will not provide specified personal information to third parties unless otherwise stated in laws or ordinances.

6. Shared Use of Personal Information

The Company may share the use of personal information with Group companies as follows:

• i. Personal information items subject to shared use
  
  • ・Name, address, phone number, e-mail address, date of birth, workplace, gender, type of transaction, etc.
• ii. Scope of those who will engage in shared use
  
  • ・Group companies of the Company
• iii. Purposes of use
  
  • ・To execute contracts with the individual concerned;
    ・To sell products and provide services offered by the Company and Group companies;
    ・To provide information and conduct surveys etc. about the products and services offered by the Company and Group companies;
    ・To notify the relevant company when the individual concerned has an inquiry or applies to use the products and services offered by the Company and Group companies;
    ・To manage customer information of the Company and Group companies;
    ・To perform other tasks that are incidental to or related to the items above;
• iv. Entity responsible for the management of personal information at the Company.
  
  • TSUNEISHI HOLDINGS CORPORATION

7. Supervision of Subcontractor Handling Personal Information

The Company may transfer collected personal information to a third-party subcontractor in order to, for example, perform smooth operation of services. In such case, the Company will treat personal information properly by selecting a subcontractor that meets the sufficient standards for protecting personal information and including appropriate measures in the relevant contracts, etc.

8. Matters Related to Security Control Measures

The Company implements the security control measures below for retained personal data.

• i. Establishment of a basic policies
  
  • ・Basic policies are established regarding “Observance of relevant laws and guidelines, etc.” and “Contact point for dealing with a complaint” etc. to ensure that personal data is handled properly.
• ii. Setting of rules for handling personal data
  
  • ・Rules are set for handling methods, person responsible, person in charge, and their duties for handling personal data per stage, such as acquisition, use, saving, providing, deleting, disposing, etc.
• iii. Organizational security control measures
  
  • ・The handling status of personal data is periodically self-inspected and audited by other departments.
• iv. Human security control measures
  
  • ・Periodic training is conducted for employees regarding points to consider in relation to handling personal data.
• v. Physical security control measures
  
  • ・Measures are taken to prevent the theft and loss of equipment, electronic media, and documents with personal data. Measures are also taken to ensure that personal data is not easily identified when such equipment, electronic media, and other are transported, including within the office.
• vi. Technological security control measures
  
  • ・Access is controlled; the persons in charge and the range of the handled personal information database are limited.

9. Procedures for Responding to Application for Disclosure, etc.

9.1 When an individual wishes to inquire about the purpose of use of his/her personal data retained by the Company and to make corrections, additions, or deletions to the personal data, and/or suspend its use or erase the personal data, the individual can request disclosure of the retained personal data by making an application for disclosure, (hereinafter the “Application for Disclosure, Etc.”). The individual shall mail the following documents or the like to the Person in Charge of Handling Personal Information in Section 10.

• i. Document that includes the address, name, profession, telephone number, e-mail address of the applicant, and the purpose of the application;
  ii. Document that identifies the applicant (a photocopy of their driver’s license or passport or national health insurance card or the like);
  iii. Postage stamps for the charge (please consult with the Person in Charge of Handling Personal Information for the amount of charge).

9.2 After the applicant is identified as the relevant individual, the Company checks the retained personal data, takes the necessary steps, and mails to the applicant a written answer to the request.

9.3 Personal information collected through the Application for Disclosure, etc. will be used only to the extent that is necessary for the Application for Disclosure, Etc. The documents mailed by the applicant will be retained for an appropriate period of time and thereafter discarded.

9.4 If an applicant falls under any of the cases stated below, the personal information will not be disclosed. When a non-disclosure decision is made, written notice of the reason will be given to the applicant.

• i. When the applicant cannot be identified;
  ii. When the applicant has not paid the charge;
  iii. When the application does not fall under an Application for Disclosure, etc.;
  iv. Cases in which disclosure might harm the life, body, property, or other rights or interests of the person or a third party
  v. When the application is likely to cause significant hindrance to proper execution of the Company’s business.

10. Request for Disclosure of Purpose of Use and Personal Information

An individual should send an Application for Disclosure to the following Person in Charge of Handling Personal Information. The Company will respond to the application in accordance with the Act on the Protection of Personal Information.

Appointed Section in Charge of Handling Personal Information:
General Affairs Section of Business Administration Department, TSUNEISHI TRADING CORPORATION
Address: 1083 Tsuneishi, Numakuma-cho, Fukuyama City, Hiroshima Prefecture 720-0393, Japan
Telephone: 084-987-3965
Reception time: Monday to Friday (excluding holidays and year-end and beginning period) from 9:30 to 12:00 and 13:30 to 16:30

11. Continual Improvements to the Privacy Policy and In-House Rules

The Company will continue to improve the Privacy Policy and the in-house rules so that protection of personal information being requested by society will be implemented effectively.

March 24, 2022