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Privacy Policy

Tsuneishi Holdings Corporation
Policy on Protection of Personal Information (Privacy Policy)

Tsuneishi Holdings Corporation (hereinafter the “Company”) recognized that respecting the right to protect personal information is essential among the numerous rights of the individual. Protecting personal information is the basis of businesses of the Company group (hereinafter the “Group”) and our social responsibility. The Company has established the following policy on protection of personal information and will make them known to and observed by its officers, employees and cooperating workers.

1. Properly Collecting 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.

2. Purposes of Use of Personal Information

The Company will use collected personal information only for the following purposes and never use it for other purposes.

  1. (i) To perform business administration of the Group companies
  2. (ii) To provide integrated common services among the Group companies;
  3. (iii) To provide and administrate any information on the Company business;
  4. (iv) To inform the Company’s shareholders, to provide various items of information and to supervise the Company’s shareholders;
  5. (v) To execute rights or obligations based on laws and ordinances;
  6. (vi) To respond to inquiries and requests from individuals on their personal information;
  7. (vii) To perform personnel management and welfare of the Company’s employees and customers;
  8. (viii) To engage in activities concerning the Company’s CSR (Corporate Social Responsibility);
  9. (ix) To perform other businesses incidental to items from (i) to (viii) mentioned above.

3. 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.

4. Providing Personal Information for Third Parties

  1. 4.1 The Company will not provide personal information for third parties except in the following cases;

    1. (i) Case where prior consent of the individual concerned is obtained;
    2. (ii) Case where it is required by laws or ordinances;
    3. (iii) Case where it is necessary to protect lives, physical bodies and/or property of people and where it is difficult to obtain consent of the individual concerned;
    4. (iv) Case where it is especially required for improvement of public sanitation or for promotion of sound growth of pupils and where it is difficult to obtain consent of the individual concerned;
    5. (v) Case where a national government body or a local government body or a person commissioned by such a body needs to extend cooperation to an affair stipulated in laws or ordinances and when obtaining consent of the individual concerned is likely to become a hindrance to the execution of the affair;
    6. (vi) Other case where providing personal information is authorized in the Act on the Protection of Personal Information.
  2. 4.2 The Company may share personal information among the Group companies in order to provide the Group’s comprehensive services.When sharing personal information with a specific person, the Company will clearly indicate the type of information, scope of people being shared with, goal of sharing and the name or title of the person responsible for the management of personal information.
  3. 4.3 Notwithstanding what is stated above, the Company will not provide specified personal information for third parties unless otherwise stated in laws or ordinances.

5. 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.

6. Procedures for Responding to Application for Disclosure, Etc.

  1. 6.1 When an individual intends to inquire the purpose of use of his/her personal data retained by the Company and applies for disclosure of the retained personal data in order to make corrections to the content, additions, deletions, and/or suspension of use or erasure of the personal information (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 7.

    1. (i) Document that includes the address, name, profession, telephone number, e-mail address of the applicant, and the purpose of the application;
    2. (ii) Document that identifies the applicant (a photocopy of their driver’s license or passport or national health insurance card or the like);
    3. (iii) Postage stamps for the charge (please consult with the Person in Charge of Handling Personal Information for the amount of charge).
  2. 6.2 After the applicant is identified as the relevant individual, the Company checks the retained personal data, takes the necessary steps, and mails a written answer to the request to the applicant.
  3. 6.3 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 they are discarded.
  4. 6.4 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.

    1. (i) When the applicant cannot be identified;
    2. (ii) When the applicant has not paid the charge;
    3. (iii) When the application does not fall under an Application for Disclosure, Etc.
    4. (iv) When the applicant is likely to harm the life, physical body, property and/or interests or rights of the applicant or a third party;
    5. (v) When the application is likely to cause significant hindrance to proper execution of the Company’s business.

7. 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.

Person in Charge of Handling Personal Information:
Department: General Affairs Department, Corporate Division, Tsuneishi Holdings Corporation
Address: 1083 Tsuneishi, Numakuma-cho, Fukuyama City, Hiroshima Prefecture 720-0393, Japan
Telephone: 084-987-1111
Reception time: Monday to Friday (not including holidays and year-end and beginning period)from 9:30 to 12:00 and 13:00 to 16:30

8. Continuous Improvements in 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.

May 30, 2017

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