Privacy Policy for Personal Information Protection

T&D Holdings, Inc. ("T&D") complies with all applicable laws and regulations, including the Act on the Protection of Personal Information and the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure ("the Number Act"). T&D establishes the Privacy Policy for Personal Information Protection and ensures that all possible efforts are made to protect personal information including specific personal information etc. such as individual numbers and specific personal information in accordance with the principles set forth in this policy (hereinafter, personal information includes specific personal information, etc.)

1. Collection of Personal Information and Notification of Purpose of Use

T&D collects personal information in a lawful and proper manner. When T&D collects personal information, the purpose of use will be promptly notified to each individual, or published on T&D's website, etc., except when the purpose of use has been announced in advance. This does not, however, apply when notification or announcement is not required by laws or regulations.

2. Use of Personal Information

(1) Purpose of Use

T&D uses personal information in a lawful and proper manner to the extent

* Notwithstanding the above, T&D corrects and uses the specific personal information etc. of its customers in accordance with laws and regulations to the extent necessary to fill out legal documents which require individual numbers.

(2) Restriction on Purpose of Use

T&D does not use personal information beyond the extent necessary to fulfill the intended purpose without obtaining the prior consent of each individual, except in the following circumstances:

  1. a.
    In instances when required by laws or regulations;
  2. b.
    In instances when necessary to protect human life, body or property, and the consent of each individual can not be readily obtained;
  3. c.
    In instances when specifically necessary for the improvement of public health or for the sound and healthy growth of children, and the consent of each individual can not be readily obtained; or
  4. d.
    In instances when necessary to cooperate with government agency, etc. in providing services, as stipulated by laws and regulations, and if obtaining the consent of each individual may pose obstacles to the implementation of such works.

* Notwithstanding the above, T&D does not use the specific personal information etc. of its customers beyond the scope of the purpose of use, even if there is consent of the customer, with the exception that the Number Act regards the case as an exception.

(3) Proper Supervision over the Third Party

In case of T&D considering the handling of personal information to a third party, T&D conducts a strict investigation on that third party and provides proper supervision over the third party to maintain confidentiality.

3. Provision of Personal Information

  1. (1)
    T&D never provides personal information to a third party without the consent of each individual, except in circumstances as described in a. or d. of the preceding 2 (2).

    * Notwithstanding the above, T&D does not provide the specific personal information etc. to a third party, even if there is consent of the customer, with the exception of the case described in the Number Act.

  2. (2)
    In instances when T&D uses personal information jointly with a third party, T&D notifies or announces in advance, as required by laws or regulations, the fact of joint use, the purpose of use, used items, etc.

    * Notwithstanding the above, T&D does not use the specific personal information etc. jointly with a third party, even if there is consent of the customer.

4. Management of Personal Information

  1. (1)
    T&D implements internal rules regarding management of personal information in addition to maintain personal information safely and accurately, and manages it safely at each stage of collection, use, custody, disposal, etc.
  2. (2)
    T&D implements appropriate security measures against unauthorized access, computer viruses, etc., to prevent leakage, loss, corruption or damage of personal information.
  3. (3)
    T&D never leaks personal information by taking it out or sending it outside.

5. Disclosure, Amendment, Suspension of Use of Personal Information

When each individual asks to have the information disclosed or amended, or its use suspend, T&D responds to such requests promptly after identifying the person unless there are special circumstances.
T&D also deals with requests regarding personal information in an appropriate manner.

* About procedures for disclosure, amendment (including addition or removal) or suspension of use (including deletion) of personal information, as well as for other requests related to personal information, please contact the address at the end of this Privacy Policy.

6. Organization

  1. (1)
    T&D designates the person responsible for the appropriate management of personal information.
  2. (2)
    T&D provides all directors, executive officers and employees with training program on protection and appropriate management of personal information to ensure proper handling on a daily business.

7. Compliance Program for Personal Information

To ensure thorough implementation, an item regarding protection of personal information is included in T&D's "Compliance Program", which is a concrete action plan for all directors, executive officers and employees on observing laws and regulations.

Please contact the address below if you have any requests, opinions, questions or proposals regarding the handling of personal information by T&D:

T&D Holdings, Inc.
2-7-1, Nihonbashi, Chuo-ku,
Tokyo 103-6031, Japan
TEL : +81-(0)3-3272-6110
FAX : +81-(0)3-3272-6552