| Privacy Policy |
Elecom Co., Ltd. (hereinafter referred to as "Elecom") is responsible as an entity handling personal information for protecting the personal information of all parties providing personal information to Elecom (hereinafter referred to as the "Subject"), whether they are users or business partners. The following are the guidelines set forth in regard to handling personal information, with which Elecom will comply to protect the Subject's personal information.
1. (Obtaining personal information)
When requesting personal information from the Subject, Elecom will make clear the purpose for obtaining the personal information (hereinafter referred to as the "Purpose of Use") to the Subject. However, if the Purpose of Use is clearly recognizable when Elecom requests personal information from the Subject, Elecom may not explicitly state the Purpose of Use. In such case, Elecom will only use the personal information to the extent that the Purpose of Use is clearly recognizable.
2. (Managing personal information)
a. Elecom will establish an internal organization promoting the safe handling of personal information and appoint a manager responsible for the handling of personal information to ensure the appropriate management of personal information.
b. In order to prevent the leakage, alteration, and loss of personal information, as well as the use of personal information beyond the Purposes of Use, Elecom will manage the personal information in strict compliance with related laws, regulations, guidelines, and internal rules. Employees will be trained in appropriate management and handling of personal information as necessary through educational programs.
c. If Elecom is to outsource the handling of personal information to an outside entity, the amount of information entrusted to that entity shall be limited to the minimum amount necessary, and the entity selected shall be compliant with personal information handling criteria set forth by Elecom. All consigned entities will be instructed to safely manage such personal information, not to further entrust such personal information with other entities, not to use such personal information outside of the Purpose of Use, and not to handle it in any other inappropriate manner.
d. Elecom will regularly and continuously evaluate and update this guideline and internal rules related to the protection of personal information, and strive to improve them.
3. (Use of personal information)
Elecom will not use personal information outside of the Purpose of Use, with the exception of the following cases:
(a) If the Subject consents to use outside of the Purpose of Use;
(b) If publicized in a manner in which the Subject is non-identifiable (e.g. statistical materials); or
(c) If related laws, regulations, and guidelines allow the use of personal information for purposes other than the Purpose of Use.
4. (Changing the Purpose of Use of personal information)
If Elecom changes the Purpose of Use of personal information within a range that the Subject can reasonably expect, Elecom will publicize or notify the Subject with the updated Purpose of Use, unless laws and regulations state otherwise.
5. (Disclosing personal information with third parties)
Elecom will never disclose personal information to any third parties, with the exception of the following cases:
(a) If the Subject consents to the disclosure of personal information to a third party;
(b) If publicized in a manner in which the Subject is non-identifiable (e.g. statistical materials);
(c) If disclosing personal information to agencies or consignors (hereinafter referred to as "Partner Businesses") with whom Elecom has signed a non-disclosure agreement to the extent necessary for them to complete the Purpose of Use;
(d) If disclosing personal information to Partner Businesses when Elecom reasonably concludes based on the content of the inquiry or information request from the Subject that Partner Businesses should be allowed to respond directly to such inquiries or information requests;
(e) If disclosing personal information to financial institutions when necessary to complete credit card transactions for payments related to purchases and subscriptions;
(f) If Elecom is entirely or partially a participant in a merger, split-up, or business transfer, Elecom may provide its successor with the personal information;
(g) If necessary to protect a person's life, body, or property from harm, and it is unrealistic to obtain the permission of the Subject;
(h) If especially necessary to improve public health or to promote the healthy upbringing of children, and it is unrealistic to obtain the permission of the Subject; or
(i) If Elecom must cooperate with a national institution, local public entity or person entrusted thereby for conducting operations prescribed by law, and obtaining the permission of the Subject could pose an obstacle to such operations.
6. (Inquiries regarding personal information)
Elecom provides support for the Subject if it wishes to inquire about, make changes, or make amendments to its own personal information through the contact listed below (Japanese only). Upon request, Elecom will take the necessary actions, within reasonable limit, based on internal procedures. In order to protect the Subject from personal information theft or unauthorized updates to their personal information, Elecom may attempt to verify the identity of the Subject upon inquiry. If Elecom is not able to verify the identity of the Subject upon inquiry, Elecom may not be able to carry out the request - please cooperate when asked for verification. Calls to the general information center and support centers by the Subject may be recorded or monitored for product and service quality control and training purposes.
7. (Handling of opinions and requests)
Unless the Purpose of Use states otherwise, Elecom may use the opinions, requests, and suggestions it receives in any matter it wishes. However, Elecom may not publicize or disclose this information to a third party in a form that allows for the Subject to be identified without prior consent of the Subject.
8. (Compliance with related laws and regulations)
Elecom will strictly comply with laws and regulations, as well as internal rules, related to personal information.
April 2005
