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Official Announcement Matter in Personal Data Protection Law of Japan

Official Announcement Concerning the Personal Data Protection Law of Japan

Sanden Corporation (hereinafter "Sanden") hereby announces the following matters, based on the Personal Data Protection Law of Japan, concerning items that can be and are required to be easily accessible by the individuals concerned.


I. Sanden’s Usage of Personal Data

(1) Except when personal data is obtained from customers, suppliers, temporary workers, external organizations, subcontractors, shareholders, and other parties (collectively “customers, etc.”), via written documentation stating the purposes for which they will be used, Sanden will use personal data as follows.

  1. Business Activities: Client Data
    • Investigations concerning clients
    • Product shipments, communications, and exchanges of data materials with clients
    • Charging the proceeds from product sales, and other general business activities

  2. Business Activities: Customer Data
    • Communications and exchanges of data materials with customers
    • Requesting customers to respond to a questionnaire survey
    • Introduction of new products
    • After-sale and other related services
    • Other general customer management

  3. Management of Suppliers
    • Selection and investigation of suppliers
    • Orders, communications, and exchanges of data materials with suppliers
    • Payments of purchases goods to suppliers
    • Other general supplier management

  4. Management of Dispatched Workers
    • Identification and general management of dispatched workers

  5. Management of External Organizations
    • Promotion of activities at external organizations, and communications and exchanges of data materials with them
    • Other external-organizations management

  6. Management of Subcontractors
    • Outsourcing business to subcontractors, and communications and exchanges of data materials with them
    • Payment of outsourcing fees and other costs
    • Other subcontractors management

  7. Management of Shareholders
    • Communications and exchanges of data materials with shareholders

  8. Other
  9. Sanden may receive personal data in the course of Corporate Social Responsibility and other activities, and will inform those concerned whenever it does

(2) Sanden may consign business to third parties, including its group companies, for the effective use of customers' personal data and to the extent necessary to achieve the purposes stipulated in the paragraph of I. "Business activities: client data". Sanden will select such third parties after confirming that personal data will be kept fully confidential, and will supervise them in accordance with contracts and by other means.

 

(3) Sanden may share customers’ personal data with its group companies and other organizations, to the extent necessary to achieve the purposes stipulated in the paragraph of I. “Business activities: client data”, and for the integration of the Sanden Group’s businesses.
Sanden will be fully responsible for managing such personal data, based on agreements with its group companies and other organizations.

 

II. Providing Personal Data to Third Parties
(Article 23, Sections 2 and 3 of the Personal Data Protection Law)

Sanden will strictly control personal data received from customers, and will not disclose such information to any third parties without their consent, except in the following cases:

  • When required by law
  • When necessary to protect life, health, or property, if it is difficult to obtain consent from the individual concerned
  • When necessary to protect public health or child raising, if it is difficult to obtain consent from the individual concerned
  • When it is necessary to cooperate with national or local authorities, or anyone who is commissioned thereby in their performance of operational works provided by law, and if acquiring consent from the individual concerned may disrupt such work.

III. Procedures for Disclosure and Other Requests
(Article 29 of the Personal Data Protection Law)

Sanden will respond to any requests regarding personal data retained by Sanden (hereinafter referred to as "retained personal data") by the individuals concerned or their representatives, for disclosure, modification, suspension of retained personal data, and other revisions of the usage of retained personal data held (hereinafter referred to as “disclosure, etc.”).


(1) Items to be indicated in disclosure requests (information contributing to identify retained personal data held):
Items of retained personal data held to be disclosed are as follows:
Name, address, telephone number, email address.


Name address telephone number email address

(2) Disclosure Request Method and Addressee:
Disclosure requests are to be submitted via postal mail, and to include an application form and necessary documents. Indication (in red ink) on the front of envelope, “Disclosure Request Enclosed”, would be appreciated. Applications are to be sent to the following address:

Sanden Corporation
Legal Group, Administration & Personnel Division
1-31-7, Taito, Taito-ku, Tokyo 110-8555
Japan

(3) Disclosure Request Documents to Be Submitted:
Application Forms are to be downloaded, filled out completely, and mailed with copies of Identifying Documents to identify the individual concerned.


A. Application Forms:



B. Identifying Documents:

        Driver’s license or passport copy. 1 copy


(4) Disclosure Requests by a Representative:
If the party requesting a disclosure is a statutory agent for the individual concerned, a minor or an adult under guardianship, or a consigned agent of the individual concerned, enclosure of the either document (for Statutory Agent or Consigned Agent) below will be appreciated.


A.Statutory Agent:

  • A declaration form prescribed by Sanden 1 copy
  • Confirmation of authority (copy of a family register or health insurance certificate describing the names of dependents are acceptable for agents with parental authority) 1 copy
  • Identification for the statutory agent of a minor or an adult under guardianship (copy of the agent’s driver’s license or passport) 1 copy

B. Consigned Agent:

  • Power-of-attorney form prescribed by Sanden 1 copy
  • Certificate of the seal impression of the individual concerned 1 copy

(5) Disclosure Request Fees:
¥300 per request. (Please enclose postage stamps equivalent to¥300.)


Note: If fee payments are insufficient or not enclosed, Sanden will notify the sender. If no fee payment is made within the deadline prescribed by Sanden, disclosure requests will be deemed void.


(6) Responses to Disclosure Requests:
Sanden will respond in written form to the addresses indicated on application forms.


(7) Usage of Personal Data Obtained from Disclosure Requests:
Personal data obtained from requests for disclosure will be treated to the extent necessary to respond to such requests. Submitted documents will be retained for three months after the completion of responses to such requests and they will be scrapped thereafter.


Note:Reasons not to Disclose Personal Data:
Sanden will not disclose personal data subject the conditions below, and will send a notice and explanation to that effect to the applicant. Fees are to be paid even in the event of such non-disclosure.

  • The individual concerned cannot be identified (e.g., discrepancies between addresses on applications, on identifying documents, and registered with Sanden.
  • Applying agent’s authority cannot be confirmed.
  • Errors on application forms.
  • Subjects of disclosure requests are not included in personal data held.
  • Disclosure may possibly threaten life, health, property, or other rights or interests of the individual concerned or third parties.
  • Disclosure may significantly interfere with Sanden’s business performance.
  • Disclosure is in violation of other laws.

IV. Complaints Desk
(Article 24, Section 1, Subsection 4, and Article 31, of the Personal Data Protection Law, Article 5 of the Personal Data Protection Enforcement Regulations)

(1) Complaints Concerning Treatment of Personal Data:
Complaints concerning Sanden’s treatment of personal data are to be submitted as follows.

  • Via Telephone:
    Sanden Corporation, Legal Group, Administration & Personnel Division:
    Phone: 03-3833-1211

  • Via Postal Letter:
    Sanden Corporation, Legal Group, Administration & Personnel Division:
    1-31-7, Taito, Taito-ku, Tokyo 110-8555, Japan

  • Via In-person Visit:
    Complaints made by visiting Sanden in person cannot be accepted.

(2) Certified Personal Data Protection Organization to which Sanden Belongs:
Sanden has no memberships in such organizations.


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