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Tokio Marine Holdings Privacy Policy

With customer trust at the foundation of all our activities, the Company aims to commit to the continuous enhancement of corporate value, through planning the strategy of Tokio Marine Group and managing the companies in the Group. The Company will properly handle personal information as described below in compliance with the Act on the Protection of Personal Information (the "Privacy Act"), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the "My Number Act"), other relevant laws, ordinances and guidelines, and the Tokio Marine Group Privacy Policy, and will take appropriate measures to ensure that personal information individual number and specific personal information (hereinafter referred to as "Specific Personal Information, etc."), as well as anonymously processed information are secure. The Company will make an effort to conduct training and education for the Company’s employees so that customers’ personal information, Specific Personal Information, etc. and anonymously processed information will be properly handled. The Company will review and improve the contents described below from time to time.

  • *
    "Personal information" and "personal data" described in this Privacy Policy exclude Specific Personal Information, etc.

1. Collection of Personal Information (please see Clause 7 with respect to Specific Personal Information, etc.)

The Company will collect personal information from customers and shareholders in a lawful and proper manner to the extent necessary for its business.

2. Purpose of Use of Personal Information (please see Clause 7 with respect to Specific Personal Information, etc.)

The Company will use personal information within the scope of the purposes provided in the Purpose of Use.

The Purpose of Use is specifically defined and made clear to customers and shareholders, and is announced on the Company’s website as shown below. The Company will make an effort to limit the Purpose of Use according to the situation in which the information is obtained.

  1. Management of companies in the Group*
  2. Giving notice to shareholders, provision of various types of information and shareholder management
  3. Exercise of rights or performance of obligations by the Company based on the Companies Act of Japan and other relevant laws and ordinances
  4. Responding to inquiries, requests, etc. from customers and shareholders
  5. Carrying out operations incidental to (1) through (4) above and operations to properly and smoothly manage the business of the Company

When handling personal information beyond the scope necessary for achieving the Purpose of Use, the Company will seek your consent except for cases prescribed under items in Paragraph 3 of Article 16 of the Privacy Act.

  • *
    Please see Clause 12 "Company List" for the scope of Group companies.

3. Provision and Collection of Personal Data to/from Third Parties (please see Clause 7 with respect to Specific Personal Information, etc.)

  1. The Company will not provide personal data to a third party without your consent, unless such provision is:
    • required under laws or ordinances;
    • made to a consignee within the scope necessary for carrying out the Company’s business (please see Clause 4 "Consignment of Handling of Personal Data and Specific Personal Information, etc.")
    • to use personal data jointly with a group company or a business partner of the Company (please see Clause 5 "Joint Use with the Company’s Group Companies and Business Partners")
  2. Unless otherwise prescribed by law, rule or regulation, the Company, when providing personal data to a third party, shall record matters concerning such provision (what type of personal data was provided to whom, etc.), and when collecting personal data from a third party, shall confirm and record matters concerning such collection (what type of personal data was received from what type of provider, how the third-party provider collected such data, etc.).

4. Outsourcing the Handling of Personal Data and Specific Personal Information, etc.

The Company may, within the extent necessary for achieving the Purpose of Use, consign the handling of personal data and Specific Personal Information, etc. to an external party. When consigning the handling of personal data and Specific Personal Information, etc. to an external party, the Company will exercise the necessary and appropriate oversight of consignees, such as checking in advance their information management systems after setting criteria for their selection.

For example, the Company consigns the handling of personal data and Specific Personal Information, etc. in the following cases:

  • Consigning shareholder register management operation
  • Consigning operations relating to the preparation and submission of payment records, etc.

5. Joint Use with the Company’s Group Companies and Business Partners

The Company, Tokio Marine Group companies and their business partners* may jointly use the following personal data for the Purpose of Use provided in the aforementioned Clause 2, items (1) through (5). There is no joint use of Specific Personal Information, etc.

  1. Personal data items:
    1. Personal data of shareholders (address, name, status on holding of the Company’s shares, etc.)
    2. Personal data held by companies of the Group (address, name, phone number, gender, date of birth and other transaction information, including the contract terms and the content of insurance incident provided in application forms)
    3. Personal data of individuals who have made an inquiry, request, etc. to the Company (name, contact details, content of inquiry, request, etc.)
  2. Party responsible for personal data management: Tokio Marine Holdings, Inc.
  • *
    Please see Clause 12 "Company List" with respect to the scope of companies of the Group. Currently, there is no joint use of personal data with business partners.

6. Handling of Sensitive Information

The Company will not collect, use, or provide to any third parties personal information requiring special care and information concerning membership of labor unions, family, domicile of origin, health condition and medical treatment, or sexual orientation (except for information released by the individual himself/herself, government agency, local government, or any party provided in each of the items in paragraph 1 of Article 76 of the Privacy Act or in each of the items in Article 6 of the Ordinance for Enforcement of the Privacy Act, or information which is collected through visual observation or by taking a photograph of the individual and hence the external appearance is evident; hereinafter, “Sensitive Information”) except for cases provided by the Privacy Act, other relevant laws, ordinances and guidelines.

7. Handling of Specific Personal Information, etc.

The Purpose of Use of Specific Personal Information, etc. is limited under the My Number Act, and the Company will not collect or use Specific Personal Information, etc. beyond the prescribed Purpose of Use.
The Company will not provide Specific Personal Information, etc. to a third party except in cases permitted under the My Number Act.

8. Notice of Matters, Disclosure, Amendment, or Suspension of Use of Personal Data and Specific Personal Information, etc. Held by the Company under the Privacy Act

Please direct requests for any notice of matters, disclosure, amendment, or suspension of use of personal data and Specific Personal Information, etc. held by the Company under the Privacy Act to the "Contact Office" indicated in Clause 11 below. After confirming that you are the requesting party and requesting you to complete a form designated by the Company, the Company will follow procedures, and, in principle, provide a written response in a proper, timely manner. The Company will charge the prescribed fees for responding to a request for any disclosure.

9. Management of Personal Data and Specific Personal Information, etc.

The Company will take full security measures to manage personal data and Specific Personal Information, etc. securely and to prevent divulgence, loss or damage to personal data and Specific Personal Information, etc. handled by the Company, and will ensure the accuracy and prompt updating of personal data and Specific Personal Information, etc. which are necessary to achieve the Purpose of Use.

10. Handling of Anonymously Processed Information

  1. Production of anonymously processed information
    The Company shall act as follows when producing anonymously processed information (information relating to an individual that can be produced from personal information so as neither to be able to identify a specific individual by taking action prescribed under the respective laws, rules and regulations nor to be able to restore the personal information).
    • Apply appropriate process in accordance with the standards set forth under relevant laws, rules and regulations;
    • Take appropriate action for the security control to prevent leakage of deleted information or information concerning the method of processing in accordance with the standards set forth under relevant laws, rules and regulations;
    • Publicly announce categories of information included in the anonymously processed information; and
    • Refrain from taking any action to identify the individual to whom the personal information pertains.
  2. Provision of anonymously processed information
    The Company, when providing the anonymously processed information to a third party, shall in advance disclose to the public the categories of information concerning an individual contained in the anonymously processed information to be provided and its method of provision, and state to the third party explicitly to the effect that the information being provided is anonymously processed information.

11. Contact Information

The Company will appropriately and promptly respond to any complaint or consultation regarding the handling of personal information, Specific Personal Information, etc. and anonymously processed information.

If you have any inquiry or matter for consultation regarding the handling of personal information, Specific Personal Information, etc. and anonymously processed information by the Company, please contact the office indicated below.

Contact Office
Compliance Dept.
Tokio Marine Holdings, Inc.
Telephone: 0120-789-967
(open from 9 a.m. to 5 p.m. excluding Saturdays, Sundays, national holidays and during the year-end and new-year period.)

12. Company List

The Company’s group companies and business partners described in Clause 2 "Purpose of Use of Personal Information" and Clause 5 "Joint Use with the Company’s Group Companies and Business Partners" are as follows.

  1. 1.
    Group Companies: Please see here.
  2. 2.
    Business Partners: The Company does not provide personal data to any business partners at the present time.
  • Note:
    Personal information, Specific Personal Information, etc. and anonymously processed information of employees of the Company shall not necessarily be treated in accordance with this policy.
  • Adopted on March 7, 2005
  • Revised on February 9, 2006
  • Revised on October 1, 2006
  • Revised on July 1, 2007
  • Revised on July 1, 2008
  • Revised on October 1, 2009
  • Revised on August 11, 2011
  • Revised on October 5, 2015
  • Revised on December 18, 2015
  • Revised on May 30, 2017