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, individual numbers and specific personal information (individual numbers and specific personal information are hereinafter collectively referred to as "Specific Personal Information, etc.") 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.
The Company will continue to review and improve the contents of this Privacy Policy from time to time.
- *In this Privacy Policy, "personal information" and "personal data" exclude Specific Personal Information, etc.
1. Collection of Personal Information (please see Clause 7 “Handling of Specific Personal Information, etc.” below with respect to Specific Personal Information, etc.)
The Company will collect personal information in a lawful and proper manner to the extent necessary for its business.
- (1) Collection from principals
The Company collects personal information through transaction documents, surveys, etc.
The Company may collect personal information from recorded phone calls, etc. in order to accurately record the details in various notices, inquiries, consultations, etc. - (2) Collection from others
The Company may collect personal information from any of the companies in the Tokio Marine Group, consignees, business partners and other third parties or based on released information. The following are specific examples showing how the Company collects personal information from persons other than principals.
- Information providers: General Incorporated Foundation Minji Houmu Kyokai, ZENRIN CO., LTD.
- Matters in personal information to be collected: information on the structure of a building or other information stated in a certificate of registered matters, a house map, etc.
In collecting personal data from a third party, the Company will confirm and record matters related to the collection (what type of personal data was collected from whom, how the third party provider collected the data, etc.)
2. Purposes of Use of Personal Information (please see Clause 7 “Handling of Specific Personal Information, etc.” below with respect to Specific Personal Information, etc.)
The Company will use personal information within the scope necessary for the following purposes and the purposes stated in Clause 5. “Joint Use with the Company’s Group Companies and Business Partners” below (the “Purposes of Use”).
- (1) Management of companies in the Group* and common duplicate operations
- (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 and other relevant laws and ordinances
- (4) Responding to inquiries, requests, etc. from customers
- (5) Management of claims and debts held by the Company and collection of the claims
- (6) Maintenance of information systems, information assets and business assets and safety control of facilities of the Company
- (7) Procedures for hiring employees of the Company from a selection (interview, examination, etc.), notice of the results of the selection, to employment
- (8) Invitation to various events, campaigns and seminars and provision of various information
- (9) Data analysis including market research, aggregation of information on each customer and collation of the information, research and development for new products and services through implementation of surveys, etc., and improvements in the quality of existing products and services of the companies in the Group
- (10) Joint research with other business operators, research institutions and other entities, development of new products and services, and improvements in the quality of existing products and services of the companies in the Group (including the case of data analysis including aggregation of information on each customer and collation of the information)
- (11) Processing of personal information in the case of consignment of such operation from another business operator
- (12) Improvements in the operations and procedures stated in (1) through (11) above
- (13) Carrying out other operations incidental to (1) through (12) above and operations to properly and smoothly manage the business of the Company
The Purposes of Use is specifically defined and made clear to customers, and is announced on the Company’s website, etc. The Company will make an effort to limit the Purposes of Use according to the situation in which the information is obtained. If there is a change in the Purposes of Use, the Company will notify each principal or announce on its website, etc. to that effect.
When handling personal information beyond the scope necessary for achieving the Purposes of Use, the Company will seek each principal’s consent except for cases prescribed under items in Paragraph 3 of Article 18 of the Privacy Act.
- *Please see (3) of Clause 5 "Joint Use with the Company’s Group Companies and Business Partners " for the scope of Group companies.
3. Provision of Personal Data to/from Third Parties (please see Clause 7 “Handling of Specific Personal Information, etc.” below with respect to Specific Personal Information, etc. The Company may provide personal information to a third party in a foreign country. Please see here.)
- (1)The Company will not provide personal data to a third party without the relevant principal’s consent, unless:
- it is permitted under laws or ordinances;
- it is required to protect the life, body or assets of a person and it is difficult to obtain the principal’s consent;
- it is especially required to improve public health or promote sound development of youths and it is difficult to obtain the principal’s consent;
- it is required to cooperate with a government agency or local government or its contractor in its conduct of statutory affairs and it is possible that the conduct is hindered if the principal’s consent is obtained;
- the third party is an academic research institute or the like and the third party needs to handle the personal data for the purpose of an academic research (including the case that part of the purpose of handling of the personal data is academic research and excluding the case that a right or interest of an individual might be unjustly infringed);
- the personal data is provided 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.")
- the personal data is provided along with business transfer for a merger or any other reason; and
- the personal data is used 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 or personal related information to a third party (in the case of the provision of personal related information to a third party, when it is expected that the information is obtained by the receiving party as personal data), shall record matters concerning such provision (what type of personal data was provided to whom, etc.).
- (3)The Company may use personal related information provided by a third party as personal information after combining the information with other information held by the Company or otherwise processing the information.
4. Consignment of Handling of Personal Data and Specific Personal Information, etc.
The Company may, within the extent necessary for achieving the Purposes 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 selecting appropriate consignees based on the selection criteria at the consignees, concluding a consignment agreement with each consignee, and checking their handling of personal data and other information management systems.
For example, the Company consigns the handling of personal data and Specific Personal Information, etc. in relation to the following cases:
- Shareholder register management operation
- Operations relating to the preparation and submission of payment records, etc.
- Operations to maintain and operate information systems
5. Joint Use with the Company’s Group Companies and Business Partners
Personal data may be used jointly by the Company, Tokio Marine Group companies and their business partners in the following manner. There is no joint use of Specific Personal Information, etc.
- (1) Purposes of use
Same as the Purposes of Use stated in (1) through (13) in Clause 2 above
- (2) Personal data items:
- a. Personal data of shareholders (name, address, phone number, e-mail address, sex, date of birth, status on holding of the Company’s shares, etc.)
- b. Personal data of individuals who have made an inquiry, request, or the like to the Company (name, address, phone number, e-mail address, sex, date of birth, content of the inquiry, request, or the like)
- (3) Business operators and other joint users
- Group companies:
Please see here for the group companies of Tokio Marine Holdings.
Please see here for the group companies of Tokio Marine & Nichido.
Please see here for the group companies of Nisshin Fire & Marine Insurance.
Please see here for the group companies of Tokio Marine & Nichido Life Insurance.
Please see here for the group companies of Tokio Marine & Nichido Facilities.
- Business partners:
There is no business partner with whom the Company jointly use personal data.
- Group companies:
- (4) Party responsible for personal data management
Tokio Marine Holdings, Inc. (Please see here for its address, name of its representative, etc.)
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, academic research institute, or any party provided in each of the items in Paragraph 1 of Article 57 of the Privacy Act or in each of the items in Article 6 of the Ordinance for Enforcement of the Privacy Act, and information which is collected through visual observation or by taking a photograph of the individual and hence the external appearance is evident) 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 any third parties except in cases permitted under the My Number Act.
8. Notice of Matters, Disclosure, Correction, Suspension or the like of Use of Personal Data and Specific Personal Information, etc. Held by the Company under the Privacy Act
Please direct requests for notice of matters, disclosure (including disclosure of records of third party provision), correction, suspension or the like of use of personal data and Specific Personal Information, etc. held by the Company under the Privacy Act (“Requests for Disclosure, etc.”) to the "Contact Office" indicated in Clause 11 “Contact Information” below. After confirming the identification of the requesting party and having the requesting party complete a form designated by the Company, the Company will provide a response at a later date. The Company will charge a prescribed fee for responding to each request for notice or disclosure of purpose of use. Please see here for details on Requests for Disclosure, etc.
9. Safety Control Measures
The Company will take safety control measures for personal data and Specific Personal Information, etc. including measures to prevent divulgence, loss or damage to personal data and Specific Personal Information, etc. Please see here for specific security control measures.
10. Handling of Pseudonymously Processed Information and Anonymously Processed Information
The Company will properly handle pseudonymously processed information and anonymously processed information. Please see here for details on the handling of pseudonymously processed information and anonymously processed information.
11. Contact Information
The Company will appropriately and promptly respond to complaints and consultations regarding the handling of personal information, Specific Personal Information, etc., pseudonymously processed information (excluding that being personal information) and anonymously processed information.
Inquiries and consultations regarding the handling of personal information, Specific Personal Information, etc., pseudonymously processed information (excluding that being personal information) and anonymously processed information by the Company and the safety control measures thereof must be made to the office indicated below.
Contact Office
Legal & 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.)
See here for its address, name of its representative, etc.
- 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
- Revised on April 1, 2022