1.Details of the Company

• Name: 

  ConciergeBANK CO., LTD

• Address: 

  Midtown East 4F, 9-7-2 Akasaka, Minato-ku, Tokyo, 107-0052, Japan

• Name of representative: 

  Shinya Sonoda, Representative Director

2.Definition of Personal Information

• (1)

  In this Privacy Policy, personal information shall mean personal information as defined in Article 2, Paragraph 1 of the Personal Information Protection Act, i.e., information about a living individual, which falls under any of the following.

  • A. Information that can identify a specific individual by name, date of birth, or other description, etc., contained in such information (including information that can be easily cross-checked with other information and thereby identify a specific individual).
  • B. Items containing personal identification codes
• (2)

  In this Privacy Policy, “personal information requiring special consideration” means personal information requiring special consideration as defined in Article 2, Paragraph 3 of the Personal Information Protection Act, i.e., personal information that includes the person’s race, creed, social status, medical history, criminal record, the fact that the person has suffered harm due to a crime, and other descriptions specified by the Personal Information Protection Act enforcement order as requiring special consideration in handling to prevent unjust discrimination, bias, or other disadvantages to the person.

3.Purpose of Use of Personal Information

We will use your personal information for the following purposes.

4.limitation of use of personal information

We will not handle personal information beyond the scope necessary to achieve the purpose of use without the prior consent of the customer, except as permitted by the Personal Information Protection Act and other laws and regulations.

5.Proper Acquisition of Personal Information, etc.

We will acquire personal information in an appropriate and lawful manner to the extent necessary for our business. We will endeavor to delete or dispose of any unnecessary personal information in accordance with the terms and conditions of use. Identification documents submitted by customers will not be returned.

6.Security Control of Personal Information

We will implement appropriate security control measures to prevent the loss, falsification, leakage, etc. of customers’ personal information. In addition, we educate all executives and employees who handle customers’ personal information on the importance of protecting personal information, and when we outsource customers’ personal information, we supervise the outsourcing company appropriately. The main contents of the safety control measures are as follows.

• (1)

  Establishment of basic policy and discipline for the handling of personal information

  In order to ensure the proper handling of personal information, we have established this Privacy Policy regarding “compliance with related laws, regulations, guidelines, etc.” and “point of contact for questions and complaints,” as well as basic handling methods when acquiring, using, and storing personal information.

• (2)

  Organizational safety control measures

  In cases where there is more than one employee handling personal information, the Company separates those in positions of responsibility from others. In the event that a fact or indication of a violation of the Personal Information Protection Act, etc. is detected, a reporting and communication system is in place for those in the above responsible positions.

• (3)

  Human security management measures

  Training and other guidance regarding confidentiality of personal information is provided as needed.

• (4)

  Physical security management measures

  Measures are taken to prevent theft or loss of equipment, electronic media, and documents that handle personal information, as well as to ensure that personal information is not easily revealed when such equipment, electronic media, etc. are carried, including within the business site.

• (5)

  Technical security management measures

  A system is in place to protect information systems that handle personal information from unauthorized external access or unauthorized software.

7.Provision of Personal Information to Third Parties, etc.

When providing a customer’s personal information to a third party, we shall obtain the prior consent of the customer, except in cases permitted under the Personal Information Protection Act or other laws and regulations. However, this shall not apply in the following cases.

8.Provision of Personal Information to Third Parties located outside of Japan

• (1)

  We will provide your personal information to third parties, such as businesses outside Japan, only in the following cases:

  • A.
    With the consent of the customer
  • B.
    When the third party to which the personal information is provided is in a country or region that is stipulated by law as a country or region that has a personal information protection system of a level equivalent to that of Japan (see a in the next item A)
  • C.
    When the third party to which personal information is provided has established a system required under laws and regulations to continuously take measures equivalent to those required to be taken by business operators handling personal information in Japan
• (2)

  If the third party to whom the customer’s personal information is provided in accordance with the preceding item is located outside of Japan, the information regarding the protection of personal information in that country or region is as follows (based on the information available on the website of the Personal Information Protection Commission as of October 30, 2023. Please check the website for the latest information).

  • A. 
    Countries subject to GDPR (EU General Data Protection Regulation) and the United Kingdom (designated by the Personal Data Protection Commission as foreign countries, etc. with a system for the protection of personal information that is recognized as having an equivalent level of protection as Japan. See Personal Data Protection Commission Notification No. 1 and No. 5 of 2019)
    
    Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Liechtenstein, Iceland, Norway, UK
  • B. 
    Countries/territories that have obtained a certificate of sufficiency in accordance with Article 45 of the GDPR (the European Commission has recognized that they have an adequate level of data protection in accordance with the GDPR. See Privacy Commission website: https://www.ppc.go.jp/enforcement/infoprovision/EU/
    Argentina, Andorra, United Kingdom (including the Crown Territories of Guernsey, Jersey and the Isle of Man) Israel, Uruguay, Canada, South Korea, Switzerland, the Faroe Islands of the Kingdom of Denmark, and New Zealand
  • C. 
    Member countries/regions of APEC’s CBPR system (They have laws and regulations that comply with APEC’s Privacy Framework. See Privacy Committee Website: https://www.ppc.go.jp/enforcement/cooperation/international_conference
    U.S.A., Mexico, Canada, Singapore, South Korea, Australia, Taiwan, Philippines
  • D. 
    Countries/regions that address all 8 principles of the OECD Privacy Guidelines other than A. through C. above (The OECD Privacy Guidelines are based on the following 8 basic principles: (1) Principle of Collection Restriction, (2) Principle of Data Content, (3) Principle of Purpose Clarification, (4) Principle of Use Restriction, (5) Principle of Security Protection, (6) Principle of Disclosure, (7) Principle of Individual Participation, (8) Principle of Responsibility. See Personal Information Protection Commission website: https://www.ppc.go.jp/enforcement/infoprovision/laws/
    China, Hong Kong, Turkey, Brazil, Peru, South Africa, Morocco
• (3)

  All such third parties to whom we provide your personal information in the countries/regions listed in the preceding items A through D have taken measures to protect your personal information corresponding to the eight principles of the OECD Privacy Guidelines. Some of the situations in countries/regions other than those listed in the preceding items A through D can be found on the website of the Personal Information Protection Commission (https://www.ppc.go.jp/enforcement/infoprovision/laws/), so please check there.

9.Disclosure of Purpose of Use of Personal Information, etc.

• (1)

  When a customer makes a request for notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, deletion, or suspension of provision (hereinafter referred to as “disclosure, etc.”) of personal information, the Company will promptly respond to the request after confirming that the request is made by the customer in question. However, if the disclosure, etc. falls under any of the following cases, all or part of the information may not be disclosed.

  • A. When there is a risk of harm to the life, body, property, or other rights or interests of the person or a third party
  • B. If there is a risk of significant hindrance to the proper conduct of our business
  • C. In case of violation of other laws and regulations
• (2)

  When making a request for disclosure, etc., the applicant is requested to clearly state in writing the applicant’s name, address, and matters requested (in the case of a request for correction, the correct information to be corrected must be stated, and in the case of a request for suspension of use, the reason for the suspension must be clearly stated), affix the applicant’s seal, and present documents necessary for identification. In addition, the applicant may be required to pay a fee as specified by the Company when responding to such a request.

10.Handling of Sensitive Personal Information

When acquiring sensitive personal information of a customer, we shall obtain the prior consent of the customer, except in cases permitted under the Personal Information Protection Act or other laws and regulations.

11.Use of Cookies

• (1)

  Our website uses a technology called ‘Cookies.’ A cookie is a mechanism that temporarily stores specific information in the user’s communication device, etc., as data, and identifies the user based on that data each time the user connects. We provide services that rely on the use of cookies. Therefore, you may choose to disable cookies, but as a result, some or all of our website functions may not be available. Disabling cookies can be set in the user’s browser.

• (2)

  The Company may use cookies, etc. (including web beacons, UIDs, and other technologies, hereinafter simply referred to as “cookies, etc.”) to obtain customer purchase history, service provision history, browsing and other activity history, information on the terminal used, network information (IP address, etc.), etc., and analyze them as personal information or information related to customers, and use them to develop, improve and enhance products and services, as well as to advertise and provide information on products and services that match the interests, preferences and trends of customers.

• (3)

  The Company obtains information related to individuals that is not personal information (including purchase history, location information, browsing and other activity history, terminal information, and network information (IP address, etc.) obtained through cookies, etc.) from third parties and use it to develop, improve, and enhance products and services, as well as to advertise and provide information on products and services that match your interests, preferences, and trends.

12.Use of Google Analytics

Our website uses Google Analytics provided by Google, Inc. in order to understand usage conditions and to improve and enhance site content. Google Analytics uses cookies and other technologies to collect access information, but this information is collected anonymously and does not personally identify you. Please refer to the following Google website for the terms of use and privacy policy of Google Analytics.

Google Analytics Terms of Use:

https://www.google.com/analytics/terms/jp.html

Google Privacy Policy:

https://www.google.com/intl/ja/policies/privacy/

Google Analytics Opt-Out Add-on:

https://tools.google.com/dlpage/gaoptout?hl=ja

13.Revisions to this Privacy Policy

We will review the operation of our handling of your personal information from time to time and strive for continuous improvement, and may revise this Privacy Policy from time to time as necessary. The revised Privacy Policy will be made public on the Company’s website, etc.

14.Contact for inquiries regarding the handling of personal information

For requests for disclosure, opinions, questions, complaints, and other inquiries regarding the handling of personal information, please contact the following;

• Midtown East 4F, 9-7-2 Akasaka, Minato-ku, Tokyo, 107-0052, Japan
• Hours: 10:00 a.m. to 5:30 p.m.
  (except Saturdays, Sundays, national holidays, and year-end and New Year holidays)
• Email: luxurex@kconciergebank.com
• ConciergeBANK CO., LTD Inquiry Desk