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| WILLCOM Inc. ("WILLCOM" hereinafter), in recognition of the importance of privacy and its role as a telecommunications carrier, hereby publishes and pledges to adhere to this privacy policy, which was formulated so as to provide for appropriate handling and treatment of personal information. This privacy policy is based on guidelines regarding the confidentiality of telecommunications and the protection of personal information by telecommunications carriers and is also based on other applicable laws and ordinances. |
| 1. Purpose of use of personal information etc. |
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| WILLCOM will not obtain personal information through false statements or other inappropriate means. WILLCOM will only use personal information that it has obtained for specific purposes of use stated in advance and only within the scope necessary to achieve the purposes set forth in 2) below. |
| 1) |
Personal information |
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For the purposes of this policy, "personal information" shall consist of the following information: |
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Name, address, date of birth, employer, occupation, contact information, gender |
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Information regarding financial institution accounts; information regarding credit cards |
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Mail addresses, information noted on driver's licenses, passports and other similar documents |
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Nature of transactions with WILLCOM, registered seal impression, personal identification number |
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Other information that would or could potentially enable the identification of specific individuals |
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| 2) |
Purpose and scope of use |
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Personal information provided by customers when they enter into contracts etc. with WILLCOM shall only be used for the following purposes and within the following scopes: |
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Identification of contracting customers |
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Screening at time of subscription |
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Notification, invoicing and collection of fees and charges |
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Confirmation of services, notification of changes etc. |
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Notification of initiation, modification, suspension, elimination etc. of services |
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Surveys regarding the services of WILLCOM; notifications regarding campaigns etc. |
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Response to customer inquiries and other customer services |
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Maintenance, system failure responses and other support services |
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Exchange of information on unpaid charges with other businesses for cases in which unpaid charges remain after cancellation of contracts) |
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Exchange of information with other businesses on subscribers subject to suspension of service (including cancellation of contracts) due to transmission of nuisance mail and other similar activities |
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WILLCOM may use personal information that it has obtained for the technical and sales purposes of WILLCOM, but will only do so after modifying it so as to render it impossible to identify specific individuals.
The purposes of use described above are subject to change, but will only be changed within a scope deemed to be reasonable and substantially related to the original purposes of use and only within a scope necessary to provide telecommunications services. |
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| 3) |
Exceptions to purposes of use |
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WILLCOM may handle personal information in ways that exceed the scope necessary for achievement of the purposes of use described above when consented to by the contracting customer at the time personal information is used or furnished, when it is deemed not illegal due to other reasons, and in the following cases: |
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When mandated by relevant laws and ordinances etc. |
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When necessary to protect life, person or property and it is difficult to obtain the consent of the relevant individual |
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When particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the consent of the relevant individual |
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When necessary to cooperate with the execution of legally-defined duties on the part of central government institutions, local government agencies or their deputies and obtaining the consent of the relevant individual would potentially impair the execution of said duties |
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However, even in these cases, WILLCOM will make a careful judgment as to whether use is truly necessary. |
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| 2. Handling of personal information |
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WILLCOM will at all times endeavor to maintain the accuracy and timeliness of the personal information it handles so as to ensure that personal information is used and provided in an accurate manner in accordance with the purposes of use. |
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| 2) |
In handling personal information, WILLCOM will in principle established retention periods within the scope necessary for the purposes of use and will delete personal information without delay at the conclusion of the retention period or after the achievement of the purpose of use. Notwithstanding the provisions of the preceding paragraph, WILLCOM may not delete personal information upon the conclusion of the retention period or achievement of the purpose of use in the following cases: |
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When required to retain personal information under relevant laws and ordinances |
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When consented to by the relevant individual |
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When WILLCOM retains personal information only to the extent required by its operations and has substantial reasons for not deleting personal information |
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When there are other extraordinary reasons for not deleting personal information |
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WILLCOM will not furnish personal information to third parties without the prior consent of the contracting customer except in the following circumstances: |
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When mandated by relevant laws and ordinances etc. |
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When necessary to protect life, person or property and it is difficult to obtain the consent of the contracting customer |
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When particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the consent of the contracting customer |
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When necessary to cooperate with the execution of legally-defined duties on the part of central government institutions, local government agencies or their deputies and obtaining the consent of the contracting customer would potentially impair the execution of said duties |
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| 3. Disclosure and amendment of personal information |
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| 1) |
WILLCOM will disclose relevant personal information without delay, in principle by furnishing the contracting customer with written copies, when requested by the contracting customer to disclose the personal information regarding the contracting customer retained by WILLCOM, provided that the contracting customer fills in the required information on the application form provided by WILLCOM and submits it together with any documentary attachments required. Notwithstanding, WILLCOM reserves the right not to disclose all or any part of the relevant personal information when doing so would impair the confidentiality of telecommunications and in any of the circumstances described below: |
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When there is potential to injure the life, person, property, or other rights and/or interests of the relevant individual or third parties |
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When there is the potential to severely impair the appropriate execution of the business of WILLCOM |
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When disclosure would be in violation of relevant laws and ordinances |
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Fees (set forth separately) may be charged for the disclosure of personal information. |
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In the event that it receives a request from a contracting customer to amend etc. personal information regarding the contracting customer, WILLCOM will investigate without delay and will amend etc. personal information without delay if it finds that personal information is contrary to fact, the retention period for personal information has elapsed, or it finds that such personal information has not been handled in an appropriate manner. |
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The following agent/attorneys may submit requests for disclosure or amendment etc. of personal information handled by WILLCOM by filling in the required information on the application form provided by WILLCOM and submitting it to WILLCOM together with any attached documentation required: |
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Statutory attorneys of minors and adult wards |
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Agents and attorneys nominated by the contracting customer to request disclosure etc. |
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WILLCOM exchanges information on non-paying customers with other telecommunications carriers in order to prevent non-payment of charges. Non-payment information will be managed appropriately and with the utmost care and will only be used for the purposes of screening at the time of subscription. |
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| 5) |
Location information and other similar personal information will be handled in accordance with "Guidelines on the Protection of Personal Information in the Telecommunications Industry" issued by the Ministry of Internal Affairs and Communications (Ministry of Internal Affairs and Communications Notification No. 695, dated August 31, 2004). |
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| 4. In-house systems |
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WILLCOM restricts employees authorized to access personal information, and even those authorized to access personal information are given access rankings according to the scope of personal information they are authorized to handle, thereby restricting information queries and modifications outside the scope necessary for business purposes. WILLCOM has rigorous management controls in place for all matters related to the confidentiality of telecommunications. |
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WILLCOM uses the "Telecommunications Network Safety and Reliability Standards" (Ministry of Posts and Telecommunications Notification No. 73 of 1987) to provide for the protection of information on telecommunications networks, prevent unauthorized access and manage information in a safe and secure manner. |
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WILLCOM conducts annual training on personal information for all employees so as to improve each individual employee's awareness of personal information and its handling. |
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| 5. Supervision of outsourcees |
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In the event that it outsources all or any part of the handling of personal information, WILLCOM will provide such supervision as is necessary and appropriate to the outsourcee so as to maintain the safety and security of the personal information entrusted to the outsourcee. |
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In the event that it outsources all or any part of the handling of personal information, WILLCOM will select parties deemed able to handle personal information in an appropriate manner and will include in outsourcing contracts appropriate provisions for safety, confidentiality, re-outsourcing terms (including whether re-outsourcing is permitted and, if permitted, matters related to the selection and supervision of re-outsourcees) and other matters related to the handling of personal information. |
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| 6. Contact |
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WILLCOM has established the following dedicated liaison for all inquiries concerning the use, submission, disclosure and amendment etc. of personal information, requests to disclose personal information, and other opinions and requests related to the handling of personal information, and will endeavor to respond in an appropriate and timely manner.
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Personal Information Liaison
WILLCOM/WILLCOM OKINAWA Personal Information Liaison
C/O WILLCOM, Inc
3-4-7 Toranomon, Minato-ku, Tokyo 105-8477
Contact hours: Monday through Friday 10:00-17:00 (closed Saturdays, Sundays, holidays, Golden Week, New Year's holidays)
Tel: 03-5400-6346
Fax: 03-5400-6368 |
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| 7. Certified Personal Information Protection Organization |
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WILLCOM is a member of Nippon Information Communications Association , a certified personal information protection organization. For feedback and enquiries on the association's handling of personal information, please contact us at:
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Electronic Communications Personal Information Protection Center
Contact number: 03-5907-3803 (Call charges apply)
Opening Hours: 10:00 to 17:00 (Closed on Sat, Sun, Public Holidays and year end/new year holidays)
Address: 〒170-8585
2-11-1 Sugamo, Toshima-ku, Tokyo
Nippon Information Communications Association
Electronic Communications Personal Information Protection Center
Feedback Department
URL:http://www.dekyo.or.jp/suishin/index.html |
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