Citizen T.I.C. Co., Ltd.

We, Citizen T.I.C. Co., Ltd. believe that the protection of personal information acquired from our customers, clients, business associates, shareholders and all other persons concerned with our business ("individuals") is an important social responsibility. To protect all those personal information, we comply with the Act on the Protection of Personal Information Law (Act No.65 of 2015) ("the Protection of Personal Information Law ") and other Japanese applicable laws and regulations including the ministerial guidelines and our Privacy Policy. We implement this Privacy Policy to provide guidance for protection, management and use of all personal information and anonymously processed information held by us.
Except as otherwise provided for in this Privacy Policy, the definition of the terms as used in this Privacy Policy shall be followed by the definition of the Protection of Personal Information Law and other Japanese applicable laws and regulations including the ministerial guidelines.
Notwithstanding this Privacy Policy, we handle personal information containing individual number and specific personal information in accordance with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No.27 of 2013) and other Japanese applicable laws and regulations including the ministerial guidelines.

• 1．Acquisition of personal information
• 2．Purpose(s) of the utilization
• 3．Management of personal data
• 4．Non-disclosure to third parties
• 5．Request for disclosure, amendment, deletion or discontinuance of usage of retained personal data
• 6．Personal information of person under 20 years old
• 7．Security on website
• 8．Revisions
• 9．Inquiries

1. Acquisition of personal information

When acquiring personal information, we will obtain the individuals' consent except in cases in which handling of personal information is based on laws and regulations.
We will clearly notify the individuals the purpose of the use of personal information upon its acquisition, and we will use the personal information only within the scope necessary for the achievement of the purpose(s) of use which has been specified to the individuals.
We will not acquire special care- required personal information except in cases in which we obtain in advance the individuals consent or is based on laws and regulations.

2. Purpose(s) of the utilization

In principal, we use the acquired personal information within the scope of the following purpose;

1. Personal information of our customers
   ①　Conduct of questionnaire survey, implementation of product and service monitoring programs for our service improvement and development of our products or the like;
   ②　Provision of information;
   ③　To properly response to inquiries or consultation;
2. Personal information of officers and employees of business associates
   ①　Personnel management and administration;
   ②　Notification or reporting in compliance and accordance with applicable laws and regulations;
   ③　Compliance under the labor laws and regulations for retired employees;

3. Management of personal data

We manage all personal data in a proper manner in principal, otherwise stipulated by laws, to prevent unauthorized access, loss, alternation, leakage, damage or loss, and to ensure the safety and accuracy of personal data acquired. We appoint supervisors in every section handling personal data, and the supervisors undertake the necessary and appropriate measures to protect and use personal data in a proper manner.

4. Non-disclosure to third parties

We do not disclose personal data acquired to any third parties, except in the following cases:

1. When the individuals have given a prior consent to the disclosure;
2. When the personal data is unable to lead to identification;
3. When we outsource or subcontract our business activities in part to third parties ("Subcontractors"), in which case, personal data is only used within the purpose, of which individuals have given prior consent to us. (In this case, we are fully aware that we are responsible for the outsource or subcontracting. We carefully choose proper Subcontractors and will exercise necessary and appropriate supervision over the Subcontractors to ensure the security control of the personal data and prevent any misuse or leakage);
4. When the disclosure of personal data is required by laws, regulations or judicial orders;
5. When the disclosure of personal data is necessary for the benefit of the relevant individuals or the public interest, and difficult to obtain individuals' consent at the time;
6. When personal data is provided as a result of succession of the business transfer, corporate division, in merger or otherwise (In such case, personal data is only used within the scope and purpose which individuals have given prior consent);
7. When personal data is to be jointly utilized based on laws and regulations by specified person and is provided to the specified person.

5. Request for disclosure, amendment, deletion or discontinuance of usage of retained personal data

1. We do our best to properly meet request(s) from individuals regarding handling retained personal data such as disclosure, amendment, deletion or discontinuance of the usage of retained personal data (collectively "Request"), after confirming the individual's Request and identity.
2. When making Request, please fill in and issue the below specified Request form and send us by mail, together with the below specified identity verification documents enclosed, to the address shown below in this policy.
   Please download the Request form and refer to the further information regarding the required identity verification documents below;
   
   ・Request Form
   ・Identity Verification Documents
   ・Identity Verification Documents of Representative
3. In order to prevent leakage or damage of personal information and maintenance of accuracy, we will provide written response after confirming the needed information in the specified Request form and identity verification documents.
   While we make effort to provide prompt response to meet the Request, please note that it may take time as we work on confirmation and identification to ensure quality and accuracy.
4. Please be also advised that we do not return those Request form and the identity verification documents received. We will maintain the Request form received in a proper manner and dispose the identity verification documents by appropriate means.

6. Personal information of person under 20 years old

We protect and treat personal information of person under 20 years old in equal measure as we protect other individuals' personal information. We will obtain parental guardian's consent as needed, when we acquire personal information of person or receive Request from person under 20 years old.

7. Security on website

We take necessary and proper measures to operate and manage our own website for the security and safe control purpose, and in order to do so, we operate management and system controlling structure, further out the access restriction on our web server.
Please be advised that when individuals contact us via our website, all the information is encrypted and protected by transmission using SSL (Secure Sockets Layer) protocol for safety purpose.
We may use cookies in part of our service on our website, in order to only help us better serve you as individuals such as statistical process of website access information, though, we will ensure that we will not use cookies to identify or to violate individuals' privacy or environment.

8. Revisions

Please be advised that we may, from time to time revise this Privacy Policy, in order to improve our management and safeguard system, or to comply with latest laws and regulation as needed.

9. Inquiries

With respect to inquiries concerning your personal information, please contact us at;