Privacy Policy

1. Acquisition and Use of Personal Information

1. The Company collects and uses personal information in a lawful and proper manner to the extent necessary for the conduct of business.
2. The Company collects personal information through individuals’ contract data, accounts, schedules, and other documentation provided by other insurance companies.

2. Purposes of Use of Personal Information

The Company receives personal information from other insurance companies to the extent necessary for the purposes of use described below in order to contribute to the management stability and the expansion of the scope of underwriting of other insurance companies through reinsurance. The Company may modify a purpose of use described below only to the extent reasonably deemed to have relevance to the original purpose of use. In such cases, the Company will officially announce the details of the modification on its website or by other means. The Company will not use personal information for any other purpose.

• Reinsurance contract underwriting examinations
• The execution of reinsurance contracts or the provision of incidental services
• Payment of reinsurance claims
• The maintenance or management of reinsurance contracts
• Other matters incidental to the Company’s business (Company-sponsored seminars, etc.)

3. Items of Personal Information Collected

The personal information collected is information necessary for the conclusion of reinsurance contracts or the payment of reinsurance claims, which includes name, date of birth, gender, address, phone number and the details of insurance contracts.

4. Provision of Personal Information to Third Parties and Collection of Personal Information from Third Parties

1. The Company shall not provide personal data it has collected to any third party (including any party in a foreign country) except in accordance with laws or ordinances.
   The Company shall not collect personal information from third parties for any reason other than those stated in 2. Purposes of Use of Personal Information above.
2. Unless otherwise stipulated by laws and ordinances, in the case of providing personal information to a third party, the Company shall record matters concerning such provision (date, the identity of the third party receiving the personal information from the Company, the type of personal information provided, etc.), and in the case of collecting personal information from a third party (including the case where information concerning individuals is collected as personal data), the Company shall check and record matters concerning such collection (date, the identity of the third party providing the personal information to the Company, the type of personal information collected, how the third party providing the personal information to the Company collected such information, etc.).

5. Provision to a third party of information concerning individuals

1. Unless otherwise stipulated by laws and ordinances, when the Company assumes that a third party is collecting information concerning individuals as personal data, the Company will not provide the subject data without first confirming that the third party has obtained from the subject persons agreement that the subject information be collected.
2. Unless otherwise stipulated by laws and ordinances, in the case of providing information concerning individuals to a third party based on the confirmation in (1) above, the Company shall check and record matters concerning such provision (date, the identity of the third party receiving the information from the Company, the type of information concerning individuals provided, how the third party obtained the agreement of the subject persons, etc.).

6. Outsourcing of Handling of Personal Data

When outsourcing the handling of personal data to external institutions within the scope necessary for achievement of the purposes of use, the Company applies criteria for selection of institutions to which the handling is to be outsourced, checks in advance the information management systems of the institutions, and carries out necessary supervision of the institutions, including monitoring of the institutions’ business execution after outsourcing of handling of personal data.

7. Handling of Credit Information

In accordance with the Ordinance for Enforcement of the Insurance Business Act, the Company will not use information provided by any credit information organization (which means any organization that collects information regarding individuals’ ability to repay debts and provides such information to the Company) regarding individuals’ ability to repay debts for any purposes other than investigating the individuals’ ability to repay debts.

8. Handling of Sensitive Information

The Company shall not collect, use, or provide to any third party any personal information whose handling requires special consideration specified by the Act on the Protection of Personal Information or any personal information regarding membership in a labor union, ancestry, domicile by birth, healthcare or sexual life (excluding information that is made open to the public by the individual, a government organization, a local government, an academic research institutes, a person described in each item of Article 57, Paragraph 1 of the Act on the Protection of Personal Information or a person described in each item of the Enforcement Regulations, or obvious information from an external form obtained by observation of the individual or capturing the image of the individual; hereinafter “sensitive information”) unless the party falls under the following conditions.

• With the consent of the person, when sensitive information is acquired, used or provided to third parties to the extent necessary for the purpose of ensuring proper business execution or operation of the insurance business
• When sensitive information is acquired, used or provided to third parties to the extent necessary for the purpose of execution of business including payment of insurance claims where inheritance procedures are involved
• When sensitive information of the employee who is affiliated or associated with organizations including political or religious organizations or labor union is acquired, used or provided to third parties to the extent necessary for the purpose of execution of receipt of insurance premiums, etc.
• Cases in accordance with laws and ordinances
• When it is necessary for the protection of the life, body, or property of an individual
• Cases in which the handling of personal information is specially necessary for improving public health or promoting the sound growth of children
• When it is necessary for the execution of affairs in accordance with laws and ordinances by the national government or local government, or any parties entrusted by the above units
• When it is for academic research purposes

9. Notification, Disclosure, Correction, or Cessation of Use of Personal Data in Accordance with the Personal Information Protection Act

The Company responds appropriately and promptly when it receives requests for notification, disclosure, correction, or cessation of use of personal data. Please refer to the contact information below. The Company performs a procedure by which it has the requesting party fill in its prescribed form and confirms that the requesting party is the subject person, and then it provides a response at a subsequent date. We appreciate your understanding that costs for handling charges may incurred in case of the notification and disclosure of the use of the retained personal data.

10. Summary of Measures to Ensure the Secure Management of Personal Data

The Company has established the Personal Information Handling Regulations and other rules to prevent any divulgence or loss of or damage to personal data handled by the Company and to ensure that personal data is otherwise securely managed and has implemented security measures, including the establishment of a structure for enforcing security management measures based on those rules and regulations. When handling personal information, the Company always implements appropriate measures to ensure personal information is accurate and current. The main content of the Personal Information Handling Regulations is as follows.

1. Establishment of a basic policy
   To ensure the proper handling of personal data, the Company will prepare, and revise as necessary, this declaration concerning compliance with relevant laws, ordinances, and guidelines; matters related to security management measures; contacts for question and complaint processing; etc.
2. Establishment of handling regulations for the safe management of personal data
   For each level of collection and input, usage and processing, storage and preservation, transport and transmission, deletion and disposal, and other activities; establish, and revise as necessary, regulations specifying handling methods, the persons responsible and the persons to do the work, the tasks involved, etc.
   For questions concerning security management measures, please refer to the contact information below.
3. Monitoring of institutions to which the handling is outsourced
   When outsourcing the handling of personal data, establish, and regularly revise, handling regulations for the outsourcing in order to ensure the selection of an institution which properly handles personal data and to ensure the implementation of security management measures at the institution.

1. Acquisition and Use of Specific Personal Information

The Company collects and uses specific personal information in a lawful and proper manner. Unless otherwise stated by laws and ordinances, the request for the provision of specific personal information is prohibited.

2. Extent of Use of Specific Personal Information

The Company uses specific personal information to the extent of use described below in accordance with laws and ordinances. The Company shall not acquire, use or provide to third parties the specific personal information other than the purposes listed below.

1. Execution of affairs in accordance with laws and ordinances concerning “Individual Number”
   1. Affairs concerning the preparation of report of payment for remuneration or rewards, distribution of dividends or surplus, interest on funds, real estate charges, acquisition of real estate, etc.
   2. Affairs including the preparation of withholding record of the income of the employee (including the dependents) and the notification for the unemployment insurance, health insurance and pension insurance
2. Under the following conditions in accordance with laws and ordinances
   1. When payment of money occurs during severe disasters
   2. Cases in which the handling of personal information is necessary for the protection of the life, body, or property of an individual and in which the consent of the person is obtained or it is difficult to obtain the consent of the person

3. Outsourcing of Handling of Specific Personal Information

The Company may outsource part of the affairs concerning “Individual Number” to another business body. When outsourcing the handling of specific personal information, the Company applies criteria for selection of institutions to which the handling is to be outsourced, checks in advance the information management systems of the institutions, and carries out necessary supervision of the institutions.

4. Summary of Measures to Ensure the Secure Management of Specific Personal Information

The Company has implemented sufficient security measures, including the establishment of the handling regulations and the structure for enforcing security management measures to prevent any divulgence or loss of or damage to specific personal information handled by the Company and to ensure that specific personal information is otherwise securely managed. The main content of the Specific Personal Information Handling Regulations is as follows.

1. Establishment of a basic policy
   To ensure the proper handling of personal data, the Company will prepare, and revise as necessary, this declaration concerning compliance with relevant laws, ordinances, and guidelines; matters related to security management measures; contacts for question and complaint processing; etc.
2. Establishment of handling regulations for the safe management of personal data
   For each level of collection and input, usage and processing, storage and preservation, transport and transmission, deletion and disposal, and other activities; establish, and revise as necessary, regulations specifying handling methods, the persons responsible and the persons to do the work, the tasks involved, etc.
   For questions concerning security management measures, please refer to the contact information below.
3. Monitoring of institutions to which the handling is outsourced
   When outsourcing the handling of personal data, establish, and regularly revise, handling regulations for the outsourcing in order to ensure the selection of an institution which properly handles personal data and to ensure the implementation of security management measures at the institution.

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<Contacts>

The Toa Reinsurance Company, Limited
Compliance Department
Contact for Personal Information
Tel:　03-3253-3309　
(Operation hours: 9:30a.m. - 5:00p.m. Closed on Sat., Sun., Public Holidays, the Year-end and New Year Holidays)

The Company is a member of The General Insurance Association of Japan, an authorized personal information protection organization. The Association handles inquiries and complaints concerning the handling of personal information of the affiliated companies.

<Contacts>

The General Insurance Association of Japan, General Insurance ADR Center (General Insurance Counseling and ADR Center)

• Address:
  7/F WATERRAS ANNEX, 2-105 Kanda-awajicho, Chiyoda-ku, Tokyo, 101-0063
• Tel:
  03-3255-1470
  (Operation hours: 9:00a.m. - 5:00p.m. Closed on Sat., Sun., Public Holidays, the Year-end and New Year Holidays)
• Website:
  https://www.sonpo.or.jp/en/