April 1, 2024

1.Introduction

Shindengen Electric Manufacturing Co., Ltd. (hereinafter referred to as "the Company") considers that it is an important responsibility of the Company to appropriately manage personal related information or personal information that can identify a specific individual by the name, address, company name, e-mail address, telephone number, etc. of customers, business partners, shareholders, etc. (hereinafter referred to as "customers, etc.") (hereinafter referred to as "Personal Information, etc."), develop measures for customers, etc. to provide Personal Information, etc. with a sense of security, and to consider the rights of privacy of customers, etc., and shall set forth the basic policy for handling Personal Information, etc. (hereinafter referred to as "privacy policy") as follows.

2.Measures to Be Taken for Safety Management

The company takes the following measures to prevent leakage, loss, or damage and other appropriate management of personal information (including personal information we are trying to obtain).

(1)Establishment and publication of privacy policy
The Company hereby establishes and publishes a privacy policy to ensure the proper handling of Personal Information, etc. in compliance with Act on the Protection of Personal Information of Japan and the applicable law concerning the protection of personal information of foreign countries. This privacy policy is in compliance with Act on the Protection of Personal Information and Guidelines, etc. of Japan (hereinafter referred to as the "Law, etc.").

(2)Development of Disciplines Regarding the Handling of Personal Information, etc.
The Company has established in-house regulations governing the handling methods, persons in charge, responsible persons and their responsibilities at each stage, including the acquisition, use, storage, provision, deletion, and disposal of Personal Information, etc.

(3)Security Control Measures
i)Systematic security control measures
・The person in charge of the handling of Personal Information, etc. shall be appointed from among the officers.
・Clarify the person handling Personal Information, etc. and the extent of Personal Information, etc. handled by the said person.
・In the event that any fact or sign of violation of Laws, etc. or in-house regulations is identified, establish a reporting system to the relevant person in charge. 　
・Periodically conduct self-inspections of the status of the handling of Personal Information, etc. and conduct actual inspections by other divisions, etc.
ii)Human security control measures
・The Legal＆Compliance Department gives regular education and training regarding explanation of the outline of Laws, etc. and matters to be noted concerning the proper handling of personal information, etc.
・The Company concludes a written pledge with its employees containing confidentiality matters concerning Personal Information, etc.
iii)Physical security control measures
・Place access control and restrictions on equipment etc. brought in by employees in areas where Personal Information, etc. is handled and take measures to restrict and prevent access to Personal Information, etc. by unauthorized employees
・Take measures to prevent theft or loss of equipment, electronic media and documents, etc. that handle personal information, etc.
・When transporting equipment, electronic media, etc., that handle Personal Information, etc., including transfer within the business office, measures will be taken to prevent Personal Information, etc. from being easily identified.
iv)Technical security control measure
・Access control shall be implemented to limit the extent of personnel in charge and Personal Information, etc. to be handled.
・Introduce a system to protect information systems that handle Personal Information, etc. from unauthorized access from the outside or unauthorized software.
v)Grasping the external environment
When handling personal data in a foreign country (including the use and consignment of cloud service providers in foreign countries), we will take appropriate measures to ensure the security management of personal data after understanding the systems related to the protection of personal information in the foreign country concerned. For inquiries regarding the name of the foreign country, the system for the protection of personal information in the foreign country, and the appropriate measures necessary for safety management, please use the specified form (click here ) .

3.Proper Handling of Personal Information, etc.

(1)With respect to the acquisition of Personal Information, etc.
The Company may acquire Personal Information, etc. of our customers through the viewing of our website, participation in various events such as exhibitions, and transactions. When acquiring Personal Information, etc., the Company shall publish the required information such as the items to be handled (name, address, company name, department, title, e-mail address, telephone number, web site browsing history, Cookie, etc.), the purpose of use, etc., in advance in the relevant privacy policy and publish such information in a manner that is easily accessible to the individual.
When acquiring special care-required personal information that includes sensitive information such as race and creed, we will not obtain such special care-required personal information without obtaining the consent of the person in question, except in cases that fall under exceptional items permitted by Laws, etc. When obtaining personal information from a third party, we shall comply with the disciplines such as the obligation to record.

(2)With regard to the use of personal information,
The Company will use Personal Information, etc. obtained from customers within the extent of "Purpose of Use of Personal Information, etc.*" . In the event the purpose of use is changed, the purpose of use after the change shall be announced. In addition, the Company will not use Personal Information, etc. by any means that encourages or threatens to induce illegal or unlawful acts. When it is no longer necessary to use Personal Information, etc., the Company shall strive to delete such Personal Information, etc. without delay.

(3)Provision of Personal Information, etc. to a Third Party
Except for the cases listed in (i) through (v) below, the Company will not provide Personal Information, etc. to any third party without obtaining the prior consent of the individual concerned.
(i) cases based on laws and regulations
(ii) cases in which there is a need to protect a human life, body or fortune, and when it is difficult to obtain a principal's consent
(iii) cases in which there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain a principal's consent
(iv) cases in which there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a principal's consent would interfere with the performance of the said affairs
(v) In the case where the third party is an academic research institution, etc., and it is necessary for the third party to handle the personal data for academic research purposes (including cases where part of the purpose of handling the personal data is for academic research purposes, except when there is a risk of unfairly infringing on the rights and interests of the individual).
In addition, when providing personal related information to a third party, in the event it is assumed that the third party to whom such personal related information is provided will use such personal related information in association with other data as personal data, the Company shall confirm in advance that such third party has obtained the consent of the individual of such personal related information. In addition, pseudonymized processed information shall not be provided to any third party except in the case set forth in the preceding clause.

(4)Provision of Personal Information (Personal Data) to a Third Party in a Foreign Country
Except in the case of taking measures stipulated by Act on the Protection of Personal Information, we will not provide Personal Information, etc. to any third party without prior consent of the data subject.

(5)Entrustment of Personal Information (Personal Data)
We may entrust the acquired personal information (personal data) to a third party within the extent of the achievement of the Purpose of Use. In the event the handling of personal data is entrusted in whole or in part, the Company shall conduct necessary and appropriate supervision of the entrusted company (including business operators in foreign countries) in order to ensure the security management of the entrusted personal data through the entrustment agreement, etc.

(6)Joint Use of Personal Information, etc.
We will jointly use the acquired personal information within the extent of the purpose of use in accordance with the following items (i) through (iv).
(i) Items of personal data to be shared:
Name, address, company name, department, title, e-mail address, telephone number, fax number, personal related information including web site browsing history and Cookie
(ii) Scope of joint users:
Our group companies and companies that have signed dealer contracts (click here)
(iii) Those who are responsible for the management of such personal data in the case of joint use:
Address: 3-14-1, Saiwai-cho, Asaka-shi, Saitama
Representative Director and President of Shindengen Electric Manufacturing Co., Ltd., Nobuyoshi Tanaka (Executive Officer, In charge of Legal & Compliance, Shoji Chiba)
(iv) Purpose of use: Refer to 3 (2) above "Purpose of Use of Personal Information, etc."

Outsourcing of Processing of Personal Information

The Company may outsource the processing of Personal Information it obtains to third parties to the extent necessary to achieve the purposes of use. In doing so, the Company ensures, mainly through contracts, etc., that contractors take appropriate security control measures with respect to the Personal Information. If the Company outsources the processing of Personal Information to third parties outside Japan, the Company will fulfill a statutory duty of keeping records, if applicable.

4.Matters concerning retained personal data

(1)The address and name of the business operator handling personal information, as well as the name of the representative:
3-14-1, Saiwai-cho, Asaka-shi, Saitama, Shindengen Electric Manufacturing Co., Ltd.Representative Director and President, Nobuyoshi Tanaka (Executive Officer, In charge of Legal & Compliance, Shoji Chiba)

(2)Purpose of use of the retained personal data:
Refer to Section 3 (2) above "Purpose of Use of Personal Information, etc." 

(3)Procedures for Responding to Requests, etc. for Disclosure, etc. of Retained Personal Data
In the event of a request by the Customer for notification of the purpose of use of retained personal data, disclosure, correction, deletion, suspension of use, or suspension of provision to a third party due to the fact that the contents of the retained personal data are not true or the occurrence of a leakage, etc., or a request for disclosure of the record of provision to a third party (hereinafter referred to as a "Request for Disclosure, etc."), the Company shall respond without delay in accordance with a prescribed "Procedure for Responding to a Request for Disclosure, etc." (click here). Provided, however, that in the event a large amount of expenses is required to take the method for "disclosure" of retained personal data requested from the data subject, or in other case where it is difficult to "disclose" such data by such a method, the Company will respond in writing. In addition, in the event the Company decides not to disclose all or part of the retained personal data pertaining to a request for any of the reasons listed in (i) to (v) below, or in the event such retained personal data does not exist, or in the event it is difficult to disclose such retained personal data by the method requested by the data subject, the Company shall notify the data subject thereof without delay.
  (i)Cases where to clarify the existence or non-existence of such personal data may encourage or induce illegal or unreasonable acts
  (ii) Cases in which prevention, suppression, search, etc. of criminals or other matters concerning maintenance of public safety is hindered by clarifying the existence or absence of such personal data
  (iii) Cases where there is a risk of harm to the life, body, property, or other rights and interests of the person in question or a third party
  (iv) Cases in which the proper execution of our business is likely to be seriously hindered.
  (v) Cases in which disclosure violates other laws and regulations

(4) Measures taken to safeguard retained personal data:  Refer to Paragraph 2 (3) "Safety Management Measures"

(5)Request for Complaints Concerning the Handling of Retained Personal Data

See Section 5 below.

We will strive to respond appropriately and promptly to any inquiries from data subjects regarding the handling of personal information. For inquiries, please use the specified form.

Established: July 17, 2019
Revised: April 1, 2024