Handling of Personal Information

As an entity that handles personal information, Gordes insurance (“we”, “us” or “our”) profoundly understand the importance of personal information protection; properly handle personal information (meaning personal information prescribed in paragraph 1 of Article 2 of the Act on the Protection of Personal Information (the “Privacy Act”)), individual numbers (meaning individual numbers prescribed in paragraph 5 of Article 2 of the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the “My Number Act”)), and specific personal information (meaning specific personal information prescribed in paragraph 8 of Article 2 of the My Number Act); and continually review this Privacy Policy and the measures for information security management to enhance them as necessary in compliance with the Privacy Act, the My Number Act, the Guidelines on Personal Information Protection in the Financial Industry (the “FSA Guidelines”), and other applicable laws, regulations and guidelines. We also continually educate our officers, employees and agents to ensure the proper handling of personal information, individual numbers and specific personal information.

*In the items 1 through 11 stipulated below, “personal information” and “personal data” do not include individual numbers and specific personal information.

  1. Collection of Personal Information
    (For individual numbers and specific personal information, please see the item 6 below.)
    We collect personal information by fairly and lawfully and to the extent necessary for the business purposes. For example, we collect personal information through such as insurance application forms, statements of claim, and our online services. We may also use cookies in order to identify a visitor or user who accesses our website through the Internet.
    When handling personal information on the Internet, we use secure socket layer technology (SSL) and encrypted communication protocol to ensure the secure transmission of personal information.

  2. Purposes of Use of Personal Information
    (For individual numbers and specific personal information, please see the item 6 below.)
    We use the collected personal information only to the extent necessary for the purposes stated below. We state these purposes on our website and on the documents for important information. When we change the purposes of use, we notify the changes to the individuals who can be identified by the collected personal information, or make an announcement on our website.
    The purposes of use are:
    (1) to provide you with our products or information of our products;
    (2) to manage or to provide you with our services/information about our services relating to the purpose (1) above;
    (3) to carry out pre-underwriting evaluations, to underwrite or to manage/provide services of non-life insurance policies;
    (4) to appropriately settle insurance payments and benefit payments;
    (5) to provide you with information on the products and services of our group companies;
    (6) to provide you with various information such as events, campaigns and seminars;
    (7) to enter into reinsurance contracts, to claim reinsurance money or to issue notices required under reinsurance contracts;
    (8) to collect our receivables;
    (9) to conduct market researches, data analyses or questionnaire surveys for development or study of new products and services;
    (10) to accomplish tasks of handling personal information entrusted by third parties;
    (11) to recruit officers, employees and agents;
    (12) to respond to your inquiries or requests; and
    (13) to provide any other services to successfully complete transactions with customers.
    When handling personal information beyond the extent necessary to achieve these purposes of use, we obtain consent from the individuals who can be identified by the collected personal information except in the cases perscribed in paragraph 3 of Article 16 of the Privacy Act.

  3. Provision of Personal Data to Third Parties
    (For individual numbers and specific personal information, please see the item 6 below.)
    We will not provide your personal data (meaning personal data prescribed in paragraph 6 of Article 2 of the Privacy Act) to any third parties without your consent except in the following cases:
    (1) where your personal data is required by laws and regulations;
    (2) where your personal data is shared with vendors or insurance agents working on our behalf to the extent necessary to conduct our business;
    (3) where your personal data is shared with third-party reinsurers under reinsurance contracts;
    (4) where your personal data is shared with our group companies (for further details, please see the item 8 below);
    (5) where your personal data is shared with other non-life insurers (for further details, please see the item 9 below); or
    (6) where your personal data is shared with the Ministry of Land, Infrastructure, Transport and Tourism (MLIT) (for further details, please see the item 9 below).

  4. Handling of Credit Information
    Pursuant to Article 53-9 of the Ordinance for Enforcement of the Insurance Business Act (the “Ordinance for Enforcement of the IBA”), we will not use credit information provided by credit information reference centers* for any other purposes than investigation of your debt paying ability.
    (*Credit information reference centers are the organizations which collect and provide us with information on your debt paying ability.)

  5. Handling of Sensitive Information
    Pursuant to Article 53-10 of the Ordinance for Enforcement of the IBA and the FSA Guidelines, we will not collect, use or provide any third parties with sensitive information* (meaning sensitive information prescribed in paragraph 1 of Article 5 of the FSA Guidelines and includes “special care-required personal information”) unless which is necessary for our business operation and other legitimate purposes. In such cases, we collect, use and provide your sensitive information with your consent to the extent necessary for our insurance services.

    * Sensitive information means the following information:
    - race, creed, social status;
    - medical history, health care and sex life;
    - criminal record, fact of having suffered a crime;
    - enrollment in a labor union;
    - family origin, registered domicile; and
    - other personal information which requires special care in handling so as not to cause unfair discrimination, prejudice or other disadvantages to the principal.

  6. Handling of Individual Numbers and Specific Personal Information
    The purposes of use of individual numbers and specific personal information is limited under the My Number Act, and we will not collect or use these numbers and information beyond the extent necessary to accomplish the limited purposes. Furthermore, we will not provide individual numbers and specific personal information to any third parties except as otherwise permitted by the My Number Act.

  7. Sharing of Personal Data, Individual Numbers and Specific Personal Information with Third Parties Working on Our Behalf
    We may share your personal data, individual numbers and specific personal information with third parties working on our behalf to the extent necessary for accomplishing the purposes of use. According to the predetermined criteria for selecting such third parties, we will check their information management systems prior to entering into contracts, and will conduct necessary and adequate supervision on such third parties.
    We may share your personal data, individual numbers and specific personal information with third parties working on our behalf in some cases including:
    (1) provision of insurance products and process of claims;
    (2) clerical, printing and mailing services concerning insurance contracts;
    (3) developments and operations of information systems; or
    (4) preparation and submission of payment records.
    (Item (4) above includes individual numbers and specific personal information.

  8. Safeguarding Personal Data, Individual Numbers and Specific Personal Information
    In order to safeguard personal data, individual numbers and specific personal information; for example to prevent unauthorized disclosure, or loss or damage of personal data, individual numbers and specific personal information; we implement sufficient safeguard measures including development of manuals and implementation of a practical framework for protecting these information, and continually enhance the implemented measures.
    In cases where we share your personal data, individual numbers and specific personal information with third parties working on our behalf to the extent necessary for our business purposes, we determine the criteria for selecting such third parties, will check their information management systems prior to entering into contracts, and will conduct necessary and adequate supervision on such third parties.
    For any inquiries about our safeguards, please contact us at the item 11, “Contact Information”, below.

  9. Inquiries about Coverage and Insured Events
    For any inquiries about coverage of your insurance policies or claims, please contact our sales offices or agents listed on the insurance certificate you have, or nearby sales offices or agents. We will respond to your inquiries after confirming that the inquirer is the insured or policyholder of the inquired policy.

  10. Notification, Disclosure, Correction, and Discontinuation of Use of Items Related to Personal Data under the Privacy Act
    For the requests under the Privacy Acts such as requests for notification, disclosure, correction and discontinuation of use of your personal data, please contact us at the item 11, “Contact Information”, below. We will firstly ask you to prove your identification, then process your request with your completed request form and mail you a written response at a later date.

  11. Contact Information
    We will immediately and appropriately respond to your complaints and consultation requests concerning handling of personal information, individual numbers and specific personal information. For any inquiries or consultation requests about handling of personal information, individual numbers, specific personal information and the personal data retained by us, please write to us at:

Gordes Insurance

Kanagawaken, yokosuka-shi, Honcho, Honcho building 2F

Tel : 046-884-8538

Email : gordes@dc5.so-net.ne.jp