Privacy Policy｜Sanwa Holdings Corporation

Sanwa Group Privacy Policy

Sanwa Holdings Corporation and its domestic Group companies (the “Sanwa Group”) view the proper handling of customers’ and business partners’ personal information as an important responsibility. We will make every reasonable effort to properly handle and protect personal information we acquire on customers and business partners in accordance with this Privacy Policy.

1．Definition of Personal Information and Personal Data

(1) “Personal information” is information on a living individual that falls under any of the following categories:

(i) Information such as names, dates of birth, addresses, telephone numbers, email addresses, IDs, passwords or visual images, etc. that can be used to identify a specific person (including information that can be easily reference against other information thereby enabling the identification of a specific individual)
(ii)Information that contains an individual identification code (as defined in Article 2, Paragraph (2) of the Act on the Protection of the Personal Information (“Personal Information Protection Act”))

(2) “Personal data” refers to personal information constituting a personal information database, etc. (as defined in Article 2, Paragraph (4) of the Personal Information Protection Act)

2．Purpose of Use of Personal Information

The Sanwa Group shall use personal information obtained by the Sanwa Group within the scope necessary to achieve the following purposes of utilization, and shall not use it for any other purposes without the consent of the customer or business partner, except as required by law.
The utilization purpose shall be changed, to the extent reasonably recognized as relevant to the utilization purpose prior to the change, and we shall notify or announce the new utilization purpose to customers and business partners.
(1) Customers’ personal information

(i) To provide products and services related to various shutters, doors, partitions, front products, and stainless steel products, etc., manufactured or sold by the Sanwa Group
(ii)To conduct surveys relating to Sanwa Group products, provide information, after-sales service, conduct maintenance, respond to opinions and requests, and make improvements, etc.

(2) Business partners’ personal information

(i) To contact and make business or transaction-related inquiries, and execute and perform contracts
(ii)To manage business partners and transaction-related information, etc.

3．Shared Use of Personal Data

In order to achieve the utilization purpose described in 2.(1) and 2.(2) above, the Sanwa Group use personal data on customers and business partners jointly within the following scope:

(1)The categories of the jointly utilized personal data
Customers’ and business partners’ names, affiliation information (company name, department name, etc.), job titles, addresses, telephone numbers, fax numbers, and email addresses, etc.
(2)The scope of the jointly utilizing users
Sanwa Holdings Corporation and its domestic Group companies
(3)The utilization purpose for the utilizing users
Same as 2.(1) or 2.(2) above
(4)The name or appellation of the person responsible for controlling the jointly utilized personal data
Sanwa Holdings Corporation

Note that, in addition to the above, domestic Group companies that manufactured or sell products by the Sanwa Group, such as Sanwa Shutter Corporation also share the personal data of business partners in the MC Data Plus, Inc. Kensetsu-Site Series or other GREEN-sites that support construction management and other operations at construction sites. See “Shared Use of Personal Information in the Kensetsu-Site Series (in Japanese only)” or other websites of companies that develop and operate such GREEN-sites for the items of personal data subject to shared use, the scope of shared users and purpose of use, and the person responsible for management of shared use.

4．Disclosure of Personal Data to Third Parties

The Sanwa Group does not disclose our customers’ or business partners’ personal data to third parties, except in the following cases:

(1)When customers or business partners have consented to disclosure
(2)When entrusting the handling of our customers’ or business partners’ personal data to subcontractors (including their subcontractors) in Japan that the Sanwa Group has determined to be reliable, to the extent necessary to achieve the utilization purpose described in 2.(1) or 2.(2) above
(3)When providing to parties listed in the scope of joint utilization in 3. above
(4)When disclosure is necessary to protect human life, body or fortune and it is difficult to obtain consent from the customer or business partner
(5)When disclosure is specifically necessary to enhance public hygiene or promote fostering healthy children, and it is difficult to obtain consent from the customer or business partner
(6)When a central government organization or local government entity, or a or a person entrusted by them performing affairs prescribed by laws and regulations and there is a possibility that obtaining consent from the customer or business partner would interfere with the performance of the said affairs
(7)In addition to the cases listed in (4) to (6) above, when required by laws or regulations

5．Management of Personal Data

(1)The Sanwa Group takes appropriate and reasonable security measures to prevent outside access to customers’ and business partners’ personal data and the loss, destruction, tampering or leakage of personal data.
(2)In addition to conducting education and awareness raising activities for all officers and employees, the Sanwa Group strives to manage customers’ and business partners’ personal data appropriately by formulating Detailed Regulations for Handling Personal Information and appointing a person in charge at each company that handles personal information.
(3)The Sanwa Group executes outsourcing contracts with subcontractors that include confidentiality clauses, supervises subcontractors to ensure they handle and protect customers’ and business partners’ personal information appropriately, to prevent leaks and use outside the scope of the utilization purpose described in 2.(1) and 2.(2) above.

6．Disclosure, Correction, Deletion of Personal Data

When the Sanwa Group receives a demand for disclosure, correction, or deletion, etc. of information from a customer or business partner, after confirming that the request meets the requirements under the Personal Information Protection Act, and that the request is made by the customer or business partner itself or by its agent, we take necessary measures within a reasonable scope. Please contact the inquiry desk stated in 10. below. Note that some services may not be used once personal data has been deleted. In addition, note that a service fee will be charged for the disclosure, etc. of personal data.

7．Disclaimers

(1)Customers and business partners are responsible for managing their user IDs and passwords when using our website (“this Site”). The Sanwa Group assumes no liability whatsoever for any loss or damage resulting from the unauthorized use of an ID or password registered by a customer or business partner.
(2)The Sanwa Group may suspend use of an ID and password if we discover that a customer or business partner registered their ID or password using false information or a third party’s information.
(3)The Sanwa Group assumes no liability whatsoever for ensuring the security of personal information on other websites linked to this Site.

8．Compliance with Related Laws and Regulations and Amendments to Our Privacy Policy

The Sanwa Group complies with the Personal Information Protection Act, laws and regulations and other norms concerning the protection of personal information, and continuously reviews and strives to improve this policy. We announce changes to this policy on this Site. Please refer to the latest version of the policy posted on this Site.

9．Use of Cookies

Cookies are a standard technology used by web servers to identify a customer’s or business partner’s computer.
The Sanwa Group use cookies to enhance convenience for users of this Site and to manage this Site. However, our use of cookies does not violate customers' or business partners’ privacy or have any adverse effect on customers' or business partners’ computers. The Sanwa Group collects information on customers' or business partners’ use of our services, however, this information is not used or disclosed in any way that identifies a specific individual.
Cookies are data recorded on customers' or business partners’ computer hard disks. They can normally be disabled via browser settings. Customers or business partners who block all cookies may lose access to some of the services on this Site.

10．Inquiries

Inquires relating to personal information on customers or business partners that Sanwa Holdings Corporation acquire and this policy should be made to the following contact desk.

Department in charge:	Sanwa Holdings Corporation General Affairs Department
Address:	Nishi-Shinjuku 2-1-1, Shinjuku-ku Tokyo, Japan 163-0478
E – Mail:	0101spost@sip.sanwa-ss.co.jp
Telephone:	+81-3-3346-3019
Office hours:	9:00 am to 5:00 pm, Mon to Fri (except for holidays and year-end and New Year’s holidays)

Please check the following link if you have an inquiry relating to personal information on customers and business partners acquired by individual Sanwa Group companies (excluding Sanwa Holdings Corporation).

Sanwa Group Inquiry Contact Desks List Concerning Personal Information

Revised Octover 1, 2023