Privacy Policy

Tanaka Kikinzoku Group's Matters Relating to Personal Information / Privacy Policy

Basic Policies Relating to the Protection of Personal Information (Approach on the Handling of Personal Information)

Basic Policies Relating to the Protection of Personal Information
(Basic Principles)

　The Tanaka Kikinzoku Group (TKG), in accordance with the "Action Charter" and "Action Rules" of the Group, complies with the Personal Information Protection Law of Japan and such other laws, regulations and rules for the protection of personal information, and has established rules and a system for responding to recent movements internationally relating to the protection of personal information. The member companies of the TKG have made their employees aware of the importance of protecting personal information and have set out the following policies with respect thereto, pledging to implement and uphold these policies.

(Policies on Protecting Personal Information)
  1. The TKG shall clarify in advance the reason for using, and the possibility of providing personal information obtained by TKG member companies to subcontractors or other third parties and will establish a management system for the purpose of preventing the use of personal information, other than in cases in which the consent has been obtained from the person involved or as permitted under applicable laws and regulations, that exceeds the scope of use.
  2. In the event the TKG outsources all or a portion of the handling of personal information acquired through the measures of the foregoing item 1, it shall select an entity that meets sufficient standards for protecting personal information and shall include appropriate measures in the relevant contracts, etc.
  3. The TKG shall establish safe management measures, such as procedures for appropriately managing personal information acquired and for preventing leaks and losses of the same.
  4. The TKG shall institute a system and procedures for handling complaints and questions relating to personal information held, and shall promptly respond to the same.
  5. The TKG shall establish, implement, maintain and continuously improve a personal information protection management system with respect to th epersonal information concerning the customers, employees and others with whom it does business in order to comply with the laws and regulations relating to the protection of personal information, as well as with the policies and other rules stipulated by the Japanese government.

Established April 1, 2010
Tanaka Holdings Co., Ltd.
Chief Executive Officer　Hideya Okamoto

[The Tanaka Kikinzoku Group]

The holding company for the Group is Tanaka Holdings Co., Ltd.(THD), and the business entities are comprised of the following eight core companies; Tanaka Kikinzoku Kogyo K.K.(TKK), Tanaka Kikinzoku Hanbai K.K.(TKH), Tanaka Kikinzoku Jewelry K.K.(TKJ), Tanaka Kikinzoku International K.K.(TKI), Tanaka Denshi Kogyo K.K.(TD"), Electroplating Engineers of Japan, Limited (EEJA), Tanaka Kinzoku Business Service K.K.(TKBS). The Tanaka Kikinzoku Group refers to the holding company, the above-described eight core companies and the various subsidiaries and controlled companies of each.

Scope of Application

The information contained in "Matters Relating to Personal Information" will apply in each case in which a customer utilizes or purchases any of the services or products of a company that is a member of the Tanaka Kikinzoku Group of companies; provided, however, that a specific Tanaka Kikinzoku Group company may publish its own policies regarding the handling of personal information, in which case such policies will apply with respect to the customers of that specific company.

Regarding Personal Information Held by a Member Company of the Tanaka Kikinzoku Group (TKG)

Member companies of the TKG are in possession of a great variety of personal information relating to its customers, employees and the like. In order to best comply with the provisions of the Personal Information Protection Law of Japan and the related regulations, Tanaka Holdings Co., Ltd. operates a protection system for the personal information that is under the control of the TKG.

1. Name of Representative Company of the TKG:
Tanaka Holdings Co., Ltd.
2. Person in Charge of Handling Personal Information:
  1. (a) Department/Position: Business Promotion Department, CSR Promotion Section/Department Head
  2. (b) Contact Information: Personal Information Enquiries Desk
    Tel No.: (in Japan) 03-6311-5570, Hours: 9:00-17:00, weekdays
3. Ways in Which Holding Personal Information May Be Used:
The reasons for holding personal information are set out in detail in the following section, item 1.
4. Contact Information for Complaints Regarding the Handling of Personal Information:
For complaints relating to the handling of personal information, please contact the Personal Information Enquiries Desk.

Matters Publicly Made Available Pursuant to the Personal Information Protection Law of Japan

Regarding the Ways in Which Holding Personal Information May Be Used

1) The ways in which the personal information held by the TKG companies may be used are set out in the table below, categorized in accordance with the type of personal information.

Type of Personal Information Obtained Reasons for Using Personal Information
Personal Information for Customers of Bullion for Investment, Jewelry, Etc.
  • To contact customers, to contact or provide notifications for efficient transactions
  • To conduct follow-up on services provided
  • To settle transaction payments
  • To perform the services requested
  • To introduce products and services, and to send questionnaires
  • To send customers novelty items and promotional products, etc.
  • To prepare statistical and other materials in such a way that specific individuals cannot be identified
Personal Information Obtained in Sales Campaigns and Other Events
  • To introduce products and services, and to send questionnaires
  • To send novelty or promotional items
  • To send customers novelty items and promotional products, etc.
  • To prepare statistical and other materials in such a way that specific individuals cannot be identified
Personal Information Obtained Through Questionnaires and Surveys, Etc.
  • To develop products and goods, to improve services and to undertake sales and marketing work in connection with TKG business activities
Personal Information Relating to Transaction Partners For Industrial Products
  • To conduct efficiently such activities with our transaction partners as communications, confirmations, negotiations, settlement of accounts, contract performance and the like
Personal Information Obtained Through Enquiries, and Requests for Information and Disclosure
  • To respond to enquiries
  • To perform the requested work
  • To undertake sales and marketing work
  • To prepare statistical and other materials in such a way that specific individuals cannot be identified
Personal Information Handled as a Result of Work Commissioned
  • To perform the commissioned work
Personal Information Relating to Persons Desiring to Be Employed
  • To communicate and provide information in connection with employment applications and hiring
  • To conduct hiring screening
Personal Information Relating to Persons Visiting a TKG company
  • To confirm the identity of persons visiting a TKG company
  • To prevent crime
Camera Recordings
  • To prevent crime
  • To prevent personal injury and property damage, and such other related purposes
Contents of Telephone or Other Oral Enquiries or Requests
  • To respond to enquiries
  • In order to perform the requested work or to understand, respond to or implement the request, all or a portion of telephone calls may be recorded

2) There may be cases in which personal information is used in a manner that exceeds the scope of purposes as set out above, such as when such use is required by applicable laws or regulations, in the event such use is necessary in emergency circumstances to protect life or property or when such use may be permitted under the Personal Information Protection Law of Japan.

2．Regarding the Handling of Personal Information

Personal Information shall be acquired through appropriate and fair means.

3．Providing Personal Information to Third Parties

TKG shall not provide personal information to a third party other than in cases in which any of the following becomes applicable. Please note that shared use of personal information and provision of personal information to transaction partners that are performing work on commission are not considered normal provisions of personal data to third parties. (For further information on these two categories, please see below.)

  1. 1) When the person involved gives consent;
  2. 2) When providing such information is done in accordance with applicable laws and regulations;
  3. 3) When it is difficult to obtain the consent of the person involved, but providing such information is necessary in emergency circumstances to protect life or property;
  4. 4) When it is difficult to obtain the consent of the person involved, but providing such information is particularly necessary in order to improve public health and sanitation, or to promote the healthy development of children;
  5. 5) When it becomes necessary to cooperate in connection with the performance of certain work undertaken by governmental agencies or public bodies, which work is mandated by applicable laws and regulations, but there is a fear that obtaining the consent of the person involved would interfere with the performance of such work;
  6. 6) When each of the following has been notified to the person involved: (a) the purpose of providing such personal information to such third party, (b) the items of personal data that are to be provided to such third party, (c) the means and methods by which such personal data is to be provided to such third party and (d) that the person involved may, by request, stop the provision to such third party of such personal data which identifies such person; provided, however, that such person involved is in a position to easily understand such circumstances and my, in fact, stop such provision of personal data by making a request to do so; and
  7. 7) When statistical data and the like is provided in such a way that specific individuals cannot be identified.
4．Shared Use of Personal Information

TKG may conduct shared use of personal information acquired by TKG member companies as set out below.

  Personal Information for Customers of Bullion for Investment, Jewelry, Etc. Personal Information Relating to Transaction Partners For Industrial Products Personal Information Relating to Persons Desiring to Be Employed
Sharing Entities: Tanaka Kikinzoku Kogyo K.K.
Tanaka Kikinzoku Jewelry K.K.
Tanaka Holdings Co., Ltd.		 All companies of the TKG All companies of the TKG
Use:
  • To conduct efficiently such activities with customers as communications, confirmations and notifications
  • To conduct follow-up work regarding services used by the customers
  • To provide information on TKK and TKJ products and services
  • To conduct efficiently such activities with transaction partners as communications, confirmations, negotiations, settlement of accounts, contract performance and the like
  • To communicate and provide information in connection with employment applications and hiring
  • To conduct hiring screening
Types of Personal Information Used: Membership number, customer's name, address, telephone number, date of expiration of membership, history of purchases and sales, etc. Company name, name of department, name, address, telephone number, transactional history of the person involved, etc. Name, address, telephone number and educational history of the person desiring to be employed and the circumstances relating to such other application items as may be the subject of hiring screening
Entity Responsible for Custody of Personal Information: Tanaka Kikinzoku Kogyo K.K. Tanaka Kikinzoku Kogyo K.K. Tanaka Holdings Co., Ltd.
Contact Information for Responsible Entity: Fixed-sum Purchases Administration Center
Tel No: (in Japan) 03-6311-5553
Weekdays, 9:00-17:00 		Marketing Department
Tel No: (in Japan) 03-6311-5596
Weekdays, 9:00-17:00 		Human Resources Development Office
Tel No: (in Japan) 03-6311-5544
Weekdays, 9:00-17:00
5．Regarding the Outsourcing for Handling Personal Information
  1. 1) All or a portion of the handling of personal information held by one of the member companies of the TKG may be outsourced to another company. In such case, the company performing such work will do so on the basis of an agreement executing by such member company and such other company that incorporates the provisions of the Personal Information Protection Law of Japan.
  2. 2) In performing work commissioned by another company, personal information may be used to the extent necessary in performing under the contract with such other company.

Regarding the Procedures for Responding to "Requests for Disclosure, Etc."

Member companies of the TKG shall promptly respond to the persons involved who make a "request for disclosures, etc." relating to personal data held by such member companies in connection with the following items, in accordance with the provisions of the Personal Information Protection Law of Japan:

  1. 1) Disclosure of personal data held;
  2. 2) Notification of the purpose of using the personal data held;
  3. 3) Amendments and additions to, and deletions of, personal data held; and
  4. 4) Termination of the use of personal data held, or the deletion of the same, or the termination of the provision of the same to third parties.

In the event any of the above are desired, please contact the appropriate person in charge of the relevant personal information for an explanation of the procedures and methods, etc., for requesting the same.

Please note, however, that no response may be made with respect to any of the following:

  1. 1) When the personal data that is the subject of the request for disclosure, etc., is outside of the scope of the personal data held by the relevant company;
  2. 2) When it cannot be confirmed that the individual making the request is the appropriate person to make such request;
  3. 3) When there is a fear that such a request could cause personal injury or property damage with respect to, or could adversely affect the rights or interests of, the person making such a request or a third party;
  4. 4) When there is a fear that such request could significantly obstruct the legitimate work of the TKG member companies; or
  5. 5) Such request would be in violation of applicable laws or regulations.

Contact Information for Complaints or Questions Regarding Personal Information

Please contact the following:

Tanaka Holdings Co., Ltd.
(Personal Information Contact Desk)
Tel No: (in Japan) 03-6311-5570 (Weekdays: 9:00-17:00)

Application of, and Modifications to "Matters Relating to Personal Information"

This TKG website on "Matters Relating to Personal Information" is intended to provide an explanation regarding the various types of handling, etc., of personal information by the TKG, and the customers using the products and services of TKG member companies are deemed to have fully understood and consented to the contents contained herein.

The contents of this TKG website on "Matters Relating to Personal Information" may be modified from time to time.