PRIVACY POLICY

sanwacompany ltd. (hereinafter “sanwacompany” or “we”) aim to provide our customers with better living space with our products. As part of the service, it is our responsibility to protect personal information that we use for the execution of our operations. We thus have established “Basic Principles” and “Handling of Personal Information” to be applied when handling personal information. We declare that we strive to observe these and protect personal information.

Basic Principles

Definition of Personal Information

“Personal information” means information about a living individual which can identify the specific individual by name, date of birth or other description contained in such information (including such information as will allow easy reference to other information and will thereby enable the identification of the specific individual).
Acquiring, Use and Disclosure of Personal Information
1. We will acquire personal information by fair and legitimate means and use properly.
2. We will clarify the purpose of use of personal information as far as possible when acquiring such information, and except when required by law, such information will only be used or provided according to the purpose approved by you.
3. When acquiring personal information from you, we will notify you of the purpose of use of such information directly or publicly announce it on our web page and other means.
Management of Personal Information
1. We will implement and maintain the appropriate measures to protect personal information from leakage, loss, damage and other risks.
2. We will not disclose your personal information to third parties without your prior consent except when required by law.
Compliance with Laws and Regulations

To protect personal information, we will comply with all legal ordinances and guidelines of government authorities concerning personal information.
Continued Improvement

We will establish and operate a Personal Information Protection Management System, and conduct regular audits of it in order to continue to improve upon it.
Dissemination of Basic Principles and Handling of Personal Information

“Basic Principles” and “Handling of Personal Information” will be available to public via our web page.
Complaints, Opinions, and Other Enquiries about Personal Information

We will establish Personal Information Enquiry Desk and make all reasonable efforts to deal with your complaint or consultation about our handling of personal information appropriately and promptly.

Handling of Personal Information

We recognize that protection of personal information is part of our social responsibility. We properly handle personal information based on followings and endeavor to protect it.
Handling during recruitment activities is based on a separate "Privacy Policy for recruitment activities”.

Acquisition of Personal Information
1. Under the following cases and when necessary for our business operations, we may acquire personal information from you. Provision of personal information is optional; however, if you choose not to provide us with certain personal information, there is the possibility that you may not be able to make use of our services:
  - When we are asked by you by internet, email, telephone and facsimile for inquiry, request, quotation, order and others;
  - When you come our showrooms;
  - When you visit various events we participate in or hold; or
  - When you answer questionnaires conducted by us.
2. Except when required by the Personal Information Protection Law, we will not obtain personal information that requires consideration without obtaining your prior consent.
Purpose of Use of Personal Information
We will use personal information obtained from you for the following purposes (hereinafter referred to as the "Purpose of Use"):
1. We will use the Personal information about you (e.g., address, name, date of birth, gender, telephone number, e-mail address, account/credit card information, financial/credit information) for the following purposes:
  - For your identification and personal identification;
  - For the purpose of issuing quotations, sending our products, settling the price, and communicating about commodity transactions;
  - For the provision and implementation of after-sales service and maintenance of our purchased products;
  - To guide our products or services by e-mail, direct mail, catalogue, etc.;
  - In order to investigate the usage and satisfaction levels of our products and services through the sending of questionnaires, etc.;
  - In order to ship winning gifts through campaigns and other means to everyone;
  - For the purpose of requesting examples of work used in advertising and publicity materials and interviews to gather the opinions of the public;
  - In order to respond to inquiries, inquiries, and requests from customers, and to confirm and record such inquiries;
  - For the purpose of exercising rights and fulfilling obligations under contracts and laws with you; or
  - In order to manage your information and to perform transactions and contracts with you appropriately and smoothly.
2. Information such as browsing history, purchase history, customer attributes (gender, date of birth, family composition, etc.) of your website will be accumulated and analyzed and used for the following purposes:
  - To guide our products or services by e-mail, direct mail, catalogue, etc.;
  - For information on our products and services via the web or on the application; or
  - For analysis of marketing data required to improve our products and services.
3. We will use the Personal information on business partners for the following purposes:
  - For the performance of business, business negotiations, and other incidental communications;
  - For the purpose of exercising rights and fulfilling obligations under contracts and laws, etc., and for communication incidental thereto, etc.;
  - For responding to various inquiries, consultations, requests, etc., and for confirming and recording them ; or
  - For the management of supplier information and the proper and smooth performance of other transactions and contracts.
4. Personal information about shareholders:
  - For the purpose of securing the exercise of rights and fulfillment of obligations under the Companies Act and other laws and regulations, and for correspondence incidental thereto ; or
  - For the management of shareholders, such as the preparation of records in accordance with various laws and regulations.
5. Personal information about employees:
  - For business communication and equipment and facility management;
  - For operations related to personnel and labor management;
  - For the payment of wages, bonuses, and other allowances;
  - For the provision of welfare;
  - For work related to safety, health, and health management; or
  - For employment insurance and social insurance services.
6. In the event of any of the following, the acquired personal information may be used for purposes other than the Purpose of Use.:
  - With your consent;
  - In accordance with laws and regulations;
  - When it is necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of the person;
  - When it is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children and it is difficult to obtain the consent of the person in question;
  - Cases in which it is necessary to cooperate with a state organ, a local government, or a person entrusted thereby in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person in question is likely to hinder the execution of the affairs in question; or
  - Cases where personal data is provided to universities, other institutions or organizations aimed at academic research, or persons belonging thereto (hereinafter referred to as "academic research institutions, etc."), and where said academic research institutions, etc. need to handle said personal data for academic research purposes (including cases where part of the purpose of handling said personal data is for academic research purposes, and excluding cases where the rights and interests of individuals are likely to be unjustly infringed).
Shared use of personal information
We will share personal data as follows.
- Items of personal data
  - Your address, name, zip code, phone number, fax number, e-mail address, etc.; or
  - Personal data obtained, used, and stored for the purpose of use as described in "2" above, including personal data related to the work requested by you.
- Scope of joint users
  Our group companies
- Purpose of Use
  Within the scope of the purpose of use mentioned in "2" above
- Name, address, and representative of the company responsible for the management of personal data
  19-19, Chaya-cho, Kita-ku, Osaka City
  sanwacompany ltd.
  Taro Yamane, President, Representative Director
Matters relating to personal information safety management measures
We will take necessary and appropriate safety management measures to control personal data handled by us, such as preventing leakage, loss, or damage. We will also conduct necessary and appropriate supervision of employees handling personal data and contractors.
The Personal Information Handling Regulations and other internal regulations stipulate specific measures to ensure the safe management of personal data.
The details are mainly as follows.
1. Establishment of personal information protection policy
  In order to ensure the proper handling of personal data, we have established these Guidelines (Personal Information Protection Guidelines) for “Compliance with Related Laws and Regulations, Guidelines” and “Contacts for Questions and Complaint Handling”.
2. Development of Disciplines Regarding the Handling of Personal Data
  We have established “Personal Information Protection Rules” for the handling of personal data by establishing the handling methods, persons in charge, persons in charge, and their duties at each stage of acquisition, use, storage, provision, deletion, and disposal.
3. Systematic security control measures
  - We have established an organizational system to take safety management measures, such as establishing a person in charge of administrative work related to the handling of personal data. At the same time, we have established a system to clarify the employees handling personal data, their roles, and the scope of personal data handled by such employees, and to report to the person in charge of administrative work in the event that any fact or sign of violation of the Personal Information Protection Law or the Personal Information Handling Regulations is identified.
  - We conduct periodic self-inspections of the status of the handling of personal data and conduct audits by persons outside the department.
4. Human security control measures
  - We regularly train employees on matters of concern regarding the handling of personal data.
  - We describe the matters concerning the confidentiality of personal data in the Work Rules.
5. Physical security control measures
  - In areas where personal data is handled, we control the entry and exit of employees and restrict devices, etc. brought in, and take measures to prevent unauthorized persons from viewing personal data.
  - In addition to taking measures to prevent theft or loss of equipment, electronic media, and documents that handle personal data, measures are taken to prevent personal data from being easily identified when transporting such equipment, electronic media, etc., including transportation within business sites.
6. Technical security control measure
  - Access control is implemented to limit the scope of personnel in charge and personal information databases handled.
  - We have introduced a mechanism to protect information systems that handle personal data from unauthorized access from outside sources or from unauthorized software.
7. Grasping the external environment
  We implement safety management measures after understanding the system for protecting personal information in countries where personal data is handled.
Disclosure, Correction, Addition, Deletion, Cessation of Use, Removal or Cessation of Provision of Personal Information to Third Parties
1. When you would like to disclose, correct, add to, delete, have us cease the use of, remove or have us cease the provision of personal information (hereinafter “disclosure or the like”), directly contact “sanwacompany Personal Information Enquiry Desk” pursuant to the provisions of Section 7 below. We will only notify you of the details of implementation when requested to do so by the method described in 7. below and only when you are able to confirm that the request is made by the identity of the requester.
2. Notwithstanding the preceding paragraph, we may decide not to disclose all or part of your personal information in any of the following cases, and in that case we will notify you of a reason:
  - When the identity of the applicant cannot be verified (When the authority of representation of a representative cannot be verified);
  - When application forms are incomplete;
  - When we don’t have the information requested to be disclosed;
  - When the disclosure may be detrimental to the life, body, property or any other rights or interests of the applicant or third parties;
  - When the disclosure or the like may cause substantial hindrance to proper conduct of business of us; or
  - When the disclosure or the like constitute violation of other laws or regulations.
  - When required by other laws and regulations.
3. Notwithstanding the provision of Section 5. (1), this provision does not apply in any case in which it is difficult to cease the use of or to remove your personal information and in which we take necessary alternative measures to protect your rights and interests.
Use of cookies (cookie)
1. Cookies are a mechanism that allows users to temporarily write data to their terminals (PCs, smartphones, etc.) through Internet browsing software (browsers) when using websites. Cookies can contain information that identifies you, viewing and inputting information, and can be used more conveniently by everyone. Depending on your browser, you can refuse to receive cookies or configure other settings. For details, contact your browser supplier.
  Note that if you select the setting to reject all cookies, it may be subject to restrictions on the use of websites.
2. Purpose of using cookies
  We sometimes use cookies in the following cases:
  - To provide customized services for each customer;
  - To analyze what you are interested in and display the most appropriate ads on other companies' sites through advertising distributors based on the usage conditions on our website;
  - To investigate the number of users and traffic on our web site;
  - To improve our services; or
  - To encourage people who have passed a certain period of time since their use to re-enter (re-authenticate) their passwords in order to maintain security.
Procedures for Request for Disclosure or the Like
1. Contact Information
  
  <In the case of a disclosure request>
  Please mail the necessary documents to the address in 9 below. (Written Application Only)
  <Request for correction, suspension of use, deletion, etc.>
  Please send the necessary documents by mail or e-mail to the address in 9 below.
2. Necessary Documents
  
  Request form (either of them)
  
  Request for Disclosure of Personal Information (Japanese Only)
  
  Request for Correction, Addition, Deletion, Cessation of Use, Removal or Cessation of Provision of Personal Information to Third Parties (Japanese Only)
  
  ※ When you need documents, please contact Personal Information Enquiry Desk.
  
  Identity verification documents
  
  <In the case of the applicant> (copy of any two of them)
  Driver’s license, passport, health insurance identification card, basic resident register card, pension booklet, physically disabled certificate, alien registration card, and individual number card (only surface)
  <In the case of a representative> ( i), ii) and iii) all necessary)
  
  A power of attorney (Japanese Only) (When you need this document, please contact Personal Information Enquiry Desk) and a certificate of a seal impression of the applicant (in the case of a statutory representative, a document certifying his/her authority of statutory representation)
  
  Applicant’s Driver’s license, passport, health insurance identification card, basic resident register card, pension booklet, physically disabled certificate, alien registration card, and individual number card (only surface) (copy of any one of them)
  
  Representative’s Driver’s license, passport, health insurance identification card, basic resident register card, pension booklet, physically disabled certificate, alien registration card, and individual number card (only surface) (copy of any two of them)
  
  Note: Please be certain that any legal domicile or individual number contained in the document to be submitted is blacked out or otherwise rendered illegible before submission.
3. Fee and Payment Method
  
  <In the case of a disclosure request>
  A disclosure fee of 1,000 yen is required for each application. Please enclose a postage stamp worth 1,000 yen when mailing necessary documents such as an application form for personal information disclosure, etc.
  <Request for correction, suspension of use, deletion, etc.>
  No fees are required.
Changes to Basic Principles and Handling of Personal Information

Due to the enactment, revision, etc., of laws and regulations, etc., we may revise this policy and the contents of this handling from time to time without prior notice. This policy and changes in this handling will become effective when the revised policy and this handling become available for publication or inspection.
Personal Information Enquiry Desk

sanwacompany Personal Information Enquiry Desk
19-19-21F Chayamachi, Kita-ku, Osaka, Japan 530-0013
Email：sanwahoumu@sanwacompany.co.jp

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