Recognizing the importance of protecting personal information, the Nitta Group (“the Group”) handles personal information in an appropriate manner in accordance with the Nitta Group Code of Conduct and the policies described below.
1. Acquisition of personal information
The Group acquires personal information in an appropriate manner, without the use of misleading or otherwise illegitimate methods.
2. Use of personal information
The Group uses personal information only to the extent necessary to accomplish its business objectives and within the scope of the purpose of use as described in “Sources and purposes of use of personal information.”
3. Provision of personal information to third parties
With the exception of the following circumstances, the Group does not provide customers’ personal information to third parties:
- (1) When the customer has consented to such provision
- (2) When using personal information jointly within the Group or with Group companies’ distributors, agents, and other specified entities in accordance with the provisions of section 4 below
- (3) When outsourcing the handling of personal information, either in whole or in part, to a third party in accordance with the provisions of section 5 below
- (4) When personal information is provided in conjunction with the transfer of a business, for example as part of a merger
- (5) When such provision is permitted by law or compelled by law or court order
4. Joint use of personal information
Companies affiliated with the Group (see note below) make joint use of personal information acquired from customers within the Group and together with distributors, agents, and other specified entities of companies that have acquired the information.
- (1) The types of personal information that are subject to joint use
- (a) Customer names, addresses, postal codes, phone numbers, fax numbers, email addresses, company and group affiliations, organizational and departmental affiliations, job titles, industries, business categories, and other information
- (b) Information about past discussions concerning, and purchases of, the Group’s products, maintenance, and services
- (c) Information about past participation in trade shows, seminars, and other events
- (d) Information about whether customers prefer to receive direct mail and other communications from the Group
- (2) Scope of participation in joint use
Group companies as well as distributors, agents, and other specified entities of the companies that acquired the types of personal information listed above
- (3) Purpose of use
Same as the purpose of the use of personal information as defined in section 2 above
- (4) Locus of responsibility for managing personal information
Group company that acquired the personal information in question from the customer
5. Outsourcing of handling of personal information
The Group may outsource handling of personal information within the scope necessary to accomplish the purposes of use set forth in section 2, either in whole or in part, to outside contractors. When doing so, it will enter into non-disclosure agreements with the contractors in question and otherwise manage and supervise operations as appropriate to ensure the safety and integrity of the shared personal information.
6. Measures to ensure the safety of personal information
The Group manages personal information safely in order to ensure its accuracy, including by implementing appropriate information security measures to address risks such as illegitimate access and computer viruses in order to prevent the loss, corruption, alteration, or unintentional disclosure of personal information.
7. Disclosure and revision of personal information
When the Group receives a request from a customer to disclose, revise, augment, delete, halt the use of, or erase personal information in its possession, it will respond as follows after verifying the identity of the customer in question:
- (1) Disclosure of personal information
The Group will disclose the personal information it has for the customer in question in a reasonable period of time and to a reasonable extent.
- (2) Revision, addition, and deletion of personal information
If the personal information in its possession is inaccurate, the Group will revise, augment, or delete the customer’s personal information in a reasonable period of time and to a reasonable extent.
- (3) Cessation of use and erasure of personal information
The Group will halt use of or erase the customer’s personal information in a reasonable period of time and to a reasonable extent.
8. Legal compliance and reassessment of structures
The Group complies with laws, national policies, and other best practices with regard to protecting personal information. Additionally, the Group formulates rules on the protection of personal information and ensures that employees are aware of all rules and policies. Finally, the Group works to review and improve mechanisms for managing personal information.
Note: Nitta Group companies included in the scope of joint use include the following companies in Japan: Gates Unitta Asia Company; Nitta Haas Incorporated; Nitta Ranch Corporation; Ashihara Driving School; Hokkaido Nitta Co., Ltd; Nitta Asocio Company; Power Techno Co., Ltd.; Kansaikako Co., Ltd.; Morimitsu Industries Company; Kyowa Industry Company; Naniwa Rubber Co., Ltd.; and Nitta Chemical Industrial Products Co., Ltd.
Table: Sources and Purposes of Use of Personal Information
- (1) Selling products and providing maintenance and services by the company and the Group
- (2) Managing information about past sales of products and provision of maintenance and service by the company and the Group
- (3) Providing information about products, technologies, and services of the company and the Group (including information provided by postal mail, email, fax, phone, and other means)
- (4) Responding to inquiries and requests for advice from customers
- (5) Conducting research related to products, technologies, and services; studying the potential development of new products, services, and technologies; carrying out marketing activities
- (6) Providing personal information related to (1) through (5) above to the Group as well as to associated distributors, agents, and other specified entities
- Business partners involved with the purchase of materials, supplies, services, and other products
- ・Fulfilling obligations under transaction agreements (purchases of materials, supplies, and services, and other transactions)
- ・Communicating information as necessary for operational purposes
- ・Exercising legal rights and fulfilling obligations
- ・Offering shareholder benefits
- ・Carrying out a variety of measures to facilitate smooth relations between shareholders and the company
- ・Managing shareholders as required by law (compiling shareholder data, etc.)
- Job applicants
- ・Providing information about subjects such as open positions and otherwise communicating with job applicants (including interns)
- ・Managing hiring operations
- Individuals who have submitted other inquiries
- ・Responding to inquiries and otherwise communicating with individuals who have submitted inquiries
- Employees, retirees, and employees’ family members
- ・Verifying personal safety in emergencies and otherwise communicating with affected individuals