Card Services Japan KK (“Card Services Japan”) is committed to protecting the privacy of all of the customers it serves. The following details the Privacy Commitment.
At Card Services Japan, we recognize that our customers are concerned about the confidentiality and privacy of their information. Your privacy is important to us and we take this matter very seriously. We would like you to understand why we ask for your personal information, how we keep your personal information confidential, and how you can inquire about the personal information we hold about you. We urge you to read our Privacy Commitment carefully.
2. WHY WE ASK YOU FOR YOUR PERSONAL INFORMATION
We ask you for your personal information for the following purposes:
- Card Services Japan and its group entities (Access Prepaid Worldwide Ltd and its subsidiaries and affiliates, collectively “Access Group”) performing or soliciting transactions and related services concerning financial instruments related to Payment Services Act of Japan
- to comply with the applicable law and regulations, such as Proceeds of Crime Act, Foreign Exchange Law, etc. in connection with a transaction;
- to review client’ suitability when we offer our financial products;
- to carry out any outsourcing services properly, if we are requested by a third party to handle part or all of such third party’s personal information;
- to facilitate the products and services for customers from Access Group as well as China UnionPay and Travelex Japan KK (and it's priori fixed related entities in their privacy commitment when it is necessary for providing appropriate services to customers;
- to provide you with information and offers on our products and services, that we believe may be of interest to you;
- to provide researching or developing financial products and services provided by or to be provided by Access Group by using market research, data analysis or customer surveys;
- to inform or advice customers performance results and account balances concerning financial products or services offered to customers;
- for any other purposes in connection with the above purposes to enable the Access Group to adequately and smoothly provide our services for customers.
INFORMATION WE COLLECT AND HOW WE USE IT
If you choose to order products or services from us, via telephone, mail, or from one of our Web sites you will have to provide us with certain information, including personal information. This information may include your name, address, phone number, date of birth, mailing or e-mail address, and other information for payment purposes or to comply with legal requirements.
At Card Services Japan, information regarding our customers is used solely in the conduct of our business and to enable us to deliver excellent service to our customers. We limit the information we collect to only that which is required to execute a transaction, and to meet the purposes set out in this Privacy Commitment. If we wish to use your personal information for any other reason we will first obtain your consent.
4. WITHDRAWING YOUR CONSENT OR REQUEST FOR SUSPENSION OF YOUR INFORMATION
You may withdraw your consent to our use of your personal information, as long as:
- you give us a written notice;
- we reasonably believe there are no legal requirements for the use or retention of your personal information;
- withdrawing your consent does not result in our inability to fulfill your financial services contract with us; or,
- suspending information does not place such identical person or any other third party’ life, body, rights and interests in threats.
However, in order to provide our services to you, there is certain information we will require and if you choose to withdraw your consent to the use of that information the service may not be available.
5. DISCLOSURE OF AND CONTROL OVER PERSONAL INFORMATION
Your personal information is shared, to the extent permitted by law, within the Card Services Japan group of companies (that is, Access Prepaid Worldwide Ltd and its subsidiaries and affiliates) and relevant card issuing entities, such as China UnionPay and Travelex Japan KK. No personal information will be disclosed to anyone outside the Access Prepaid Worldwide Ltd group of companies, China UnionPay and Travelex Japan KK (and its priori fixed related entities) except:
- when you give us permission to do so;
- as permitted by law;
- when in good faith we believe the law requires it;
- under limited circumstances specifically described in this Privacy Commitment; or
- to Card Services Japan agents who carry out financial services functions on our behalf, such as data processing, and we will require such agents to conform to this Privacy Commitment.
For details in relation to Travelex Japan KK and its priori fixed related entities, please see its link: “http://www.travelex.jp/privacy/index.htm”
6. PROTECTION OF PERSONAL INFORMATION
We share our customer information internally in accordance with strict internal security controls to protect against unauthorized use, alteration, duplication, destruction, disclosure, loss or theft of, or unauthorized access to your personal information, in accordance with applicable privacy laws. Security is continually reviewed and enhanced as new technologies present themselves. We maintain physical, organizational and electronic security measures to protect your personal information. These include the use of secure locks on doors, restricted access to our information processing and storage areas, limited access to relevant information by authorized employees and independent contractors only ("Employees"), and through the use of passwords and pass keys.
We instruct our Employees with access to your information that it is to be used only in adherence with the principles set forth in this Privacy Commitment and the laws applicable to each specific business. As a condition of employment, our Employees are required to sign a confidentiality agreement binding them to this responsibility, which remains with them even if they leave or retire from Card Services Japan. We hold all Employees fully accountable for adhering to this Privacy Commitment and the law.
7. ACCESSING YOUR PERSONAL INFORMATION
If you want to review or verify your personal information, as permitted by this Privacy Commitment, or if you are unsure whether we have a record containing your personal information and would like to confirm whether or not we do, you can contact us, as per the contact information in Section 13 below, and we will respond to your request in a reasonable time flame. At that time, we will need specific information from you to enable us to search for, and provide you with, the personal information we hold about you.
There may be instances where we will not be able to provide the personal information we hold about you that you request. Some of these instances include, if:
- it contains references to other persons;
- it's subject to solicitor-client or litigation privilege;
- it contains our own proprietary information that is confidential to us;
- it has already been destroyed due to legal requirements or because we no longer needed it for the purposes set out in this Privacy Commitment; or,
- it cannot be disclosed for legal reasons or if there is any life, body, rights and interests threatening arising over identical person or any third party by such disclosure.
If we are unable to provide you with access to your personal information, we will always explain the reason why if possible.
8. KEEPING YOUR PERSONAL INFORMATION ACCURATE
We are committed to maintaining the accuracy of your personal information for as long as it is being used for the purposes set out in this Privacy Commitment, and you play an active role in keeping us up-to-date. Prompt notification of any changes, for example to your address or telephone number, will help us provide you with the best possible service. Should you discover, upon review of your personal information, that amendments are required, please advise us. We will use our best efforts to advise others of any important amendments to your personal information which we may have released to them.
We only keep your personal information for as long as we need it to meet the purposes set out in this Privacy Commitment. The length of time we retain your personal information is also affected by: (1) the type of product or service you have with us; and (2) any legal requirements we may have to meet.
10. UNSOLICITED DIRECT MARKETING
Your personal information will not be provided to anyone outside the Card Services Japan group of companies for direct marketing purposes unless you have expressly consented to such activities. If you do not wish to receive marketing materials from us you may opt out of such activities by contacting us at the e-mail address or phone numbers provided below. Customers acknowledge that they may be contacted by mail, telephone or e-mail for customer service and/or billing purposes. Under no circumstances do we sell lists of our customers to others for their use.
11. RESTRICTION OF DISCLOSURE TO ANY THIRD PARTY
We are prohibited to disclose customers’ personal information unless otherwise shown below:
- When a customer provides us an agreement for disclosure;
- Within the scope of purpose stated above, when a part or all of your personal information is handled by a contractor (s) to provide our services for customers. In this case, we will have supervision over our contractors to the extent necessary to meet local regulatory requirements;
- When an immediate protection over a person’s live, body, rights or interests is required, and it is difficult to obtain a customer’s consent;
- When it is specifically necessary for the purpose of improving public health and it is difficult to obtain a customer’s consent; and,
- When legal requirements under the name of the government, local government or its entrusted party statutory require disclosing, and it would harm legal interest if a customer’s consent is obtained.
13. WEBSITE PRIVACY COMMITMENT
This Privacy Commitment governs any dealings you enter into with us on the Internet. We consider any information we collect through the Internet to be personal information, and therefore only use such information in accordance with this Privacy Commitment.
14. CHANGE OF PRIVACY COMMITMENT AND FEEDBACK
We continually monitor and strengthen our Privacy Commitment. If we decide to change our Privacy Commitment we will reprint this Privacy Commitment for distribution and will post those changes on our Websites.
15. PLEASE CONTACT US
If, at any time, you have questions, concerns or comments about our Privacy Commitment, please feel free to contact our privacy manager at [ Personal Information Responsible Person, Cerulean Tower 16F, 26-1, Sakuragaoka-cho, Shibuya, Tokyo 150-8512, Japan ] or call 00531 780 221 .