(This is a translation from the Japanese texts. It should be treated as a reference only. The Japanese original supersedes this English translation.)
1.Compliance to Act on the Protection of Personal Information and other related acts
We comply with Act on the Protection of Personal Information, Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures and other laws, regulations and guidelines related to the protection of the personal information.
2.Purposes of use of the personal information
In compliance with laws and regulations for the protection of the personal information, we use your personal information in our services described (1) below, and for the purposes described (2) below, to the extent necessary to achieve the purposes. We clarify and define the purposes of use in details for our customers. We make efforts to restrict the purposes of use of your personal information, wherever possible, according to the circumstances: e.g., we will use your survey answer only for tallying.
- (1)Our services
- Overseas remittance service and other services related thereto
- (2)Purposes of use
- To enroll and register customers for our membership and provide international remittance service;
- To verify the identity of our customers and their qualification for our services pursuant to Act on the Transfer of Criminal Proceeds, Foreign Exchange Act, Act on Submission of Statement of Overseas Wire Transfers for the Purpose of Securing Proper Domestic Taxation, and other relevant laws and regulations;
- To properly execute remittance requests by providing the personal information, to the extent necessary to perform the transactions, to third parties, including financial institutions and other financial service providers, both domestic and abroad;
- To properly execute transactions requested by other financial institutions or financial service providers, where they entrust us to perform certain transactions, in whole or in part, involving the personal information;
- To exercise our rights or fulfill our obligations arising from the contracts with customers and/or pursuant to relevant laws and regulations;
- To announce the winners of prizes and to send the prizes to them;
- To analyze existing service or to develop new service by market research, data analysis and customer survey;
- To conduct direct marketing and/or make various proposals on our services;
- To offer and propose products and services of our partners;
- To close our customer accounts and to manage them after the closure; and
- To perform any and all other transactions with our customers appropriately and smoothly.
We will not use certain personal information for the purpose other than stipulated by law or regulations, where such use of specific information is restricted by laws and regulations:
In compliance with Article 26 of Cabinet Office Order on Funds Transfer Service Providers, we take measures to ensure that we will not use sensitive information except for the purposes to ensure the proper business operation and for the purposes deemed only necessary. Such sensitive information includes the personal information regarding racial, ethnic or family origins, faith, registered domicile, medical or criminal records and other special non-publicized information concerning individuals we may acquire in the course of our business.
We will not collect Specific Personal Information or use it for the purposes other than defined by Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.
3.Proper collection of personal information and Specific Personal Information
We will collect your personal information and Specific Personal Information appropriately and lawfully to the extent only to achieve the purposes of use described in 2 above through the sources exemplified below:
- Customers to provide their personal information and Specific Personal Information via application forms in writing and/or input and upload to our website screens or mobile Application their personal data, selfie and/or photos of identification cards, among other things; and
- Customers to make inquiries and consultation by phone and other electronic means. Note that we may record the telephone conversation in order to improve our service quality and to validate the contents.
4.Non-Disclosure of personal information to third parties
We will properly manage the personal information of our customers and will not disclose it to third parties except in the cases mentioned below. We will not disclose Sensitive Information to third parties except in the cases permitted by the relevant laws, regulations or guidelines. Nor will we disclose Specific Personal Information to third parties except in the cases clearly set forth in Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.
- where customers consent to the disclosure;
- where we need to disclose the personal information to our entrusted contractors to perform the services requested by our customers; or
- where we are required to disclose it pursuant to relevant laws and regulations;
We may, from time to time, outsource the handling of a whole or part of the personal information to our entrusted contractors in performing the overseas remittance service and maintaining IT systems, among others. In this case, we will take necessary and proper oversight of our entrusted contractors.
5. Disclosure of personal information to third parties
We may, from time to time, provide the personal data of our customers under their consent for our partner financial institutions for the purposes described below. In this case, the personal data may be provided overseas, and our partner financial institutions may disclose it within their group companies and their entrusted contractors as well as their financial supervisors and regulators according to the purposes of use below.
Details of the personal data to be provided:
- Your profile (including, but not limited to, your address, name, date of birth, employer, contact information such as telephone numbers, and information related to your family)
- Your financial standing (including, but not limited to, your income, expenditure, assets and liabilities)
- Your transactional data (including, but not limited to, the remittance amounts, dates of transactions, beneficiaries, beneficiary countries and reasons for remittances)
- Other information necessary for our administration of your transactions (including, but not limited to, the reference numbers, remittance records and circumstances, information related to our decisions to the remittances and other transactions)
(Purposes of Use at third parties)
- To perform the overseas remittance service and to provide facility, products and services for the customers and to provide such information to their group companies, entrusted contractors or other third parties for the said purposes;
- To improve the customer service, which includes the research, analysis and analytics, marketing and product development and designing and to provide such information to their group companies, entrusted contractors or other third parties for the said purposes;
- To take measures against anti-money laundering and counter-terrorist financing and to detect, investigate, prosecute and prevent crimes, including other related criminal activities as well as to provide information for the relevant authorities of their detection, investigation, prosecution and prevention of such crimes.
(Financial institutions to receive the personal information)
- The Western Union Company, a Delaware corporation, or such other successor in interest, and its subsidiaries as shown Form 10-K of SEC Filing, The Western Union Company - Investor Relations - Financial Information - SEC Filings - SEC Filings Details when customers use Western Union service
6. Security measures to protect the personal information
We establish the policies to keep the personal information of our customers accurate and up-to-date and to define the organizational, human, physical and technical measures to prevent unauthorized access, loss, falsification or leakage. We implement necessary and appropriate measures to manage the personal information of the customers by maintaining the security system, developing the administrative structure and educating the employees among others.
7. Other pertinent information on international data transfer
Other pertinent information related to the international data transfer of the personal information is as follows:
We cannot specify the country to which the personal information is transferred since it varies depending on to which countries customers make remittances and via which countries the remittances are routed as well as in which countries our partner financial institutions and their group companies reside.
We are unable to present the legal frameworks of the extensive number of countries. Our partners are financial institutions or financial service providers duly licensed by or registered with the competent authorities of the countries permitted to conduct overseas remittance business in their countries; therefore, they comply with the laws and regulations for the personal data protection in their respective domiciles.
8. Procedure to request disclosure of the personal data
We will process a request from an individual or his attorney for the disclosure of his personal data we hold as follow. Such disclosure includes notification of the purposes of use, disclosure, correction and deletion of the personal information.
- After verifying the identity of the individual and/or his attorney, we will inform of the detailed procedure to request to disclose his personal information. We may respond in writing or by another means or by the means designated by him unless it is difficult for us to do so. We may require a request in a prescribed format in certain cases.
- A request from an individual or his attorney for the disclosure of his personal data should be made using the prescribed form, which should be mailed to the address in Paragraph 10 below with the proof for his identification enclosed.
- There will be no fee for the disclosure. He shall bear his own costs, such as the cost of his communication with us and the cost for his preparation of his identification as described above.
- We will respond within a reasonable period of time.
9. Compliance to laws and regulations and updates
We abide by laws and regulations of Japan and other rules applicable to the personal information of the customers and review this policy from time to time for improvement.
Contact the following address for more details:
Unidos Co., Ltd.
Stairs Building 2F, 2-4-8 Hyakunin-cho, Shinjuku-ku