Personal Information Protection<\/strong> Personal Information Protection Policy<\/strong> At Japan Communications Ltd., we are committed to providing our clients with exceptional service.\u00a0 As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.<\/p>\n While we have always respected our clients\u2019 privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of the Personal Information Protection Act (PIPA).\u00a0 PIPA came into effect on January 1, 2004.<\/p>\n We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.<\/p>\n This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients\u2019 personal information.\u00a0 Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients\u2019 personal information and allowing our clients to request access to, and correction of, their personal information.<\/p>\n This Personal Information Protection Policy applies to Japan Communications Ltd.<\/p>\n This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Japan Communications Ltd.<\/p>\n Personal Information \u2013means information about an identifiable individual. Personal information does not include contact information (described below).<\/p>\n Contact information<\/strong><\/span>\u00a0\u2013 means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.\u00a0 Contact information is not covered by this policy or PIPA.<\/p>\n Privacy Officer<\/strong><\/span> \u2013 means the individual designated responsibility for ensuring that Japan Communications Ltd., complies with this policy and PIPA.<\/p>\n 1.1\u00a0 Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.<\/p>\n 1.2\u00a0 We will only collect client information that is necessary to fulfill the following purposes:<\/p>\n 2.1\u00a0 We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).<\/p>\n 2.2\u00a0 Consent can be provided orally, in writing, electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.<\/p>\n 2.3\u00a0 Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client does not opt-out.<\/p>\n 2.4\u00a0 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for Japan Communications Ltd., to use their personal information in certain ways.\u00a0 A client\u2019s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.\u00a0 If so, we will explain the situation to assist the client in making the decision.<\/p>\n 2.5\u00a0 We may collect, use or disclose personal information without the client\u2019s knowledge or consent in the following limited circumstances:<\/p>\n 3.1\u00a0 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:<\/p>\n 3.2\u00a0 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.<\/p>\n 3.3\u00a0 We will not sell client lists or personal information to other parties unless we have consent to do so.<\/p>\n 4.1\u00a0 If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.<\/p>\n 4.2\u00a0 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.<\/p>\n 5.1\u00a0 We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.<\/p>\n 5.2\u00a0 Clients may request correction to their personal information in order to ensure its accuracy and completeness.\u00a0 A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.<\/p>\n 5.3\u00a0 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year.\u00a0 If the correction is not made, we will note the clients\u2019 correction request in the file.<\/p>\n 6.1\u00a0 We are committed to ensuring the security of client’s personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.<\/p>\n 6.2\u00a0 The following security measures will be followed to ensure that client’s personal information is appropriately protected:<\/p>\n [the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures].<\/p>\n 6.3\u00a0 We will use appropriate security measures when destroying client\u2019s personal information such as shredding documents, deleting electronically stored information.<\/p>\n 6.4\u00a0 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.<\/p>\n 7.1\u00a0 Clients have a right to access their personal information, subject to limited exceptions.<\/p>\n 7.2\u00a0 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.<\/p>\n 7.3\u00a0 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.<\/p>\n 7.4 \u00a0We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.<\/p>\n 7.5\u00a0 A minimal fee may be charged for providing access to personal information. \u00a0Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request.<\/p>\n 7.6\u00a0 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.<\/p>\n 8.1\u00a0 The Privacy Officer or designated individual is responsible for ensuring Japan Communications Ltd.\u2019s \u00a0compliance with this policy and the Personal Information Protection Act.<\/p>\n 8.2\u00a0 Clients should direct any complaints, concerns or questions regarding Japan Communications Ltd.\u2019s \u00a0compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of Ontario.<\/p>\n Contact information for Japan Communications Ltd.\u2019s Privacy Officer or designated individual:<\/p>\n Shin Kawai<\/p>\n
\nPrivate Sector Privacy Legislation<\/p>\n
\nJapan Communications Ltd.,<\/p>\nPersonal Information Protection Policy & Terms and Conditions<\/h1>\n
Scope of this Policy<\/h2>\n
Definitions<\/h2>\n
Policy 1 \u2013 Collecting Personal Information<\/h2>\n
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Policy 2 \u2013 Consent<\/h2>\n
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Policy 3 \u2013 Using and Disclosing Personal Information<\/h2>\n
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Policy 4 \u2013 Retaining Personal Information<\/h2>\n
Policy 5 \u2013 Ensuring Accuracy of Personal Information<\/h2>\n
Policy 6 \u2013 Securing Personal Information<\/h2>\n
Policy 7 \u2013 Providing Clients Access to Personal Information<\/h2>\n
Policy 8 \u2013 Questions and Complaints:\u00a0 The Role of the Privacy Officer or Designated Individual<\/h2>\n