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TOP Privacy Policy

Personal Information Protection



I. Privacy Statement
A. In the handling personal information ("personal information" is defined hereinafter as information relating to living individuals which can be used to identify specific individuals), the Simul Group companies pledge to strictly comply with this privacy statement, the obligations stipulated in the Law Concerning the Protection of Personal Information and the various other applicable laws and regulations related to personal information protection, as well as the guidelines issued by the state minister in charge.
B. The Simul Group companies shall, after specifying to the degree possible the purposes of use of the personal information, handle personal information only within the scope of those purposes of use, excluding cases where the consent of the principal ("principal" is defined hereinafter as the specific individual identified by the personal information) has been received in advance and cases provided by law as exceptions. Moreover, the Simul Group companies shall use personal information provided (entrusted) by outsourcers to a Simul Group company accompanying its undertaking of outsourced duties only within the scope necessary for the achievement of the purposes of the contract with the said outsourcers.
C. The Simul Group companies shall use only lawful means to obtain personal information and shall, excluding cases provided by law as exceptions, either publicly announce in advance the purposes of use of the information or notify or publicly announce the purposes of use to the principal immediately after obtaining the information. The Simul Group companies shall, in principle, clearly state the purposes of use in advance in the case that the information is obtained in writing directly from the principal.
D. The Simul Group companies shall endeavor to maintain the personal data handled ("personal data handled" is defined hereinafter as the personal information comprising a personal information database, etc. and "personal information database, etc." is defined hereinafter as a collection of information, including personal information, which is designated by government ordinance as something systematically structured so as to ensure easy retrievability of specific personal information, such as an electronic database or a Who's Who publication) so that it is accurate and up to date within the scope of the purposes of use.
E. The Simul Group companies shall not, excluding cases provided by law as exceptions, provide personal data handled to third parties without receiving in advance the consent of the principal.
F. The Simul Group companies shall, in accordance with the law, respond to requests received from the principal for disclosure, correction, etc. of retained personal data ("retained personal data" is defined hereinafter as personal data which the Simul Group companies have the authority to disclose, correct, etc., which is not designated by government ordinance as information which, if the existence or nonexistence of the said information were known, would threaten public (or other) welfare, and which is not designated by government ordinance as information that must be deleted within six months).
G. The Simul Group companies shall promptly and appropriately respond to complaints from the principal regarding the personal information handled and shall endeavor to develop an in-house framework for that purpose.
H. The Simul Group companies shall take all necessary and appropriate measures and shall supervise employees, etc. and subcontractors to prevent illegal access to or loss, destruction, tampering, leakage, etc. of the personal information handled by the Simul Group companies.
I. The Simul Group companies shall review as appropriate and improve on an ongoing basis its compliance program, including internal regulations regarding the protection of personal information.
  Simul International, Inc.
Simul Business Communications, Inc.
Simul Technical Communications, Inc.
LinkTrans Simul, Inc.


II. Public Announcement Issued in Accordance with the Law Concerning the Protection of Personal Information

  Businesses Handling the Personal Information:
Simul International, Inc.
Simul Business Communications, Inc.
Simul Technical Communications, Inc.
LinkTrans Simul, Inc.

Simul International, Inc., Simul Business Communications, Inc., Simul Technical Communications, Inc., and LinkTrans Simul, Inc. (hereinafter referred to collectively as "the Simul Group companies") hereby announce matters related to the purposes of use of personal information and retained personal data obtained by the Simul Group companies, the provision to third parties of personal data, the procedures regarding requests for disclosure, etc. of retained personal data, and the reception of complaints regarding the handling of personal information based on the Law Concerning the Protection of Personal Information, the Basic Policy Concerning the Protection of Personal Information (cabinet decision), enforcement regulations for the Law Concerning the Protection of Personal Information, and guidelines issued by the state minister in charge based on the Law Concerning the Protection of Personal Information.

Personal information related to employment management, such as the personal information of Simul Group company employees and others, does not fall under the provisions of this public announcement.

Matters Publicly Announced

A. Purposes of Use of Personal Information and Retained Personal Data

1. The purposes of use of the personal information obtained directly by the Simul Group companies from the principal through a means other than writing (including websites), personal information obtained indirectly, and retained personal data are listed under b) in relation to the operations listed under a).

a) Operations in Which the Information Will Be Used

Simul International, Inc. Operations
(1) Translation and interpreting services
(2) Simul Academy and other language classes and language training programs
(3) Planning and operational support services for international conferences
(4) Other operations related to or incidental to the above items

Simul Business Communications, Inc. Operations
(1) Temporary staffing and permanent job placement services
(2) Other operations related to or incidental to the above item

Simul Technical Communications, Inc. Operations
(1) Rental, operation, sales, and maintenance services for simultaneous interpreting equipment as well as sound and video equipment
(2) Other operations related to or incidental to the above item

LinkTrans Simul, Inc. Operations
(1) Translation services
(2) Other operations related to or incidental to the above item

b) Purposes of Use

(1) To provide products and services in response to orders
(2) To provide information about company products and services
(3) To prepare questionnaires and surveys as well as statistical and marketing materials
(4) To use in research, planning, and development related to the operations of each of the Simul Group companies
(5) To outsource duties in the various processes (including the planning, development, production, marketing, sales promotion, sales, and delivery of products and services), to request cooperation in operations monitoring and others, and to request part-time employees and others and to perform work
(6) Other operations related to or incidental to the above items
Notes:
1. The Simul Group companies shall, in principle, clearly state separately the purposes of use of personal information obtained directly from the principal in writing (including websites).
2. The purposes of use of the personal information of those who are registered with the Simul Group companies are stated separately.
2. The Simul Group companies shall use the personal information provided (entrusted) by outsourcers to a Simul Group company accompanying its undertaking of outsourced duties only within the scope necessary for the achievement of the purposes of the contract with the said outsourcers.

B. Matters regarding Provision of Personal Data to Third Parties

1. The Simul Group companies shall properly control the personal data retained by each of the companies and shall not, excluding cases provided by law as exceptions, provide such personal data to third parties without receiving in advance the consent of the principal.
2. The Simul Group companies shall, in the case of joint use of personal data with a specified third party, directly notify the principal or publicly announce by posting on its website the fact that the personal data will be used jointly by the specified party, the items of personal data that will be jointly used, the party who will be jointly using the data, the purposes of use by that party, and the title of the person responsible for control of the said personal data at that party.

C. Procedures Related to Requests for Disclosure, Etc. of Retained Personal Data

The Simul Group companies shall, based on the Law Concerning the Protection of Personal Information, respond to requests for notification of purposes of use, disclosure, correction, addition, removal, deletion, suspension of use, or suspension of provision to third parties (hereinafter referred to collectively as "requests for disclosure, etc.") regarding retained personal data.

Procedures for requests for disclosure are outlined below. For procedures related to other requests, please inquire at the contact point regarding the handling of personal information indicated in D-1.

1. Specification of Retained Personal Data Desired
  In requests for disclosure, the retained personal data desired for disclosure must be specified.
2. Procedures for Making Requests for Disclosure
  Please phone the contact point indicated in D-1 to learn the detailed procedures for making a request, including the necessary documents.
3. Principal's Identification Documents to Be Submitted at Time of Request for Disclosure
  The principal must submit the following documents to verify his or her identity:
  • In the case of a driver's license, health insurance card, or other official document stating the principal's current address: One copy of that document
  • In the case of a passport or other official document not stating the principal's current address: One copy of that document and one copy of the principal's certificate of residence
  • 4. Requests for Disclosure Made by a Representative
      In the case that the person making the request for disclosure is the legal representative of a minor or a ward who is of age or a proxy authorized by the principal to make the request for disclosure, the following documents [a) or b)] must be submitted in addition to the principal's identification documents listed in C-3.
      a) In the Case of a Legal Representative
    (1) Document verifying the power of attorney of the legal representative
  • A family register or, in the case of a person with parental authority over a minor, a health insurance card on which are written the names of family dependents: One copy of that document
  • (2) Document verifying the identity of the legal representative
  • In the case of a driver's license, health insurance card, or other official document stating the legal representative's current address: One copy of that document
  • In the case of a passport or other official document not stating the legal representative's current address: One copy of that document and one copy of the legal representative's certificate of residence
  •   b) In the Case of an Authorized Proxy
     
    (1) Letter of attorney specified by the Simul Group company: One copy
    (2) Authorized proxy's certificate of seal impression: One copy
    (3) Document verifying the identity of the authorized proxy
  • In the case of a driver's license, health insurance card, or other official document stating the authorized proxy's current address: One copy of that document
  • In the case of a passport or other official document not stating the authorized proxy's current address: One copy of that document and one copy of the authorized proxy's certificate of residence
  •   Note: The copy of the certificate of residence and the certificate of seal impression in C-3 and C-4 must have been issued within three months from the date of submission of the request for disclosure and must state the person's current address.
    5. Processing Fee and Method of Fee Collection
      Requests for disclosure are subject to the following processing fee. The fee is to be remitted to the financial institution designated by the Simul Group company, and the remittance fee is to be covered by the principal or his or her representative.

    Processing fee: ¥970 (including consumption tax, etc.) per request

    No processing fee is charged for requests for correction, addition, removal, deletion, suspension of use, or suspension of provision to third parties.
    6. Method of Responding to Requests for Disclosure
      Responses are sent in writing to the address filed by the principal or his or her representative.
    7. Purposes of Use of Personal Information Obtained via Requests for Disclosure, Etc.
      The personal information obtained via requests for disclosure, etc. shall be handled within the scope necessary to process the request for disclosure, etc. Documents submitted shall not be returned. Documents shall be retained for two years from the date of response to the request for disclosure, etc. and then destroyed.
    8. Notes
     
    a) In the case that a request for disclosure, etc. falls under one of the following, the information shall not be disclosed. In the event of nondisclosure, the Simul Group company shall notify the principal or his or her representative of the same in writing and state the reason why compliance with such a request is not possible. The processing fee is charged even in the case of nondisclosure.
  • In the case that the information requested for disclosure does not fall under the category of retained personal data
  • In the case that the request falls under the category of nondisclosure based on the Law Concerning the Protection of Personal Information
  • b) If the procedures designated by the Simul Group companies are not followed, the request will not be accepted as a request for disclosure. In such a case, any processing fee already remitted shall be refunded.

    D. Contact Point regarding the Handling of Personal Information

    1. Simul Group Contact Point regarding the Handling of Personal Information
      Please address complaints regarding the handling of personal information and requests for disclosure, etc. to the following:
    Tel: 81-3-3539-3100 (9:30 a.m. to 5:30 p.m. daily, excluding Sundays, public holidays, and the year-end/new year's holiday period)
    Notes:  
    1. No request made in person directly at a Simul Group company office shall be accepted.
    2. Separate regulations govern the matters provided in A. to C. in relation to executives and employees (including all position applicants and retired employees and executives) of the Simul Group companies. Please inquire at the above contact point regarding the handling of such personal information.
    2. Name of Authorized Personal Information Protection Organization
    The Simul Group companies are not affiliated with a personal information protection organization at present.

    Copyright 2005 SIMUL INTERNATIONAL, INC. All Rights Reserved.