Purpose of Use of Personal Information

The Company will use personal information within the scope of the following purposes of use. If we intend to use personal information for any purpose other than those listed below, we will inform you of such purpose of use in advance.
(1) Responses to inquiries and our record keeping
(2) Sending products, substitutions, prizes, reports and other documents
(3) Questionnaire surveys for product development and service improvement
(4) Personalization of products
(5) Recruitment activities
(6) Personnel and labor management, social insurance procedures, official procedures such as registration, execution of contracts and other communications with the employees of the Company (including seconded employees)
(7) Contacting suppliers, vendors or other business partners, or billing and payment processing and executing contracts with such business partners
(8) Contacting shareholders and dividend procedures
(9) Contacting our retired employees
(10) Organizational management of our group companies

Sharing of Personal Information

We may share personal information with third parties in accordance with the following requirements. In such cases, the third parties with whom we share personal information will also make efforts to handle and protect personal information appropriately in accordance with their privacy policy which are equivalent to those of the Company.
(1) Items of personal information to be shared:
Name, company name, department, position, address, telephone number, fax number, e-mail address
(2) Scope of third parties with whom we share personal information:
The following Tombow Pencil Group companies

• Tombow Pen & Pencil GmbH
• American Tombow, Inc.
• Tombow Pencil (Dalian) Co., Ltd.
• Tombow Manufacturing Asia Co.,Ltd.
• Tombow Stationery Vietnam Co.,Ltd.
• Tombow Vietnam Ltd.

(3) Purpose of use of personal information by the parties with whom we share such information:

• (1) through (3), (6), (7), (9), (10) described in “Purposes of Use of Personal Information” above

(4) Person responsible for the management of personal information:

Personal information supervisor at Tombow Pencil Co., Ltd.

Provision of Personal Information to Third Parties

We will not provide or disclose personal information to third parties without the consent of the individual.
However, in cases where the Company outsources the handling of personal information for the purpose of providing services (e.g., sending prizes or sending e-mails), the Company may provide personal information only to the extent necessary after concluding an appropriate contract with the contractor handling personal information for and on behalf of the Company.
In addition, we may disclose personal information when required to do so by law or by a court of law, the police or other public agency.
We may provide third parties located in the following foreign countries with certain personal information only with the prior consent of the individual.
● Germany, U.S.A., China, Vietnam
For information on legislation for the protection of personal information in foreign countries to which we may send personal information, please refer to the “Survey of Foreign Legislation for Protection of Personal Information” (Japanese only) posted on the website of the Personal Information Protection Commission.
The third parties to whom we may provide personal information comply with the legislation for the protection of personal information in the foreign country concerned.

Disclosure, Correction, Suspension of Use, Deletion or Other Handling of Personal Information

We confirm that the individuals have the right to request disclosure, correction, suspension of use, suspension of provision to a third party, deletion, or notification of the purpose of use (hereinafter collectively referred to as “Disclosure”) of their own personal information, and if such a request is made, we will respond as follows.

■Person who can make a request for Disclosure
The principal or his/her agent with a document evidencing his/her authority to represent the principal (hereinafter referred to as the “agent”)

■Method of making request for Disclosure
Please fill out the form (A) specified below, enclose the required documents (B), (C), and (D), and send them by registered or recorded delivery mail to the address below.
Please indicate “Documents for request for Disclosure enclosed” on the envelope.

• Postal Code 114-8583 6-10-12 Toshima, Kita-ku, Tokyo
• To: Personal information handling manager, Tombow Pencil Co., Ltd.

When making a request for Disclosure, please be aware of the following items.

All expenses for obtaining identification documents, postage, etc. shall be borne by the person making the request.

All documents submitted at the time of request will not be returned.

Requests other than sending by post (e.g., in person, by telephone, or by e-mail) will not be accepted.

The fee will not be returned even if disclosure or notification of purpose of use is not made for any of the below-specified reasons.

(A) Our designated invoice form
• Request for Disclosure of Personal Information (Japanese only)

(B) Identification documents
• A copy of an official document with a photograph that can verify the identity of the person making the request, such as a driver’s license, passport or similar document (which must be a document that indicates the name and address of the person making the request for Disclosure and must be within the period of validity).

(C) Documents required if the request is made by an agent
• Identification documents of the agent (the same as (B) above)
• In the case of a statutory agent: A document to verify that the person making the request has the authority of statutory agent (a copy of the family register issued within the last 3 months; or in the case of a person with parental authority, a copy of a valid insurance card showing dependents (children) is also acceptable).
• In the case of an appointed agent: Power of attorney (Japanese only)and certificate of seal impression of the principal

(D) Documents proving payment of fees (such as bank transfer certificate or bank transfer statement)

■Fees for Disclosure In the case of disclosure or notification of purpose of use, please transfer a handling fee of 1,000 yen per request to the account below.

• Bank/branch name: MUFG Bank, Ltd., Asakusabashi Branch
• Name of account holder: Tombow Pencil Co., Ltd.
• Account number: Current account 9006201
• Transfer fee: Paid by the individual making the request

■Cases in which we cannot accept a request for Disclosure of personal information Requests for Disclosure cannot be accepted if any of the following items apply:
• If we cannot confirm that the request is from the individual himself/herself, such as when the address on the request form differs from the address on the identification documents, or when the information registered with us differs from that on the request form;
• If the right of representation cannot be verified when a request is made by an agent;
• If the prescribed request documents are incomplete;
• If the subject of the request does not fall under the category of “personal information subject to disclosure”;
• If there is a risk of harm to life, body or other rights and interests of the individual concerned or a third party;
• If there is a risk of significant hindrance to the proper conduct of our business; or
• If it would otherwise violate laws or regulations.

■Response Method We will respond to the requestor sending by post or e-mail to the address on the request form, according to the requestor’s choice.

Contact Information

For inquiries regarding personal information obtained or retained by us, including complaints., please contact us at the following “Representative Telephone” or “Inquiry Web Form”.

1)Representative Phone
• 03-3912-1181
• Office hours: 10:00 – 12:00 / 13:00 – 15:00
• (Excluding Saturdays, Sundays, national holidays, year-end and New Year holidays, and summer holidays) Please follow the voice guidance and select “7 (Other)”.
2) Click here for inquiry web form.

Security Control Measures for Personal Information

In order to safely manage personal information, we have established internal rules and organizational systems for the handling of personal information, and conduct periodic reviews of these rules and systems as well as employee training. In addition, to prevent loss, destruction, falsification or leakage of personal information, we control access to personal information and access rights in areas where personal information is handled, and implement appropriate information security measures against unauthorized access from outside, computer viruses and similar problems.

Changes to our Privacy Policy

We will handle personal information appropriately and review and improve this policy as appropriate. This policy is subject to change without prior notice.