Handling of Personal Information

Privacy Policy

This Privacy Policy has been established based on the recognition that Nabtesco Corporation and its group companies (collectively, the “Nabtesco Group”) have a social responsibility to promote the proper handling of personal information. The Nabtesco Group is committed to ensuring that all officers and employees comply with this Privacy Policy and to exerting all possible efforts to protect personal information.

1. Basic stance

In the course of handling the personal information of customers, business partners, shareholders, job applicants and all other individuals (collectively, “Customers”), the Nabtesco Group will comply with all laws and governmental regulations concerning the proper handling of personal information and all other applicable rules and guidelines.

2. Purpose of using personal information

The Nabtesco Group will use the personal information received from Customers solely within the scope of permissible use described as follows.

  • Introduction of products and services
  • Response to inquiries and questions about products and services
  • Communication, response and administration necessary for the conclusion and execution of agreements
  • Operations related to the delivery of products and provision of services
  • Operations for the settlement of payment for products and services
  • Confirmation of the usage conditions of products and services and the provision of feedback/support for products and services
  • Invitation to events, exhibitions, etc. and communications in relation to their operation
  • Signing up for e-mail distribution services or other services available on the Nabtesco Group’s websites, distribution, confirmation and other communications in relation to those services
  • Response to the access to and use of the Nabtesco Group’s facilities by Customers
  • Planning of and response to human exchange activities, including the acceptance of secondment
  • Shareholder administration and notifications to shareholders pursuant to the Companies Act of Japan
  • Provision of recruitment information to job applicants; screening and selection of prospective employees
  • Creation of data through de-identification of personal information, which cannot be restored to original personal information (“anonymously processed information”)
  • Processing of personal information into data through which a specific individual cannot be identified unless the information is collated with other information (“pseudonymously processed information”)
  • Investigations, examinations, surveys and reports about compliance
  • Other purposes of use as announced on Nabtesco Group’s websites and others where its products and services are introduced

3. Purposes of using pseudonymously processed information

The Nabtesco Group may use pseudonymously processed information for any of the purposes listed below.

  • Development of the Nabtesco Group’s products and services, improvement of their quality, research for new services, and various marketing surveys and analysis to facilitate the foregoing
  • Creation of statistical data for business analysis and utilization of analytical findings
  • Provision of other information that the Nabtesco Group may find beneficial for Customers

4. Shared use of personal data

The Nabtesco Group may share personal data received from Customers (excluding the specified personal information) for use in accordance with the following conditions.

(1)Shared use within the Nabtesco Group

  • Types of personal data that may be shared:
    Customers’ attribute information, including the name, address, telephone number, age, gender and e-mail address as well as other information provided by Customers, including the details of inquiries made by them
  • Scope of those who may share personal data
    Nabtesco Group companies within and outside Japan
    (Group companies in Japan, Group companies outside Japan)
  • Purposes of shared use
    The purposes described in Section 2 (Purposes of using personal information)
  • Administrator for shared use
    Nabtesco Corporation

(2)Shared use of personal information at the Nabtesco Group’s construction sites

  • Types of personal data that may be shared
    • Name, date of birth and age
    • Job type
    • Whether or not insured regarding medical insurance under the Health Insurance Act/National Health Insurance Act of Japan, pension provided under the National Pension Act/Employees’ Pension Insurance Act of Japan and employment insurance under the Employment Insurance Act of Japan
    • Whether or not the worker is qualified for mutual aid under Article 2. 7 of the law on the Japanese Smaller Enterprise Retirement Allowance Mutual Aid System
    • Details of education on health and safety, if the person has received such education
    • Qualifications for construction work-related knowledge, technique and skills
    • Other items that need to be described in the work ledger and others in pursuant to the Construction Business Act of Japan and others
  • Scope of those who may share personal data
    Companies that placed an order for the work, contractors that placed an order for the work to Nabtesco Group companies, Nabtesco Group companies, and partner companies engaging in the work at the construction sites of Nabtesco Group companies
  • Purposes of shared use
    Creation and management of work ledgers, list of workers and others as required by the Construction Business Act of Japan and other laws and regulations
    Communication and information sharing about the construction work
    On-site safety management
  • Administrator for shared use
    Nabtesco Group companies that placed/received an order for the work (excluding the types of work to which the Construction Business Act is not applied.)

5. Provision of personal data to third parties

The Nabtesco Group will never disclose or provide any of Customers’ personal information without the person’s consent, to any third parties other than the parities included by the Nabtesco Group in the scope of those who may share personal data, the Nabtesco Group’s outsourcing partners and those taking over a business from the Nabtesco Group, except when such disclosure is required under the law or justified on any other grounds.

※Specified personal information of Customers will not be provided to any third party, regardless of whether the person’s consent is obtained or not, except when such information is provided to an outsourcing partner of the Nabtesco Group or provided under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures of Japan (the “Number Use Act”) or any other applicable laws and regulations.

6. Administration of outsourcing partners

The Nabtesco Group will conclude a non-disclosure agreement with the outsourcing partners to whom the Nabtesco Group will disclose Customers’ personal information pursuant to the preceding paragraph and direct and supervise the outsourcing partner to ensure the proper handling and protection of the personal data.

7. Transfer of personal data outside Japan

For the transfer of Customers’ personal data outside Japan, the Nabtesco Group will implement necessary measures in line with the relevant laws and regulations.

8. Disclosure, correction, etc. or cessation of use, etc. of retained personal information

If Customers desire disclosure, correction, etc. (meaning correction, addition or deletion) or cessation of use, etc. (meaning deletion, cessation of use or cessation of provision to third parties) with regard to their own personal data retained by the Nabtesco Group, they will be required to contact the Human Resources Department of Nabtesco Corporation. After verifying the identity of the person, the Nabtesco Group will take necessary action as soon as reasonably possible. However, the foregoing does not apply when acting as requested by the person may be detrimental to any right of a third party, or when the Nabtesco Group determines that its proper business operations may be significantly disrupted, or when a violation of law may arise.

9. Items related to data security management

The Nabtesco Group will appropriately manage data security when handling personal data, thereby preventing illegal access to the data from outside the Nabtesco Group as well as data loss, destruction, falsification, leakage and other incidents. To this end, the Nabtesco Group will implement data security management measures in an appropriate and rational manner. In the event of an incident, the Nabtesco Group will promptly take corrective measures. If you have any questions about the Nabtesco Group’s data security management, please make an inquiry to the contact point described in Section 11 below.

10. Names, addresses and representatives of Nabtesco Group companies

Nabtesco Corporation: https://www.nabtesco.com/company/profile.html
Nabtesco Group companies in Japan: For Group companies in Japan, please refer to the names, addresses and representatives of the business operators handling personal information on their respective websites.

11. Inquiries

Any inquiries or questions regarding personal information can be directed to the contact point to which Customers provided their personal information. If you are unaware of the contact point, please click the following link to contact the Human Resources Department of Nabtesco Corporation.

Contact for inquiries

Please note that this Privacy Policy may be revised from time to time without notice.

Revised on April 1, 2022

Privacy Policy for Personal Information of Nabtesco Group Members

Nabtesco Corporation (“the Company”) and its group companies (collectively, the “Nabtesco Group”) undertake to properly handle personal information of employees or other personnel serving in the Nabtesco Group (“NTS Group Members”) pursuant to the conditions described below, in compliance with the Act on the Protection of Personal Information of Japan, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures of Japan (the “Number Use Act”), and other norms.

※NTS Group Members refer to officers, employees and any other persons who are currently engaged in business operations of the Nabtesco Group, who will join the Nabtesco Group (by receiving job offers from it) and those who were engaged in business operations of the Nabtesco Group in the past (retirees).

1. Purposes of using personal information of NTS Group Members

The Nabtesco Group will acquire, retain and use the personal information of NTS Group Members for any of the purposes listed below.

  • Communications in the course of business operations (including emergency communications); operations for the administration of equipment and facilities
  • Reassignment, personnel evaluation, commendation, disciplinary action and other operations for human resources management
  • Back-office services for workforce management
  • Operations for wages, bonuses, retirement benefits, corporate pension plans and the like
  • Operations for personnel education and training
  • Operations for employee welfare and benefits
  • Operations for safety and health, healthcare administration and the like
  • Operations for employment insurance and social insurance
  • Operations for tax management, social security and other statutory or regulatory affairs
  • Operations regarding immigration control and status of residence
  • Operations for employee shareholding plans
  • Operations for the creation of statutory documents, such as invitation letters and for the management of stock option exercise
  • Operations for the management of inventors as part of the management of patent applications, etc.; for the payment of rewards for intellectual property; and for the registration and administration of user IDs for intellectual property-related databases
  • Operations for IR, PR, advertising, recruitment and the publication of the in-house magazine articles
  • Investigations, examinations, surveys and reports about compliance
  • Operations associated with or incidental to any of the operations listed above

2. Purposes of using specified personal information of NTS Group Members and their dependent relatives

The Nabtesco Group will acquire, retain and use “specified personal information” of NTS Group Members and their dependent relatives for any of the purposes listed below, solely to the extent necessary for the intended purpose in each instance.

  • Back-office services for preparation and submission of withholding certificates
  • Back-office services for regulatory notifications in relation to employment insurance
  • Back-office services for insurance claims based on the Industrial Accident Compensation Insurance Act of Japan
  • Back-office services for regulatory notifications in relation to health insurance or employees’ pension insurance
  • Documentation for property accumulation savings plans for employees
  • Documentation for employee shareholding plans
  • Documentation for public pension plans
  • Back-office services for regulatory notifications for tertiary insured persons under Japan’s national pension plan
  • Preparation of payment reports for remunerations, fees and the like
  • Preparation of payment reports for shares in the Nabtesco Group
  • Preparation of payment reports for real estate usage fees, consideration for acquisition of real estate and the like
  • Other back-office services associated with any of the services listed above

3. Shared use of personal data

The Nabtesco Group may share personal data (excluding “specified personal information”) of NTS Group Members for use in accordance with the following conditions.

(1)Shared use between Nabtesco Group companies

  • Types of personal data that may be shared
    The personal data of NTS Group Members acquired and retained by the Nabtesco Group that fall under any of the categories listed below, limited to what is needed to achieve the purpose of shared use in each instance
    • An NTS Group Member’s name, employee code and other identification number assigned on an individual basis, residential address, division or department, job position, e-mail address, or other basic information
    • Information about an NTS Group Member’s family members including their names and dependency status
    • An NTS Group Member’s job qualifications, reassignment, job performance evaluation, commendation, disciplinary action and other information related to human resources management
    • Information about wages, bonuses, retirement benefits, corporate pension plans and the like
    • Information about employee benefit programs such as the status of usage of benefit services
    • Information about medical examination findings and other health information
    • Other information that the Nabtesco Group may acquire and retain in the context of personnel administration and business operation and administration
  • Scope of those who may share personal data
    Nabtesco Group companies within and outside Japan
    (Group companies in Japan, Group companies outside Japan)
  • Purposes of shared use
    The purposes described in Section 1 (Purposes of using personal information of NTS Group Members)
  • Administrator for shared use Nabtesco Corporation

(2)Shared use of personal information at the Nabtesco Group’s construction sites

  • Types of personal data that may be shared
    • Name, date of birth and age
    • Job type
    • Whether or not insured regarding medical insurance under the Health Insurance Act/National Health Insurance Act of Japan, pension provided under the National Pension Act/Employees’ Pension Insurance Act of Japan and employment insurance under the Employment Insurance Act of Japan
    • Whether or not the worker is qualified for mutual aid under Article 2. 7 of the law on the Japanese Smaller Enterprise Retirement Allowance Mutual Aid System
    • Details of education on health and safety, if the person has received such education
    • Qualifications for construction work-related knowledge, technique and skills
    • Other items that need to be described in the work ledger and others in pursuant to the Construction Business Act of Japan and others
    • Contact information, including the cell phone number of the worker/the person’s family member
  • Scope of those who may share personal data
    Companies that placed an order for the work, contractors that placed an order for the work to Nabtesco Group companies, Nabtesco Group companies, and partner companies engaging in the work at the construction sites of Nabtesco Group companies
  • Purposes of shared use
    Creation and management of work ledgers, list of workers and others as required by the Construction Business Act of Japan and other laws and regulations
    Communication and information sharing about the construction work
    On-site safety management
  • Administrator for shared use
    Nabtesco Group companies that placed/received an order for the work (excluding the types of work to which the Construction Business Act is not applied.)

4. Provision of personal data to third parties

The Nabtesco Group will never disclose or provide any of NTS Group Members’ personal data without their consent, to any third parties other than the parties included by the Nabtesco Group in the scope of those who may share personal data, the Nabtesco Group’s outsourcing partners or those taking over a business from the Nabtesco Group, except when such disclosure is required under the law or justified on any other grounds.

※Specified personal information of NTS Group Members will not be provided to any third party, regardless of whether their consent is obtained or not, except when such information is provided to an outsourcing partner of the Nabtesco Group within the scope of purposes of permissible use specified in this Policy or provided under Article 19 of the Number Use Act or any other applicable laws.

5. Miscellaneous provisions

Matters not specified in this Privacy Policy are governed by the Privacy Policy of the Nabtesco Group.

6. Inquiries

Any inquiries or questions regarding personal information of NTS Group Members can be directed to the following.

Human Resources Department, Nabtesco Corporation
General administration & human resources department of each Nabtesco Group company

Please note that this Privacy Policy may be revised from time to time without notice.

Revised on April 1, 2022