Personal Information Protection Policy
Travelex Japan KK (“Travelex”) is committed to ensuring the privacy of the personal information it has acquired from customers. Travelex complies with the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003) (“Act”), and here publishes the policy it has established regarding protection and use of personal information it acquires from customers (“Policy”).
Proper acquisition of personal information
Travelex acquires personal information through fair and proper means.
Purpose of using personal information
Travelex acquires personal information for safe and secure implementation of transactions with customers as well as for provision of better financial products and services for customers. Travelex uses personal information it has acquired for the purpose of confirming customer identity according to internal procedures and law, examining status of transactions it is conducting, and proposing customers its new products and/or services.
- Foreign exchange transactions (shop counter services, foreign currency doorstep delivery, foreign currency wholesale, etc.), and related transactions;
- Cash Passport (prepaid cards for overseas travel), and related transactions; and
- Western Union’s international money transfer services, and related transactions.
- Any other businesses and related to them than stated above that Travelex can operate (including those might be approved to operate in the future)
Travelex uses personal information it has acquired for the purpose of:
- Accepting applications of customers for financial products and services;
- Confirming customer identity and other identifying matters according to the Act on Prevention of Transfer of Criminal Proceeds, Foreign Exchange and Foreign Trade Act, and other related laws and regulations, as well as conforming eligibility of customers for specific financial products and/or services;
- Managing due dates of financial services Travelex offer;
- Making judgments about appropriateness of provision of financial products and services, including judgments based on the principle of suitability;
- Conducting contract work for another business operator in a proper manner where Travelex is entrusted by the entity with personal information in whole or in part to process it;
- Exercising Travelex’s right and/or fulfilling its obligations according to contracts with customers and/or law;
- Allowing Travelex’s group companies (its parent and affiliates) to better understand customers’ needs and deliver information about products and services most suitable for them;
- Conducting market research, data analyses, and questionnaires surveys, among others, for research and development of financial products and services;
- Proposing or introducing a variety of financial products and services to customers by sending direct mails or other means;
- Canceling transactions with customers, and managing affairs after cancelation; and
- Conducting other operations needed to implement transactions with customers properly and smoothly.
Travelex uses personal information without departing from the purpose for which it has been acquired, only within the range needed to conduct transactions, and refrains from using it for any other purpose than that for which it was intended. Travelex also acquires and uses sensitive information of customers within the minimum range needed to conduct transactions and/or authorized by law.
Types of personal information
For the purpose of providing its products and services for customers, Travelex acquires their names, addresses, and phone numbers, or other information it needs to confirm their payments, identity, and identifying matters. Travelex collects different types of information depending on products and/or services it offers, and Travelex may decline to provide a customer with products or services he/she wants when he/she refuses to transfer information Travelex needs.
Restriction of provision of personal information to a third party
Travelex may transfer customers’ personal information to a third party only when:
- Travelex has obtained the customers’ consent;
- Travelex considers it necessary based on laws and regulations;
- Travelex entrusts the information in whole or in part with the third party (including overseas comapanies) within the range needed to implement transactions. In such a case, Travelex exercises necessary and appropriate supervision over the trustee;
- Travelex considers it necessary for the customers themselves and/or for public interests;
- Travelex proposes to customers financial products and services it considers useful for them; and
- Travelex allows its group companies to better understand customers’ needs and deliver information about products and services most suitable for them;
Quality of personal information
Travelex intends to keep personal information it holds correct, complete, and up-to-date at all times. If you find your personal data Travelex retains incorrect, incomplete, or out-of-date, please contact it. Travelex will correct the information according to your request within an appropriate range.
Security Control Measures for information
Travelex preserves personal information it has acquired from customers electrically, electromagnetically, on paper or by other means, and is committed to keeping the information safe and secure. Access to the storages is strictly controlled. Travelex takes appropriate measures to prevent customer information from being lost, misused, accessed by any unauthorized person, falsified, or leaked. In terms of security of transactions on the internet, Travelex protects customer information using cutting-edge technologies, including date encryption, so that customers will carry out transactions with security.
Disclosure of personal information
Any customer may request Travelex to disclose his/her personal data it retains. When you wish to request Travelex to disclose your personal data it retains, please contact the “Contact person” for the Policy. Travelex honours the request, after confirming your identity(*), within an appropriate period of time. You may be charged some fees for disclosing retained personal data, depending on types of data you request Travelex to disclose and/or their contents. In such a case, Travelex will ask you for consent before starting procedures for disclosure.
Travelex may decline to disclose to a customer his/her personal data it retains for certain reasons, which it will explain to the customer. Travelex may decline disclosure for reasons below:
- That Travelex cannot identify the person;
- That items of the information Travelex is requested to disclose do not fall under retained personal data;
- That it is difficult to identify personal data that Travelex is requested to disclose;
- That the disclosure will have unreasonable influence on personal data of other customers;
- That personal data Travelex is requested to disclose relate to procedures of a lawsuit concerning the customer; and
- That disclosure of the specific information is prohibited by law;
(Ways to confirm identity)
- Travelex confirms your identity with identity documents issued by a public agency (valid driver’s license, passport, etc.); and
- A legal representative for a customer can make a disclosure request only with documents that confirm his/her power of attorney.
Termination of use of personal information
If you would not wish Travelex to provide you with information by direct mail or by other means, including postal mail, telephone and e-mail, please contact the “Contact person” for the Policy. Travelex will terminate provision of information immediately.
If you have any question about Travelex’s Personal Information Protection Policy, please contact:
Compliance Dept. Travelex Japan KK
ORIX Akasaka 2-chome Building 6th Floor, 9-11, Akasaka 2-chome, Minato-ku, Tokyo 107-0052
Inquiries and complaints
When you inquire of Travelex about your own personal data, you would wish Travelex to correct or terminate use of your personal data it retains, or file a complaint to Travelex about its violation, or alleged violation, of the Policy or the Act, please contact the Compliance at the “Contact person” as above.
Travelex will do everything it can do to solve any complaint it has received from customers. But if you feel Travelex is not doing enough, you may consult with external institutions. You will be accepted by different institutions depending on products or services Travelex provided for you. Please make sure which institution you should consult with before asking counsel.
Foreign exchange (shop, doorstep delivery, etc.)
(For Cash Passport, Travelex has adopted the Financial ADR (Alternative Dispute Resolution) system.)
Kessaikyo (fund transfer operators’ association) (dedicated website: www.s-kessai.jp
) Phone: 03-3219-0628
Dispute Resolution Center, Tokyo Bar Association (Phone: 03-3581-0031)
Arbitration Center, Daiichi Tokyo Bar Association (Phone: 03-3595-8588)
Arbitration Center, Daini Tokyo Bar Association (Phone: 03-3581-2249)
Western Union international money transfer service
Western Union Customer Service Center Phone: 0034-800-400-733
Changes to the Policy
Travelex may make changes to the Policy for various reasons. Travelex will publish these in documents, on its website, and/or by other means.
Links to other sites
Information about persons who are alive that identifies specific persons with names, dates of birth or other entries contained in it.
Data generated from personal information by computers or other tools and stored into a database in an orderly manner that enables retrieval.
Retained personal data (personal data that Travelex retains):
Personal data over which a business operator has the authority, among others, to disclose, to correct, to discontinue its utilization, and to erase, excluding the data which are to be erased within six months.
Act on Prevention of Transfer of Criminal Proceeds:
The act has been enforced to prevent designated operators from being used for funding of terrorism, money laundering, or other unlawful purposes by encouraging them to improve their customer management systems, and the Act obliges designated operators, among others, to confirm the identity of their customers.
Information about highly private affairs, such as race, ethnicity, family origin, legal domicile, or other affairs that may lead to social discrimination, or thought, religion, political opinions, or information about a person’s body.