Personal Information Protection Policy

Travelex Japan KK (“Travelex”) is committed to ensuring the privacy of personal information it acquires from customers. Travelex complies with the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003) (“Act”), and herein publishes the policy it has established regarding the protection and use of personal information it acquires from customers as well as how to properly process customer complaints (“Policy”).

Proper acquisition of personal information

Travelex acquires personal information through fair and proper means.
Personal information will be, in principle, acquired from customers themselves through applications for foreign exchange business or other means.

Purpose of using personal information

Travelex acquires personal information for the purpose of establishing 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 the status of transactions it is conducting, and proposing to customers its new products and/or services.

(Transactions)

  • 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)

 

(Purposes)
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 the due dates of financial services that Travelex offers;
  • Making judgments about the 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 its 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 them direct mail or other by other means;
  • Cancelling 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 will not, in principle, acquire special care-required personal information without first obtaining a customer’s consent. Travelex will not acquire, use or provide to a third party sensitive information of customers except in case it is based on law or otherwise, and if Travelex makes the use, acquisition or provision to a third party, it will do so properly in compliance with applicable laws concerning protection of personal information.

Types of personal information

For the purpose of providing its products and services to customers, Travelex acquires their names, addresses, and phone numbers, or other information that 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 any information that Travelex may need.

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 customer's consent;
  • Travelex considers it necessary based on laws and regulations;
  • Travelex entrusts the information in whole or in part with the third party (including those that are overseas) within the range needed to implement transactions. In such a case, Travelex will exercise the 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;

Joint use of personal information

Travelex may, for the purpose of provision of Travelex’s products and services, as well as of business management and administration as a group, jointly use with Travelex Limited and its subsidiaries and affiliated companies, a customer’s name, address, telephone number, e-mail address and other information related to the customer, and the transaction date, transaction details, transaction amount and other information related to the transaction between the customer and Travelex. In such a case, Travelex Japan KK will be responsible for the management of personal information under the joint use.

 

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 is 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 storage of personal information 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 data encryption, so that customers can carry out transactions with security.

Notification of purpose of use and disclosure of personal information

Any customer may pursuant to the Act, request Travelex to notify them of the purpose of use and disclose his/her personal data it retains. When you wish to request Travelex to notify the purpose of use or disclose your personal data it retains, please contact the “Contact person” for the Policy. Travelex will honour the request without delay after confirming your identity. You may be charged fee for requesting the disclosing of retained personal data, depending on the type of data you request Travelex to disclose and/or its contents. In such a case, Travelex will ask you for consent before starting such a procedure for disclosure.

Travelex may decline to notify the purpose of use for certain reasons, which it will explain to the customer. Travelex may decline notification for the reasons below:

That the purpose of use of the retained personal data that identifies the customer is clear; and

That the case falls under item (i) through item (iii) of Article 18, paragraph 4 of the Act.

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 the reasons below:

  • That Travelex cannot identify the person;
  • That there is a possibility of harming the customer’s or third party’s life, body, fortune or other rights and interests;
  • That there is a possibility of interfering seriously with Travelex implementing its business properly; and
  • That it violates laws or regulations other than the Act.

 

Correction, suspension of use and suspension of provision to third person of personal information

If you request correction, suspension of use, or suspension of provision to a third party of personal data, please contact the “Contact person” for the Policy. Travelex will honour the request without delay after confirming your identity(*). If you do 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.

(Ways to confirm identity)

  • Travelex confirms your identity with identity documents issued by a public agency (e.g. a 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.

 

Contact Person

If you have any question about Travelex’s Personal Information Protection Policy, please contact:

Compliance Department Travelex Japan KK
ORIX Akasaka 2-chome Building 6th Floor, 9-11, Akasaka 2-chome, Minato-ku, Tokyo 107-0052
Phone: 03-3568-1061
Fax: 03-3568-1072

Inquiries and complaints

When you inquire to Travelex about your personal data, or file a complaint with Travelex about its violation, or alleged violation, of the Policy or the Act, please contact the Compliance Department at the “Contact person” as above.

Travelex will do everything it can do to solve any complaint it has received from its customers. However, if you feel Travelex is not properly responsive, you may consult with external institutions. You will be accepted by different institutions depending on the products or services Travelex provided for you. Please make sure you know which institution you should consult with before asking for counsel.

Foreign exchange (shop, doorstep delivery, etc.)


Cash Passport

(For Cash Passport, Travelex has adopted the Financial ADR (Alternative Dispute Resolution) system.)

Complaint handling

Kessaikyo (fund transfer operators’ association) (dedicated website: www.s-kessai.jp) Phone: 03-3219-0628

Dispute resolution

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

Travelex websites may contain links to other websites whose operators may or may not adhere to a privacy policy or be regulated under the Act.

Cookies

Travelex uses cookies to collect information about accesses to its website. Cookies are small-sized text files stored on your computer’s hard drive by a web server, and Travelex has access to the server. You can alter your browser to disable acceptance of cookies, but with such a configuration, you will not be able to use Travelex's website to its full extent. Cookies enable Travelex to know how many accesses its website has accepted at what time as well as to what page on it. Information collected by cookies itself does not identify anyone, but only offers statistics needed to analyze and improve Travelex’s website.

About terms

Personal information:
Information about persons who are alive that falls under any of the items of Article 2, Paragraph 1 of the Act.

Personal data:
Personal information constituting a personal information database, etc.

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 prescribed by cabinet order as likely to harm the public or other interests if their presence or absence is made known nor those set to be deleted within six (6) months.

Special care-required personal information:

Personal information comprising a principal's race, creed, social status, medical history, criminal record, fact of having suffered damage by a crime, or other descriptions, etc., prescribed by cabinet order as those of which the handling requires special care so as not to cause unfair discrimination, prejudice or other disadvantages to the principal.

Sensitive information:

Special care-required personal information, and information on participation in union activities, family origin, registered domicile, health care and sex life (excluding those that fall under the category of Special care-required information) (excluding the information disclosed by the principal, government institution, municipal government, or those prescribed in Article 76, Paragraph1, each item of the Act or Article 6 of the Enforcement Order, and the information that is externally apparent by visually observing or taking photographs of the principal when such information is acquired).

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