Privacy Policy for the Data Subject in EEA and the UK
NTT FINANCE will use its best efforts to protect personal data (any data relating to an natural person (the "Data Subject" or "you") in the European Economic Area and the UK ("the EEA and the UK"), complying with the applicable personal data protection laws and regulations in the EEA and the UK (including the EU General Data Protection Regulation and Data Protection Act 2018), related guidelines and other applicable laws and regulations. NTT FINANCE will process your personal data according to this Privacy Policy.
1. Personal Data Obtained from the Data Subject
To the extent necessary for the purpose designated in Article 2, NTT FINANCE will obtain the personal data such as your name, nationality, position, address, telephone number, e-mail address, Internet Protocol (IP) addresses, browser information, website activities, cookies information or information that you provide us with for recruitment.
We may obtain personal data of individuals of our business partners from other individuals of business partners.
If you do not provide your personal data which is necessary to provide our services selected by you, it is possible that we can not start or continue to provide our services.
2. Purposes of use of the personal data
NTT FINANCE will process your personal data when applicable laws in Japan permit or for the purposes detailed below:
- (a) Financing, credit card services and other businesses listed in NTT FINANCE's articles of incorporation;
- (b) To communicate with you about our products, services and contracts and to inform you of matters that are important for you;
- (c) To respond to your inquiries or requests;
- (d) For credit assessment and credit management, contract management, and to facilitate proper and smooth transactions with you;
- (e) To collect information for the purpose of market research, service development and service improvement;
- (f) To inform you about the services of our business partners;
- (g) For proof of identity based on laws or regulations related to preventing the illegal transfer of earnings;
- (h) To provide information to or contact job applicants; or
- (i) Processes related to the items above.
If NTT FINANCE processes your personal data for purposes other than the items above, NTT FINANCE will notify you in advance of the new purposes for which the information will be used and other matters as required by applicable laws and obtain your consent.
3. Legal basis for processing
We will process your personal data on the following legal bases.
- (a) Contract. This is where we need to process your personal data to perform the contract we enter into with you.
- (b) Legitimate Interests. This is where the processing of your personal data is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
- (c) Consent. This is where you have given consent for us to process your personal data.
- (d) Legal obligation. This is where we need to compliance with a legal obligation to which we are subject.
- (e) Protection of the vital interests. This is where the processing is necessary in order to protect the vital interests of you or of another natural person.
4. Disclosure of Personal Data
NTT FINANCE will disclose your personal data to the following categories of recipient.
- (a) Our affiliated company, subsidiaries, business partners, agent or service provider (including Internet Service Provider, Cloud Service Provider, IT Service Providers etc.);
- (b) Lawyers, accountants, tax accountants, financial institutions, insurance companies, and consultants who provide an advice of management, operation management or other professional knowledge;
5. Transfer Personal Data Outside the EEA and the UK
NTT FINANCE will transfer your personal data outside of the EEA and the UK. In such case, NTT FINANCE will ensure that:
- (a) the recipient destination has been subject to a finding from the European Commission that it ensures an adequate level of protection for the rights and freedoms that you possess in respect of your personal data; or
- (b) the recipient enters into standard data protection clauses with us that have been approved by the European Commission.
You can obtain more details of the protection given to your personal data when it is transferred outside the EEA and the UK by contacting us in accordance with the information indicated below in Article 10.
6. Privacy protection
NTT FINANCE implements necessary and appropriate organizational and technical security measures to protect unauthorized disclosure, loss, and unlawful destruction of your personal data. NTT FINANCE conducts employee training to raise awareness about privacy protection, implementing relevant procedures and systems and regular auditing, and uses its best efforts to comply with these policies.
7. Retention period of personal data
NTT FINANCE stores personal data for the time required to carry out the purpose indicated above in Article 2, or for the time specified by laws and regulations. When your personal data is no longer needed, NTT FINANCE will promptly take measures to delete or anonymize it in a safe way.
8. Your Rights
You have the following rights regarding personal data collected and processed by NTT FINANCE.
-
(a)
Access to personal data
the right to obtain access to the personal data which we hold about you -
(b)
Rectification of personal data
the right to request that we rectify your personal data if it is inaccurate or incomplete -
(c)
Erasure of personal data
the right to request that we erase your personal data in certain circumstances -
(d)
Restriction on processing of personal data
the right to request that we restrict our processing of your personal data in certain circumstances -
(e)
Data portability of personal data
the right to receive any personal data which we process about you on the basis of the performance of a contract with you or your consent (as opposed to any other legal ground) in a structured, commonly used and machine-readable format and/or request that we transmit that data to a recipient where this is technically feasible -
(f)
Object to processing of personal data
the right to object to us about our processing of your personal data -
(g)
Withdraw consent to our processing of your personal data
the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we can rely on another legal ground for doing so -
(h)
Lodge a complaint with the data protection authority
the right to lodge a complaint with the data protection authority if you think that any of your rights have been infringed by us
9. Updates to Privacy Policy
NTT FINANCE may revise or update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on this Website. If NTT FINANCE makes changes which we consider to be significant, we will inform you through the Website to the extent possible and seek your consent where applicable.
10. Inquiries
For any questions or requests relating to this Privacy Policy, or if you wish to exercise the rights mentioned in this Privacy Policy, please contact NTT FINANCE using the contact details below.
Contact: The privacy help desk (in the Legal Dept.) of NTT FINANCE
E-mail address: nf-gdpr@ntt-finance.com
Address: Shinagawa Season Terrace 14F, 1-2-70 Konan, Minato-ku, Tokyo 108-0075, Japan