HOYA Corporation Basic Policies for the Protection of Personal Information
1. Approach to the protection of personal information
HOYA Corporation collects and uses customer names, addresses, telephone numbers, email addresses and other information for the seamless promotion of its business operations. We are aware that the appropriate protection of the personal information of our customers as well as that of company officers, employees, contract staff and other employees (“personal information”) is a serious responsibility of the company and, in order to fulfill that responsibility, we handle personal information appropriately and safely based on these policies.
In addition to these Hoya Corporation Basic Policies for the Protection of Personal Information Hoya strives to comply with the high standards of data protection in the European Union. For information on the Protection of Personal Information in Germany:
(1) We shall comply with the Law on the Protection of Personal Information and other related laws and ordinances. We shall also ensure our adherence to practices regarding the handling of personal information generally deemed to be fair and appropriate and handle that information appropriately. We shall furthermore strive to realize sustained and appropriate improvements in order to continue handling such information in an appropriate and pertinent manner.
(2) We shall clarify rules regarding the handling of personal information and strive to thoroughly familiarize the employees with them. In addition, we shall also require subcontractors and other business partners to handle personal information in an appropriate manner.
(3) When collecting personal information, we shall specify and notify or release the purpose of use such as indicated in item 2 below and handle personal information in accordance with the purpose of use.
(4) We shall devise necessary measures and implement appropriate management in order to prevent the divulgence, loss, alteration, etc., of personal information.
(5) We shall not provide collected personal information to any third party except in the following cases.
• If the consent of the individual in question is obtained in advance
• If such provision is authorized by the Law on the Protection of Personal Information or other laws and ordinances
(6) The disclosure, revision, discontinuation of usage, etc., of personal information shall be accepted by the department that maintains the personal information or that provides service. Upon receipt of a request for disclosure, a fee in the amount of $430 shall be charged as the actual cost of delivery (recorded delivery). In addition, inquiries shall in principle be limited to those received from the individual in question. The company shall make an appropriate response only when it is possible for the company to confirm that the contacting party is the individual in question (including proxies) in order to prevent alteration of personal information by a third party.
2. Purpose of use, etc.
The company shall acquire personal information required for the performance of business with the aim of facilitating company operations and such personal information shall be used for the purposes given below. In addition, in order to promote seamless business operations, personal information may be provided to subcontractors to the extent required. In such event, the company shall enter into contracts with such subcontractors regarding the handling of personal information and appropriately monitor them.
(1) For the purpose of providing services in response to requests from customers and engaging in related or incidental conduct (e.g., provision of support to customers relating to the services that are provided)
(2) For the purpose of introducing customers to the company’s products or services
(3) For the purpose of requesting the provision of opinions or impressions of customers regarding the HOYA Group (including opinions and impressions of products and services)
(4) For the purpose of preparing classified statistical materials with the aim of contributing to future improvements in services
(5) For the purpose of providing personal information in response to the demands of courts of law, law and ordinances, etc.
(6) For other purposes specified by the company upon the receipt of information from customers
The company shall not use personal information other than for the purposes indicated above without the consent of the customer in question.
Effective date: April 1, 2005
President and CEO