Privacy Policy

With customer trust as the foundation of our corporate philosophy and all our activities, we aim to be a company that contributes to the development of society through providing our customers with a sense of security and safety. Guided by this philosophy and as a Data Controller, we comply with the Act on the Protection of Personal Information (the "Privacy Act"), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the "My Number Act") and other relevant laws and ordinances, the Personal Information Protection Guidelines in the Financial Sector and other relevant guidelines, the Personal Information Protection Guidelines of Non-Life Insurance Companies, issued by the General Insurance Association of Japan, and Tokio Marine Group Privacy Policy in handling personal information as well as individual numbers and specific personal information (hereinafter referred to as "Specific Personal Information, etc.") in a proper manner as described below. Tokio Marine & Nichido Fire Insurance Co., Ltd. ("the Company") takes appropriate measures to ensure that personal information and Specific Personal Information, etc. are secure and make every effort to train insurance agents and employees in the proper handling of information. The Company also performs reviews as needed in order to improve itself in this respect based on the contents outlined below.

• *
  "Personal information" and "personal data" provided in this Privacy Policy exclude Specific Personal Information, etc.

(Please see Clause 9 “Handling of Specific Personal Information, etc.” below with respect to Specific Personal Information, etc.)
The Company collects personal information in a lawful and appropriate manner to the extent necessary in conducting business.

• (1)
  Acquisition from the Individual
  The Company acquires personal information through applications for insurance policies, written claims for insurance benefits, transaction documents, the provision of ancillary services, and surveys, etc.
  Furthermore, in order to accurately record the content of various notifications, inquiries, consultations, etc., the Company may collect personal information by recording telephone conversations, etc.
• (2)
  Acquisition from Third Parties
  The Company may acquire personal information from Tokio Marine Group companies, subcontractors, business partners, and other third parties or based on information that is publicly disclosed. The following are specific examples of personal information that the Company acquires from third parties.

  • Examples of sources: Ippan Shadan Hojin Minji Houmu Kyoukai, Zenrin Co., Ltd.
  • Examples of items of personal information that are acquired: Information on the structure of a building stated in the certificate of registered matters, etc., housing maps, etc.

  If the Company acquires personal data from a third party, we will confirm and record matters concerning that acquisition (such as what type of source it was acquired from, what type of personal data was acquired, and how the third-party source acquired the relevant data).

(Please see Clause 9 “Handling of Specific Personal Information, etc.” below with respect to Specific Personal Information, etc.)
The Company uses personal information only to the extent necessary for the purposes listed below and for the purposes described in Clause 5 “Joint Use with the Company's Group Companies and Business Partners” and Clause 6 “Information Exchange System” (hereinafter, "Purpose of Use").

• (i)
  Explanation, solicitation, and sale of non-life insurance products, life insurance products, investment trusts and other financial products handled by the Company and other products and services handled by the Company (hereinafter, collectively, “the Company’s Products and Services”), and explanation, provision and management of services ancillary or related thereto
• (ii)
  Examination into the appropriate underwriting of the offer of insurance policies
• (iii)
  Performance, maintenance, and renewal of the Company’s Products and Services and services ancillary thereto
• (iv)
  Notification, claiming, and refunding of insurance premiums
• (v)
  Handling of the receipt of and consultation on insured events, provision of information pertaining to various professional business operators concerning events, intermediation, placement, and introduction of various professional business operators, and investigation of damage and the cause of events pertaining to insured events
• (vi)
  Investigation, analysis, and advice in order to prevent or reduce the occurrence of insured events and other risks
• (vii)
  Payment of appropriate insurance benefits and refunds, investigation of insured events pertaining to insurance claims, and investigation of payment grounds for insurance benefits, etc. (including inquires and cooperation with related parties)
• (viii)
  Prevention and elimination of false claims for insurance benefits, etc. and other inappropriate incidents
• (ix)
  Execution of reinsurance policies with domestic and foreign reinsurance companies, and notifications and claims for reinsurance benefits based on reinsurance policies
• (x)
  New establishment and maintenance of sales channels (agents, etc.)
• (xi)
  Consulting and management of the defined contribution pension plan business of the Company
• (xii)
  Consulting business pertaining to life planning and asset accumulation for individuals
• (xiii)
  Examination of loans, and contracting, performing and managing loans
• (xiv)
  Managing of receivables and obligations held by the Company and the collection of receivables
• (xv)
  Explanations of events, campaigns and seminars, and provision of information
• (xvi)
  Making inquiries about products, services provided by the Company or its agents
• (xvii)
  Research and development of new products and services through market research, data analysis that includes gathering information on individual customers and comparing that information, and questionnaires, and quality improvement of the Company’s Products and Services that already exist
• (xviii)
  Analysis of information such as customers’ browsing histories, purchase histories, and attributes, in order to advertise Company’s Products and Services according to customers’ interests, and recommendations and introductions of insurance solicitors who meet customers’ needs
• (xix)
  Explanation of non-life insurance, life insurance, consulting, and other products and services handled by Tokio Marine Group companies and business partners, etc.
• (xx)
  Advertising of products and services handled by Tokio Marine Group companies and business partners, etc. according to customers’ interests based on analyses of customers’ browsing histories and purchase histories, etc.
• (xxi)
  Conservation of information systems, information assets, and business-use property, and security management of the Company’s facilities
• (xxii)
  Meetings, testing and other screening procedures pertaining to the hiring of the Company’s employees, communication of the results of screening, and procedures at the time of hiring
• (xxiii)
  Performance of contracted services if the processing of personal information was contracted by other business providers
• (xiv)
  Research, development of new products and services, and quality improvement of the Company’s Products and Services that already exist that is carried out jointly with other business providers or research institutions, etc. (including cases of data analysis that includes gathering information on individual customers and comparing that information)
• (xxv)
  Risk analysis using insurance policy information and event information, etc. concerning customers, and proposal of the Company’s Products and Services that are appropriate in accordance with customers’ risks based on forecasts
• (xxvi)
  Response to inquiries and requests, etc., and provision of information concerning the Company’s business and the Company’s Products and Services
• (xxvii)
  Improvement of business contents and procedures concerning (i) through (xxvi) above
• (xxviii)
  The performance of other businesses related to (i) to (xvii) above, the ascertainment and management of various risks, the execution of business in order to smoothly and appropriately perform client transactions and the operation of the Company, and administrative management and shared or overlapping business of Tokio Marine Group companies through a holding company

The Purpose of Use is declared on its website and published within application forms and brochures. If the Company makes any changes to the Purpose of Use, the Company will issue appropriate notices regarding such changes or make a public announcement of such changes on its website.

The Company will obtain your consent, except in the cases laid out in Paragraph 3 of Article 18 of the Privacy Act, if it handles personal information beyond the defined necessary extent.

(Please see Clause 9 “Handling of Specific Personal Information, etc.” below with respect to Specific Personal Information, etc. The Company may also provide personal data to third parties in foreign countries. Please click here for details.)

• (1)
  The Company will not provide personal data to any third parties without prior consent except in the following cases.

  • If provision is permitted under laws or ordinances
  • If there is a need to protect the life, body, or property of an individual and it is difficult to obtain your consent
  • If there is a special need to enhance public hygiene or promote the fostering of healthy children, and it is difficult to obtain your consent
  • If there is need to cooperate with a national government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and there is a possibility that obtaining your consent would interfere with the performance of those affairs
  • If the relevant third party is an academic research institution, etc., and that third party has a need to handle the relevant personal data for the purpose of academic research (including the case in which part of the purpose of handling that personal data is the purpose of academic research; excluding cases that risk unjustifiably infringing on the rights and interests of individuals)
  • If providing personal data to outsourcees, including insurance agents, to the necessary extent required in order to do business (please see Clause 4 “Outsourcing the Handling of Personal Data and Specific Personal Information, etc.” below)
  • If personal data is provided in conjunction with the succession of a business due to merger or other grounds
  • If personal data is used jointly with the Company's group companies or business partners (Please see Clause 5 "Joint Use with the Company's Group Companies and Business Partners" );
  • If personal data is used jointly with other non-life insurance companies (Please see Clause 6 " Information Exchange System" below)
  • If personal data is used jointly with The Ministry of Land, Infrastructure and Transport (Please see Clause 6 " Information Exchange System" below)
• (2)
  Unless otherwise prescribed by law, rule or regulation, the Company, when providing personal data or individual-related information to a third party (the provision to a third party of individual-related information is the case in which it is anticipated that the recipient will acquire it as personal data), shall record matters concerning the provision (what type of personal data was provided and to whom, etc.).
• (3)
  The Company may use individual-related information received from third parties as personal information by, for example, linking it with other information possessed by the Company. In such cases, the Company will take appropriate measures in accordance with the Privacy Act and related guidelines, such as obtaining your consent.

The Company may outsource the handling of personal data and Specific Personal Information, etc. to the extent necessary for achieving the purpose of its utilization. Whenever the Company outsources the handling of personal data and Specific Personal Information, etc., it exercises the necessary and appropriate oversight of outsourcees, such as appropriately selecting outsourcees after setting criteria for their selection, executing outsourcing agreements, and checking their information management systems, including the status of the handling of personal information at the outsourcees.
For instance, the Company outsources the handling of personal data related to the following operations:
(Item (iv) below includes Specific Personal Information, etc.)

• (i)
  Operations relating to the solicitation of insurance contracts
• (ii)
  The payment of insurance benefits and other damage service operations
• (iii)
  Operations relating to the maintenance and operation of information systems
• (iv)
  Operations relating to the preparation and submission of payment records, etc.
• (v)
  Operations relating to the provision of ancillary services for insurance policies

(There is no joint use of Specific Personal Information, etc.)
The Company, Tokio Marine Group companies and their business partners may jointly use the following personal data.

• (1)
  Purpose of Use
  The same as the Purpose of Use set forth in (i) through (xxviii) of Clause 2.
• (2)
  Personal Data:

  • Address
  • Name
  • Telephone number
  • E-mail address
  • Sex
  • Date of birth
  • Any other policy details described in application forms and the details of events and statements of payment of insurance benefits
  • Details recorded on dashcams
  • Data related to properties subject to insurance such as structure, use status, topography, weather, and disasters
  • Location information
  • Purchase history
  • Website browsing history
  • Vital data
  • Data such as physical examination results, itemized statements of medical expenses, treatments, and medications
  • Work history and qualifications held, etc.
  • Data related to economic condition, household finances, and asset management
• (3)
  Business operators, etc. that jointly use personal data

  • Group companies
    Please click here for group companies of Tokio Marine Holdings.
    Please click here for group companies of Tokio Marine & Nichido Fire Insurance.
    Please click here (Japanese) for group companies of Nisshin Fire & Marine Insurance.
    Please click here (Japanese) for group companies of Tokio Marine & Nichido Life Insurance.
    Please click here (Japanese) for group companies of Tokio Marine & Nichido Facilities.
  • Business partners
    The Company does not jointly use personal data with any business partners.
• (4)
  Person responsible
  Tokio Marine & Nichido Fire Insurance Co., Ltd. (Please see the Company Information page on our website for our address and the name of our representative, etc.)

  • *
    The preceding details do not cover the personal information, Specific Personal Information, etc., anonymously processed information, and pseudonymously processed information of persons engaged in the Company’s operations. The Company also does not jointly use Specific Personal Information, etc.

(The information exchange system does not cover Specific Personal Information, etc.)

• (1)
  Upon finalizing insurance policies or filing insurance claims, the Company will share personal data with non-life insurance companies and other entities to eliminate misconduct. For details, please visit the website of The General Insurance Association of Japan.
• (2)
  The Company will share personal data with the Non-Life Insurance Rating Organization of Japan in order to appropriately pay insurance benefits for compulsory automobile liability insurance. For details, please visit the website of the General Insurance Rating Organization of Japan.
• (3)
  In order to consign and supervise non-life insurance agents and to recruit its new employees, the Company will make shared use of personal data of employees of non-life insurance agents and other entities, and of persons who have passed a non-life insurance agents examination or other tests conducted by the General Insurance Association of Japan with other non-life insurance companies in the following five systems (For details, please visit the website of the General Insurance Association of Japan):.

  • (i)
    Special Trainees Information System
  • (ii)
    Now-defunct Agents Information System (Designed to cover personal data acquired by the end of June 2013)
  • (iii)
    Handling of information, etc. on persons who have passed the non-life insurance agents examinations
  • (iv)
    Handling of personal information in electronic applications, etc. for registration/notification of non-life insurance agents
  • (v)
    Handling of information registered on the Insurance Solicitors Qualification Information System
    In addition, the Company will, in the Now-defunct Agents Information System and the Discontinued Insurance Solicitors Information Registration System, make shared use of personal data on insurance solicitors with non-life and life insurance companies and other entities in order to use such information as a reference, etc. for making a judgment on the eligibility and quality of insurance solicitors (Designed to cover personal data acquired on or after July 1, 2013).
• (4)
  In order to check on scooters or small motorcycles without compulsory automobile liability, insurance the Ministry of Land, Infrastructure and Transport sends postcards to confirm if a policyholder owning a scooter (not more than 125cc) or small motorcycles (more than 125cc and not more than 250cc) has compulsory automobile liability insurance in which the contract term is deemed to have expired. The Company will provide to the Ministry, personal data regarding compulsory automobile liability insurance for the above types of vehicles, and share such personal data with the Ministry at their discretion.
  For details, please visit the website of the Ministry of Land, Infrastructure and Transport.

The Purpose of Use of personal information provided by any credit information organization (which means any organization that collects information regarding your ability to meet your debt payments and provides such information to the Company) is limited to its investigation of your ability to meet your payments in accordance with Article 53-9 of the Enforcement Regulations of the Insurance Business Law.
The Company will not use such credit information for any purpose other than investigating your ability to meet your payments.

The Company will not collect, use, or provide to any third parties personal information requiring special care and information concerning membership of labor unions, family, domicile of origin, health condition or medical treatment, or sexual orientation (except for information released by the individual himself/herself, government agency, local government, academic research institution, etc., or any party provided in each of the items in paragraph 1 of Article 57 of the Privacy Act or in each of the items in Article 6 of the Ordinance for Enforcement of the Privacy Act, or information which is collected through visual observation or by taking a photograph of the individual and hence the external appearance is evident) except for cases provided by the Privacy Act, other relevant laws, ordinances and guidelines.

The Purpose of Use of Specific Personal Information, etc. is limited under the My Number Act, and the Company will not collect or use Specific Personal Information, etc. beyond the prescribed Purpose of Use.
The Company will not provide Specific Personal Information, etc. to any third parties except in cases permitted under the My Number Act.

Please direct inquiries regarding details of insurance policies and payment of insurance benefits to the office or agent listed on the insurance policy or the office or agent in your area. The Company will respond after confirming that you are the requesting party.

Please direct requests for any notice of matters, disclosure (including disclosure of third party-provided records), amendment, or suspension of use of personal data and Specific Personal Information, etc. held by the Company under the Privacy Act (“Disclosure, etc. Requests”) to the address listed in Clause 14 “Contact Office” below.
After confirming that you are the requesting party, the Company will ask that you to complete a form and will then provide a response. There will be a fee charged for this service.
Please click here for details of Disclosure, etc. Requests.

The Company takes security management measures for personal data and Specific Personal Information, etc. to prevent divulgence, loss or damage to retained personal data and Specific Personal Information, etc. Please click here for the details of specific security management measures.

The Company appropriately handles pseudonymously processed information and anonymously processed information. Please click here for details of the handling of pseudonymously processed information and anonymously processed information.

The Company will appropriately and promptly respond to any complaints or consultations regarding the handling of personal information, Specific Personal Information, etc., pseudonymously processed information (excluding any that is personal information), and anonymously processed information.
If you have any questions regarding the handling of personal information, Specific Personal Information, etc., pseudonymously processed information (excluding any that is personal information), and anonymously processed information by the Company, suggestions for the secure management of personal data, Specific Personal Information, etc. and anonymously processed information or any other inquiries or consultations, please contact the office below.
Please also contact the office below if you do not desire explanations of new products and services via e-mail or direct mail, etc. from the Company. However, the office below does not handle communications regarding the maintenance or management of insurance policies or the payment of insurance benefits.

Contact Office

Tokio Marine & Nichido Fire Insurance Co., Ltd.
Customer Center
Tel 0120-065-095
(open from 9:00 to 17:00 excluding Saturdays, Sundays, holidays and the new year holiday periods.)

Please see the Company Information page on our website for our address and the name of our representative, etc.

The Company is a member of the General Insurance Association of Japan and Japan Consumer Credit Association, each of which is an authorized Private Information Handling Entity. Both organizations handle claims and consultations regarding the handling of personal information, Specific Personal Information, etc., pseudonymously processed information (excluding any that is personal information), and anonymously processed information by member companies.

Contact Offices

General Insurance Counseling and ADR Center
The General Insurance Association of Japan
Address: 7F Waterasu Annex, 2-10-5, Kanda Awajicho, Chiyoda-ku, Tokyo 101-0063
Tel: 03-3255-1470
(open from 9:00 to 17:00 excluding Saturdays, Sundays, holidays and the year-end and new-year periods.)
URL: https://www.sonpo.or.jp/en/

Japan Consumer Credit Association (regarding financial business)
Tel: 03-5645-3360
(open from 10:00 to 12:00 and from 13:00 to 16:00 excluding Saturdays, Sundays, holidays and the year-end and new-year periods.)
URL: https://www.j-credit.or.jp/en/

Revised on April 1, 2022