PEMS recognizes that all personal information managed and used in its business activities must be handled and protected with the utmost care. Therefore, PEMS will follow the basic policy stated below.

  1. PEMS will comply with the Act on the Protection of Personal Information and other relevant laws, regulations and guidelines set forth by Japanese governmental authorities or other applicable governmental authorities.
  2. PEMS will not acquire or use any personal information through false or other improper means.
  3. PEMS will use personal information only to the extent and for the purposes specified, which will be announced or noticed to the persons to whom the information pertains at or before the time of collection.
  4. PEMS will endeavor to keep such personal information accurate and up-to-date.
  5. PEMS will take necessary and appropriate measures to maintain the security of such personal information.
  6. PEMS will furnish its employees and contractors handling such personal information with the necessary and appropriate guidance and supervision.
  7. PEMS will not provide personal information to any unaffiliated third party without the consent of the person involved, other than (i) as required by applicable law, or (ii) to our service providers for legitimate business purposes.
  8. If PEMS receives an inquiry from a person about the use or content of personal information related to that person, it will provide a reasonable response.
  9. If PEMS receives any complaints regarding the handling of personal information, it will resolve such complaints in a timely and appropriate manner.
  10. PEMS will establish rules and management systems for proper handling and protection of personal information and will thoroughly adhere to them.
  11. PEMS will engage in a strong effort to further enhance personal information protection systems by regularly reviewing and updating all rules and procedures regarding the handling of personal information, including this policy.

For information regarding the business purposes, the practical handling method of personal information by PEMS, refer to the following:

1. Use of Personal Information

PEMS will acquire and use personal information only as needed or helpful for its business performance according to its business purposes. (See “7. Activities of PEMS”.) The business purposes of personal information are:

  1. To make applications for transactions between PEMS and its customers and other parties concerned with its businesses; obtain confirmation regarding customers and other parties concerned; review and assess such transactions; execute and manage agreements; and conduct termination and other proceedings following termination of agreements with customers and contractors.
  2. To issue notices regarding improvement of PEMS products and services and of associated products and services, and respond to customer inquiries regarding such products and services.
  3. To respond to inquiries about the products and services provided by parties having business relations with PEMS.
  4. To confirm applications for and participation in various exhibitions and seminars, communicate with lecturers, and report on the results of studies and events to the persons involved, and also to provide visitors with access to PEMS’s facilities
  5. To make contact with the members of any organizations in which PEMS is a member, and issue various notices from PEMS according to the purposes of activity of such organizations
  6. To send publications issued by PEMS to persons who request them, and to distribute e-mails to the applicants for the PEMS electronic mailing service.
  7. To communicate with journalists and analysts in publicity activities
  8. To receive applications for employment, communicate with and issue the notification of employment to the applicants, and other issues concerning recruitment activities.
  9. To communicate and conduct transactions with public accountants, attorneys and patent attorneys concerned with the business activities of PEMS.
  10. To communicate with the officers, directors, employees or any related persons in the subsidiaries and affiliates of PEMS in the course of performance of business activities other than those as stated above.
  11. To issue notices to PEMS’s retired employees and to communicate with the families of PEMS’s employees.
  12. To exchange necessary information between PEMS and its cooperative, non-regular, temporary, part-time and student workers in execution of contracts with them and performance of their works.
  13. To receive personal information provided for any order-based works and to complete such works within PEMS’s scope of business.
  14. To personalize or improve PEMS’s website experience and to deliver content relevant to the interests of our website visitors, including targeted advertising through our website or third-party websites.
  15. To fulfill the reason the information was provided to PEMS.
  16. To conduct business activities incidental or related to the above business purposes.

PEMS may provide personal information to a third party with the approval of each respective individual, consign the handling of personal information to a third party, or share personal information with subsidiaries and/or affiliates of PEMS to the extent that such personal information is required for a business purpose as stated above.

(Please see the following “4. Provision of Personal Information to Third Parties” and “5. Joint Use of Personal Information”.

If any personal information is acquired or used for any other business purposes than those described above, a notice or announcement will be issued separately.

2. Possession of Personal Information

PEMS possesses and will possess personal information including, without limitation, names, addresses, telephone numbers, FAX numbers, e-mail addresses, gender, ages, memberships, departments and titles of its customers, suppliers and other related companies.

PEMS does not acquire and possess any personal information that is not intended for the business purposes listed above. (See “1. Use of Personal Information”.)

3. Personal Information Management

PEMS will take necessary and appropriate measures to ensure the security of the personal information possessed by it and endeavor to maintain the contents of such personal information are accurate and up-to-date to the extent necessary for business purposes.

Personal information which is no longer necessary for business purposes will be disposed of in an appropriate manner.

PEMS takes the following main security control measures:

  1. Formulation of a basic policy
    • To ensure proper handling of personal data, PEMS formulates a basic policy regarding compliance with related laws, regulations, guidelines, etc., a contact point for handling questions and complaints, and other matters
  2. Establishment of rules regarding the handling of personal data
    • PEMS formulates personal information protection rules that stipulate the responsible persons of the company and each department including their duties, as well as the way to handle personal data for each stage, including acquisition, use, management, provision and responding to requests from the concerned individual.
  3. Organizational security control measures
    • PEMS appoints the person and department responsible for protecting personal information for the company and assign a responsible person in each department to monitor employees, and maintains an organization for reporting to and notifying the responsible person in case of a violation or suspected violation of laws or the personal information protection rules.
    • In cases where all or part of the handling of personal data is entrusted to a subcontractor, PEMS selects the subcontractor in accordance with the personal information protection rules and concludes
  4. Personnel-based security control measures
    • PEMS incorporates personal information protection into company-wide periodic training, and appropriately conducts training in accordance with the needs of each department
    • PEMS obtains confidentiality pledge covering personal information and stipulates in the employment rules that improper handling of personal information results in disciplinary action
  5. Physical security control measures
    • PEMS establishes security measures and controls the entry and exit of persons for each factory, building, department and area, and implements measures for preventing unauthorized or unrelated persons from viewing or handling personal data
    • PEMS implements measures for preventing the theft, loss of devices, electronic media, paper-based documents, etc. that contain personal data
  6. Understanding of the external environment
    • In cases of handling personal data in a country outside Vietnam, PEMS confirms the legal systems regarding the protection of personal information in that country and implements security control measures

4. Provision of Personal Information to Third Parties

PEMS will not provide the personal information of any person to any unaffiliated third party without such person's approval, except in the following cases:

  1. With respect to the provision of personal information (excluding special care-required personal information, improperly acquired personal information and personal information provided by a personal information handling business operator) to third parties, the matters stipulated for the provision of personal information in the Personal Information Protection Act are noticed or easily known to such person and also reported to The Personal Information Protection Commission, provided that the provision of the personal information will be suspended upon the individual’s request;
  2. The work of handling personal information is entrusted, in whole or in part, to any third party to the extent necessary for PEMS’s business purposes.
  3. Provided, that an agreement protecting the confidentiality of personal information shall be entered into by and between PEMS and such entrusted company and that PEMS will provide necessary and appropriate supervision of such entrusted company;
  4. PEMS will share the personal information of any specific person with one or more of its subsidiaries and/or affiliates to the extent necessary for business purposes (see “5. Joint Use of Personal Information”); and
  5. Such disclosure of personal information to any third party is otherwise authorized or required under any applicable law or regulation

5. Joint Use of Personal Information

PEMS may share the personal information acquired by PEMS with one or more of its subsidiaries and/or affiliates for the above business purposes (see “1. Use of Personal Information”), provided PEMS shall remain responsible for the security of the same. Such personal information may include, without limitation, the names of customers and other parties concerned with PEMS's businesses and their work or home addresses, telephone numbers, fax numbers, e-mail addresses, genders, ages, associated organizations and departments and professional titles.

6. Contact for Personal Information

For information regarding the specific business purposes, the disclosure, correction and suspension of use of the contents of personal information (hereinafter "inquiries about personal information"), contact the respective departments of PEMS to which such personal information was provided. (To make inquiries about personal information, it is necessary to submit a completed request form including a valid form of identification. Request forms will be sent from PEMS on request.)

In the event the department to which the personal information was provided is unknown, or for any inquiry for general information on the process of handling personal information, contact: