PRIVACY POLICY
"TENLION Co., Ltd. (the “Company”) recognizes the importance of the personal information it obtains and, in handling such information, complies with the Act on the Protection of Personal Information of Japan (the “APPI”), guidelines established by the Personal Information Protection Commission of Japan, and other applicable laws, regulations, guidelines, and standards concerning the protection of personal information. The Company handles personal information appropriately as set forth below.
1.Scope and Definitions
This Policy applies to personal information, personal data, retained personal data, and other information concerning individuals handled by the Company.
Unless otherwise provided in this Policy, the meanings of “personal information,” “personal data,” “retained personal data,” “person-related information,” and other terms relating to the handling of personal information shall be as defined in the APPI and other applicable laws and regulations.
2.Security Control of Personal Information
The Company takes organizational, personnel, physical, and technical security control measures to prevent leakage, loss, damage, unauthorized access, unauthorized use, and other improper handling of personal information, and endeavors to manage personal information appropriately.
The Company also provides necessary and appropriate education and supervision to its officers, employees, and other personnel who handle personal information. When the Company entrusts the handling of personal information to an external contractor, it selects the contractor appropriately and exercises necessary and appropriate supervision over such contractor.
3.Matters to Be Observed in the Acquisition and Other Handling of Personal Information
The Company observes the following matters in acquiring, using, and providing personal information.
(1)Acquisition of Personal Information
he Company may acquire personal information to the extent necessary for the performance of its business through websites managed and operated by the Company (the “Website”), inquiry forms, email, telephone, various application forms, contract procedures, transactions involving products and services, seminars and training programs, events, human resources-related services, and other business activities of the Company.
Personal information acquired by the Company may include the following information:
- Name
- Medical institution name, corporate name, company name, or other affiliation
- Department, title, and occupation
- Address
- Telephone number
- Email address
- Other contact information
- Details of inquiries, consultations, requests, and other communications
- Information necessary for orders, quotations, contracts, delivery, billing, payment, and other transactions relating to products and services
- Information concerning applications for and participation in seminars, technical training, workshops, academic conferences, events, and similar programs
- Background, qualifications, work history, and other information provided in connection with the use of recruitment, placement, or other human resources-related services
- Information contained in documents, images, and other files attached or submitted through the Website or other forms; and
- Other information necessary for the provision of the Company’s services or the performance of its business.
The Company does not acquire personal information by deception or other improper means.
If the Company acquires sensitive personal information, such as medical history or medical treatment information, it will handle such information appropriately in accordance with the APPI and other applicable laws and regulations, including, except where permitted by law, obtaining the prior consent of the individual concerned.
(2)Purposes of Use of Personal Information
Except where permitted by law or with the consent of the individual concerned, the Company does not use acquired personal information beyond the scope necessary to achieve the following purposes
1. To respond to and handle inquiries, consultations, requests, and other communications made to the Company
2. To explain, provide materials concerning, and give information on cosmetic medicine-related products, medical-related products, and other products and services handled by the Company.
3. To carry out procedures necessary for transactions, including quotations, orders, contracts, procurement, importation, delivery, shipment, billing, and payment confirmation relating to products and services.
4. To provide post-installation support, usage guidance, and other responses concerning products and services.
5. To provide information on, accept applications for, operate, and communicate with participants regarding technical training, hands-on seminars, workshops, study meetings, academic conferences, events, and other programs conducted by or involving the Company for physicians and other healthcare professionals.
6. To provide necessary information concerning the Company’s products, services, seminars, events, and related matters according to the individual’s inquiries, transaction details, or relationship with the Company.
7. To provide recruitment, placement, and other human resources-related services, including consultation, registration, provision of job information, matching with employers, applications, screening, and related communications.
8. To communicate, negotiate, enter into contracts with, manage transactions with, and perform business with medical institutions, corporations, companies, physicians, healthcare professionals, manufacturers, sales agents, and other business partners that have transactions or collaborations with the Company.
9. To communicate and coordinate with domestic and overseas manufacturers, business partners, medical institutions, physicians, and other related parties as necessary for business alliances, product transactions, technical exchanges, and other business activities of the Company.
10. To improve the quality and operation of products and services provided by the Company, and to plan and develop new products and services.
11. To collect and analyze questionnaires, opinions, requests, and other feedback concerning the Company’s business and services.
12. To prevent, investigate, and respond to fraud, violations of rules, and other inappropriate conduct against the Company.
13. To respond to requests and requirements based on laws, regulations, administrative agencies, and other public authorities.
14. To conduct recruitment screening, communications, and post-hiring personnel management for applicants for employment with the Company and
15. To conduct operations incidental or related to any of the foregoing purposes.
(3)Inquiry Forms and Attached Files
Inquiry forms and other forms established by the Company on the Website may allow users to attach files depending on the details of their inquiries or other circumstances.
If documents, images, or other attached files contain personal information, the Company handles such information appropriately in accordance with this Policy.
Please refrain, to the extent possible, from sending or attaching personal information of third parties, medical treatment information, medical history, or other sensitive personal information that is not necessary for making an inquiry or using the Company’s services.
If it is unavoidable to provide personal information of a third party to the Company, the provider is responsible for taking appropriate measures in accordance with applicable laws and regulations, including obtaining the consent of the individual concerned where necessary.
（4）Provision and Other Handling of Personal Information
Except where based on laws and regulations or otherwise permitted under the APPI, the Company does not provide personal data to third parties without the consent of the individual concerned.
If the individual requests disclosure, correction, addition, deletion, suspension of use, erasure, suspension of provision to third parties, notification of the purpose of use, or other action with respect to personal information held by the Company, the Company will verify the identity of the requester and respond appropriately in accordance with the APPI and other applicable laws and regulations.
4.Changes to the Purposes of Use of Personal Information
The Company may change previously specified purposes of use of personal information to the extent reasonably recognized as related to the purposes of use before the change.
If the purposes of use are changed, the Company will notify the individual or publicly announce the changed purposes of use by posting them on the Website or by another appropriate method.
5.Provision of Personal Data to Third Parties and Entrustment of Handling
（1）Provision to Third Parties
Except in the following cases, the Company does not provide personal data to third parties without the prior consent of the individual concerned
1. Where based on laws and regulations.
2. Where necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of the individual concerned.
3. Where particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the individual concerned.
4. Where it is necessary to cooperate with a national government organ, local public entity, or a person entrusted by either of the foregoing in performing affairs prescribed by laws and regulations, and obtaining the consent of the individual concerned is likely to impede the performance of such affairs.
5. Where otherwise permitted under the APPI or other laws and regulations.
（2）Entrustment of Business Operations
The Company may entrust external business operators with delivery, system operation, data storage, payment processing, administrative processing, and other operations to the extent necessary to achieve the purposes of use, and may entrust the handling of personal data in connection therewith.
In such cases, the Company confirms the suitability of the entrusted contractors, takes necessary contractual and other measures, and exercises necessary and appropriate supervision to ensure that the entrusted personal data is properly managed.
6.Provision of Personal Data to Third Parties Located in Foreign Countries
The Company may conduct product transactions, business alliances, technical exchanges, seminars, training programs, and other business activities with overseas manufacturers, overseas medical institutions, overseas physicians and specialists, overseas offices, and other related parties outside Japan.
If, in connection with such operations, it becomes necessary to provide personal data to a third party located in a foreign country, the Company will take appropriate measures in accordance with the APPI and other applicable laws and regulations, including, where necessary, obtaining consent after providing the individual concerned with information required by law, such as information concerning the personal information protection system of the foreign country in which the recipient is located and measures taken by the third party to protect personal information.
When handling personal data in a foreign country, the Company will understand the personal information protection system and other external environment of such foreign country and take necessary and appropriate security control measures.
7.Improvement and Review of the Handling of Personal Information
The Company periodically or as necessary inspects its handling of personal information, management systems, and security control measures, and endeavors to continuously improve and review them in order to protect personal information appropriately.
8.Retention and Disposal of Personal Information
The Company retains acquired personal information appropriately for the period necessary to achieve the purposes of use or for the period required by laws and regulations.
When personal information is no longer necessary in light of the purposes of use, the Company endeavors to erase or dispose of such information by a method that makes restoration difficult or by another appropriate method, except where retention is required by laws, regulations, or business necessity.
9.Use of Cookies and Similar Technologies
The Website may use cookies and similar technologies to the extent necessary for proper display of the Website, provision of functions, improvement of convenience, and other operation of the Website.
Information acquired through cookies alone does not normally directly identify a specific individual by name or other identifiers. However, if such information can be readily collated with other information and thereby identify a specific individual, the Company handles such information appropriately as personal information in accordance with this Policy.
If the Company introduces access analysis services, advertising distribution services, or other external services in the future, and changes occur in the handling of personal information or person-related information, the Company will revise this Policy as necessary and publicly announce the details on the Website.
10.Disclosure and Other Procedures Concerning Retained Personal Data
Under the APPI, individuals may request notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to third parties, and other actions with respect to retained personal data held by the Company concerning themselves.
When the Company receives such a request, it will verify that the requester is the individual concerned or a legitimate representative and respond appropriately in accordance with laws and regulations.
The Company may be unable to respond to all or part of such requests where laws and regulations permit the Company not to make disclosure or take other requested action.
11.Changes to this Privacy Policy
The Company may change this Policy as necessary due to amendments to laws and regulations, changes in the Company’s business or services, changes in the method of handling personal information, or other reasons.
The revised Privacy Policy will be publicly announced by posting on the Website or by another method deemed appropriate by the Company, and will apply from the time of such public announcement. However, if a change requires the consent of the individual concerned under laws and regulations, the Company will obtain the necessary consent in accordance with such laws and regulations.
12.Complaints, Consultations, and Inquiries
For complaints, consultations, or inquiries concerning the Company’s handling of personal information, this Policy, or disclosure and other procedures concerning retained personal data, please contact the Company through the inquiry form on the Website or at the following contact point.
TENLION Co., Ltd.
Ebisu Garden Place Tower 18F, 4-20-3 Ebisu, Shibuya-ku, Tokyo 150-6018, Japan
Telephone: +81-3-5789-5141
Representative Director: Toru Nakamura
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Established: [2026/08/17]
Last revised: [Same as above]