TXP Medical Co. Ltd.(hereinafter ”TXP”) sets its Privacy Policy(hereinafter ”The Policy”)as set forth below on handling user information including the person’s personal information obtained in the course of services TXP offers( hereinafter ”The Services”).
1. Comply with laws and regulations
TXP will comply with the related laws and regulations including Private Information Protection Law and The Policy in handling user information including the person’s personal information collected, managed, utilized through the conduct of its business.
2. User information TXP collects and its collection method
In The Policy, ‘user information’ is defined as information TXP collects based on The Policy including, information concerning user’s identification, action histories on communication services and other information generated or accumulated in user’s devices such as smartphones or tablets. According to the collection methods, the user information TXP collects through The Services is classified as listed below.
(1) Information user provides
Information user provides to use The Service are shown below;
*Full Name
*Mail Address
*Other information user inputs to fill input forms TXP sets
(2) Information TXP collects through registered user’s utilization of The Service
TXP may collect information concerning access or utilization status including information shown below.
*terminal information
*log information
*Cookie and anonymous ID
(3) This website uses Google LLC’s ”Google Analytics'' to analyze website access information. Although Google Analytics may collect user information such as action history in this website when visiting the site, using Cookie which records data for a temporary period of time, the data does not include identifiable information of specific individuals. The collected information will be managed according to TXP’s or Google LLC’s privacy policy. You can set Google Analytics disabled by applying “Google Analytics opt-out browser add-on” provided by Google LLC. You can also disable Cookie by changing your browser settings. Regarding above, please refer to Terms and Service of Google LLC.
3. Utilization Purposes
3-1 TXP utilizes collected user information for the purposes listed below;
(1) To provide, maintain, protect and improve The Service (e.g. registration acceptance, identification)
(2) To communicate with user (e.g. sending notification concerning The Service, response to inquiries)
(3) To respond to violations of TXP’s terms of services, policies and others regarding The Service(hereinafter”Terms”)
(4) To notify information such as change of Terms
(5) To conduct TXP’s operations smoothly
(6) To create anonymized statistic data concerning TXP’s services
(7) To deliver or display advertisements of TXP or third parties
(8) To conduct TXP’s recruiting activities
(9) To utilize for other types of marketing activities
(10) To utilize for purposes in conjunction with above mentioned ones
3-2 Should TXP handles user information
beyond necessary range to achieve the purposes specified in the above provision, TXP will obtain the consent of the person in advance.
3-3 Notwithstanding prior 2 provisions, TXP may utilize user information beyond necessary range to achieve the purposes in the cases listed below;
(1) required by laws and ordinances
(2) necessary to protect people’s lives, bodies and properties and difficult to obtain consent of the person
(3) Extremely necessary to improve public health or promote children’s healthy development and difficult to obtain consent of the person
(4) Necessary to collaborate with government organizations , local governments or organizations entrusted by them for executing their businesses based on laws and ordinances, and such execution might be influenced by obtaining consents of the person
3-4 TXP may change the utilization purpose within the range reasonably acceptable that it has considerable relevance. In such cases, TXP will reflect the amended purpose(s) in updated The Policy unless otherwise provided for by laws and ordinances
4. Appropriate acquirement
4-1 TXP will acquire user information legally and properly and will not acquire it by deception or other wrongful means
4-2 TXP will not obtain special care-required personal information without prior consent unless otherwise provided for by laws and ordinances
4-3 Personal information TXP obtains will be limited to be necessary and minimal to achieve the utilization purposes. Personal information collected through questionnaire or other measures also will be limited to be minimal to produce aggregate results
5. Provision to third parties
TXP will not provide personal information of user information to third parties without prior consent of user, except when disclosure is permitted based on the Personal Information Protection Act or other laws, regulations and guidelines. However, this will not apply in the cases listed below;
(1) TXP entrusts all or part of personal information handling, within range to achieve its utilization purposes
(2) Provide personal information accompanying business succession due to merger or other reasons
(3) Necessary to collaborate with government organizations , local governments or organizations entrusted by them for executing their businesses based on laws and ordinances, and such execution might be influenced by obtaining consents of the person
(4) Other cases disclosure is permitted based on Personal Information Protection Act or other laws, regulations and guidelines
6. Disclosure of personal information
When user requests to disclose personal information based on provisions of the Personal Information Protection Act, TXP will disclose such information promptly after confirming such request is placed by user himself/herself (when such information does not exist, TXP will notify the fact). Provided that, when TXP has no obligation to do that based on Personal Information Protection Act or other laws, regulations and guidelines, this provision will not apply. Please note that commission for disclosing personal information will be charged.
7. Securement accuracy of personal information contents and disposal
TXP will endeavor to maintain personal information contents in an accurate and up to date manner within the scope necessary to fulfill the utilization purposes, and dispose relevant information without delay when such information is no longer necessary.
8. Safety Management Measures
TXP will implement preventive measures concerning personal data it handles against events such as unauthorized access, loss, alteration and leakage, and take necessary and adequate safety management measures.
9. Selection and Supervision of outosourcing contractors
9-1 TXP may entrust operations accompanying its business activities such as various procedures, surveys, researches and PR activities, to outsourcing contractors. TXP will select such contractors from those proved to handle such information properly and securely when it entrusts all or part of handling personal information, and in such cases TXP will conclude adequate contracts with them.
9-2 TXP will conduct necessary and proper supervision to the contractors for them to manage the personal information securely, when it entrusts all or part of handling personal information.
10. Corrections, Suspension of use and disposal of Personal Information
10-1 When user, based on provisions of the Personal Information Protection Act, (1) requests to correct contents of personal information for the reason that the contents are not genuine, and,
(2) requests to suspend the use of personal information for the reason that it is used beyond the previously disclosed range of purposes or collected by deception or other wrongful means,
TXP will conduct necessary surveyillance promptly after confirming such request is placed by user himself/herself, and will correct the contents or suspend the use of such information based on result of the surveillance, and also will notify the fact to the user. In addition when TXP decides not to correct nor suspend the use of such information based on reasonable grounds, it will notify the fact to the user.
10-2 When user requests to dispose his/her personal information and TXP decides it necessary to fulfill the request, it will dispose such information after confirming such request is placed by user himself/herself, and also will notify the fact to the user.
10-3 When TXP has no obligations such as correction, suspension and disposal based on the Personal Information Protection Act and other laws, regulations and guidelines, prior 2 provisions will not apply.
11. Indemnification
In case defined by any item of the following, TXP assumes no responsibility for collection of user information by third parties.
(1) User himself/herself disclosed his/her user information to third party
(2) Information user or other person input in The Service made individual identification possible
12. Continuous Improvement
12-1 TXP will continuously monitor, review, and improve its handling of personal information, to conduct above mentioned provisions.
12-2 TXP will accordingly review The Policy to handle personal information properly. TXP will disclose the latest version of The Policy when revised.
13. Contact
For inquiries such as suggestions, questions, complaints or other requests concerning handling of user information, please contact the mail address below.
TXP’s personal information management supervisor
E-mail：inquiry@txpmedical.com
14. Procedures of revising Privacy Policy
TXP will review the operation status of personal information handling and endeavor to improve it continuously, and may revise The Policy. Should revision placed, the latest version will be disclosed in a short period. However, regarding revisions required to obtain users’ contents based on relevant laws or regulations, such contents will be obtained by the method prescribed by TXP.
Established on June 29th, 2019
