1.
Introduction
This
Privacy Policy explains how and why the personal information of customers and
other individuals obtained by OCS. ("OCS", "we",
"our" or "us") is used. Please read this Privacy Policy
carefully before providing personal information to OCS or using our products or
services. Chapter 1 of this Privacy Policy provides an overview of how we use
your personal information. Chapters 2, 3,
and 4 provide region-specific information for customers located or residing in
the European Economic Area/United Kingdom, China, and California, respectively.
Other policies may apply to OCS products and services, and details will be
provided separately in the terms of service, etc.
For
customers who reside in Japan, "personal information" in this chapter
refers to information about living individuals that can identify specific
individuals by their names, dates of birth, other descriptions, or personal
identification codes contained in the information.
The Privacy Policy will apply when customers and other
individuals provide personal information to OCS or use OCS's services and
products.
3. Purpose of using personal information
OCS
utilizes personal information obtained from its customers for the following
purposes. However, even within the intended scope, it will not use customers'
personal information in a way that may encourage or induce illegal or improper
conduct.
1.
Acceptance
of applications, provision, and communication regarding OCS services and
products
2.
Research and analysis of usage of OCS's
services/products
3.
All operations incidental or related to
purposes "1." through "2." Above
4.
Implementation of questionnaires
concerning service and products, etc., offered by OCS
5.
Development
of new services and products
6.
Notification of services and products
offered by OCS
7.
Operation and management relating to the
events and campaigns implemented by OCS, ANA and ANA Group companies, partner
companies, etc.
8.
Provision of information about the
services, products, events and campaigns of OCS, ANA Group companies, partner
companies, etc. as well as provision of
various pieces of information through methods including direct mail, e-mail
magazines, notices, and advertisements.
*
Customers' personal information (analytical data, etc. such as details of the
usage of services and products of OCS, ANA, ANA Group company, etc., OCS and ANA
website and mobile app browsing history, etc.) may be analyzed using AI, etc.
to estimate customer hobbies, tastes, purchasing trends, attributes, etc., and
the results used to formulate advertising distribution and marketing measures,
etc. targeting the customer.
9. Response
to enquiries, requests, etc.
※ In addition to the above-mentioned purposes,
personal information will be utilized for the purposes described in Chapter 1
Article 8 (Data sharing) below.
4. Acquisition of personal information
OCS will obtain the following personal
information by fair and appropriate means for the purpose of achieving the
previously mentioned purposes.
1. Identity, contact and payment
information, etc.
The customer's name, gender,
date of birth, address, telephone number, fax number, email address, employment
information (company name, division/department the customer belongs to, title,
address, telephone number, fax number), mailing address, passport information, ANA
Mileage Club customer number, etc.
2. Details of enquiries and complaints to OCS
Voice recording information
and other similar information that can identify a specific individual because
it contains the individual's name or for other reasons.
※We may monitor, record, store and use any telephone,
email or other communication with you in order to check any instructions given
to us, for training purposes, for crime prevention and to improve the quality
of our customer service.
3. IT and system data including
information on the usage of the OCS website
Information such as that on
how customers use the OCS website including details on cookies, advertising
identifiers (IDFA/GAID), location information, unique device identifiers, IP
address, details on OS and browser type, etc., and website activity logs by
which OCS may be able to identify a specific individual.
(For details on the purpose of use of
cookies and other related matters, please refer to "Handling of information on
the website”.)
OCS will never obtain and use information
of a sensitive nature to the customer (hereinafter, "sensitive
information"), such as information on race, beliefs, social standing,
history of illness, crime records, and history of having been afflicted by crime,
unless required by laws and regulations or by the consent of the customer.
5.
Choice by the customer
As a rule, OCS obtains personal information by the volition of the
customer. Customers may experience disadvantages if they refuse to provide
their personal information, such as being unable to make use of the various
services provided by OCS, or being unable to receive campaign notices and other
OCS information because a part of the functions of OCS's system become
inoperable and thereby unavailable. Please note that customers may change their
contact information as well as their decision on whether or not they wish to
receive email magazines at any time they wish, in a manner designated
separately by OCS.
6.
Disclosure and provision of information to a third party
(1) When OCS discloses or provides
customers' personal information to third parties
OCS will not disclose or provide personal customer information to any third
parties except under the following circumstances. Also, customers' personal
information including sensitive information will not be disclosed or provided
to third parties under any circumstances, unless allowed by laws and
regulations or by consent of the customer. Note that provision of information
to data sharing partners and business entrusted companies are not deemed to
constitute disclosure or provision to third parties.
1. Customer consent has been
obtained.
2. Disclosure or provision is required within the scope allowed by laws or
regulations.
3. Disclosure is required to protect human life, health, or property in cases
where obtaining customer consent is difficult.
4. Disclosure is required to cooperate with the public affairs of national or
local governments, and when obtaining customer consent is likely to hinder the
administration of public affairs.
5. Disclosure or provision of information as statistical data (in a format that
does not disclose the customer's identity).
6. Provision of information as a result of the succession of business due to a
merger, company split, transfer of business or otherwise.
7. Provision of information in accordance to procedures based on laws and
regulations, under the condition that the following
information can be easily checked by the customers themselves through
the OCS website, etc., and that the customers have not declared their wish to
refuse provision of their information.
• The purpose of obtaining information is to provide such information to a
third party
• Specific personal data items to be provided to a third party
• The means by which such personal information is provided to a third party
• Provisions of information will be suspended upon the customers' request
• Methods for accepting requests from customers
(2) Third parties to which OCS may
disclose or provide customers' personal information
OCS may disclose or provide customers' personal information to the following
categories of recipients.
1. Affiliates: OCS may disclose or provide customers'
personal information to companies belonging to the OCS Group and organizations
related to the OCS Group.
2. OCS's employees: OCS may disclose or provide
customers' personal information to the OCS's employees who are authorized and
who have a need to access such data.
3. Service providers: OCS may disclose or provide
customers' personal information to third-party service providers that perform
certain services, such as IT service providers (including data server and cloud
service providers), data analytics service providers, advertising distribution
service providers and legal advisors.
7. Data Sharing
OCS may share customer
information as follows.
Scope of entities that data can be
shared |
|
Purpose of using
data by the user |
1. For provision of air transportation
services, travel services including tours and hotels, and other
products/services handled by OCS or companies that share data |
Items of personal
information to be shared |
The
customer's name, address, telephone number, fax number, email address,
employment information (company name, division/department the customer
belongs to, title, address, telephone number, fax number), mailing address,
transaction detail, ANA Mileage Club customer number, service usage record,
details of enquiries, requests and complaints contained in correspondence
with customers, information on the use of OCS website, including cookie and
action log on the website, etc. |
Name, address, and representative of
the party responsible for management of personal information |
ANA
Holdings Inc. |
8. Business entrustment
In providing products and
services to customers, OCS may entrust a part of its business operations to
third parties to which personal information may also be disclosed to the extent
required to achieve the purpose of the entrustment. In these cases, OCS will
implement appropriate measures in managing and supervising such third parties
to safeguard the handling of customers' personal information, including
establishing agreements on the handling of such personal information.
9. Transfer to outside of Japan
OCS may transfer your
personal information (name, cargo information, etc.) outside of Japan for the
purpose of handling customers' cargo and other shipments. The countries or
regions to which customers' personal information is transferred may not have a system
for personal information protection equivalent to Japan's.
If
OCS provides customers' personal information to third party business operators
outside of Japan, including entrusted companies and data sharing partners, OCS
will do so based on customer consent, except in either of the following cases:
- when the third party is located in a
country specified by laws and regulations as one that has a personal
information protection system equivalent to Japan's; or
- when the third party has a system in
place where it can continuously take measures corresponding to those that
business operators handling personal information in Japan should take.
In the case of
"2." above, OCS will take necessary and appropriate measures to
ensure that the third party takes the corresponding measures on an ongoing
basis. If you wish to know the details of OCS's measures, please make a request
in accordance with "11. Request about handling of Personal
Information".
10. Management of personal information
In receiving customers'
personal information, OCS will manage such information according to the
strictest standards and take necessary safety management measures to prevent
leaks, loss, or alterations. OCS ensures that the board members and employees
are properly trained regarding appropriate handling to safeguard the security
of information identifying individual customers. An appropriate retention
period for personal information will be established in accordance with the
purpose for which such information is used. After the purpose of the
information has been achieved, OCS will dispose of the information in question
by appropriate methods.
11. Request about handling of Personal Information
If OCS
receives a request from a customer, submitted in the manner specified, for the
disclosure, correction, deletion, addition, discontinuance of use, erasure, or
information provision concerning the personal information protection measures
referred to in "9. Transfer to outside of Japan" and "10.
Management of personal information" ("disclosure, etc.") with
regard to the customer's personal information stored in a database held by OCS,
the request will be handled according to the laws and regulations as follows,
within a reasonable timeframe and scope, after confirming that the request was
submitted by the customer themselves.
1. Request
for disclosure
Personal information items,
purpose of use, or records on the provision of personal data to third parties
will be disclosed in accordance with the customers' request.
2. Request for correction, deletion, or addition
Correction, deletion, or
addition of personal information will be undertaken wherever possible after due
review of the request.
3. Request for discontinuance or erasure
The use of personal
information items designated by the customer will be discontinued, and the
relevant information erased if so desired, in accordance with the submitted
request. However, please note that such requests may prevent customers from
being provided with services that they had utilized, or may impede the
provision of services in accordance to their wishes.
4. Request for
information provision concerning personal information protection measures
The following information will
be provided in accordance with the customer's request.
1) Details of the safety
management measures taken by OCS in receiving customers' personal
information
2) Details of the measures
taken by OCS when providing customers' personal information to third parties
outside of Japan
(in the case of
"9. Transfer to outside of Japan '2.'")
OCS may not be able to fulfill
the customers' requests if compliance with such requests would seriously impact
OCS's business operations, result in a violation of laws and regulations, or
disrupt the safety management of personal information.
12. Submission of a request for disclosure, etc.
The method for submitting
a request for disclosure, etc or notification of
purpose of use of personal information ("requests for disclosure,
etc.") received by OCS from customers, and contact information are as
follows.
■
Requests for disclosure, etc.
1. Method for submitting a request
Please send the required
documents by postal mail to the address below.
(Mailing
address)
Overseas Courier Service (Deutschland)
GmbH
Fasanenweg 7D, 65451 Kelsterbach,
Germany
2. Required documents
Written application
Customer
requests for disclosure, etc., may not be acknowledged if any of the required
information is missing.
Documents required for confirmation of
identification of individual, etc.
<For
individuals>
1
A Copy of one of the followings: Driver's
License, Passport, Individual Number Card (front side only), Physical
Disability Certificate,
Resident
Card
<For representatives>
In addition to "<For individuals>," the following documents
described in ① and ② are required.
1
Power of Attorney (legal
representatives must provide a certifying document)
2
Documents to identify the
representative (A Copy of one of the followings: Driver's License, Passport,
Individual Number Card
(front
side only), Physical Disability Certificate, Resident Card)
You can check the status of
your OCS shipments within the normal scope of services and change your account
registration information on the OCS website (www.ocs.co.jp) or at the contact point
for each service. Please note, however, that in all cases the customer's
identity must be verified.
13. Modification
of the Privacy Policy
OCS may make modifications to this
Privacy Policy. If modifications are made, details will be posted on the OCS
website (www.ocs.co.jp).
Overseas
Courier Service Co., Ltd.
President and CEO
Hiroshi Sugiguchi
3-9-27 Tatsumi, Koto-ku, Tokyo 135-8527, Japan
Chapter 2 Handling of personal data of EEA and UK residents by
OCS
1. Introduction
This Chapter 2 provides additional information about the
handling of personal data of customers and other individuals in the European
Economic Area ("EEA") and/or the United Kingdom ("UK") in
accordance with EU General Data Protection Regulation 2016/679
("GDPR")
and the UK Data Protection Act 2018 ("DPA 2018") and other national
and international data protection and privacy laws
(together,
"Data Protection Laws").
Please
note that the UK's laws are similar to those in the EEA, and customers from
both jurisdictions have very similar rights. Accordingly, references to the
GDPR in this Chapter should also be read as references to corresponding UK law.
The
consent shall be given or authorized by the holder of parental responsibility
in the event that a customer under the age of 16 uses OCS's service. The data
subject's consent to this Privacy Policy must be obtained in the event that a
person such as family member applies for OCS's service on behalf of the data
subject.
In
the event that any provisions of this Chapter 2 contradict those of Chapter 1,
the provisions of this Chapter 2 shall prevail.
2. The controller of personal data
The
controller of your personal data is the OCS.
OCS
protects personal data which is collected and used by controllers (who make
decisions about how and why your personal data is used) and processors (who act
on the controller's written instructions) on the basis of Data Protection Laws.
3. Our
legal basis for processing personal data
OCS protects your personal data by ensuring that it can only be
used to the extent necessary for specific purposes (as set out in Part 3 of
Chapter 1 of this Privacy Policy) and by requiring that there
is a legal basis for each processing activity on the basis of Data Protection
Laws.
OCS may process customer
personal data on one or more of the following legal basis:
(a) When your consent is obtained to the
processing (Article 6(1)(a) GDPR)
Consent will usually only be
relied upon for promotional and marketing related processing, or in some cases,
in relation to sensitive personal data.
(b) When processing is necessary in order to
perform or take steps to enter into a contract (Article 6(1)(b) GDPR)
This is typically why we process customer information which is essential
to providing our services, including a customer's identity, contact, payment,
travel information etc.
(c) OCS needs to process the information to
comply with a legal obligation (Article 6(1)(c))
This includes the requirement to share
personal data with customs and immigration authorities or law enforcement, as
well OCS's legal obligations towards its staff and customers.
(d) The information is required to protect
your, or a third party's, vital interests (Article 6(1)(d)), for example in the
event of a medical emergency.
(e) It is in OCS's or a third party's
legitimate interests to process the personal data, and these interests are not
overridden by your rights under Data Protection Laws (Article 6(1)(f) GDPR).
This includes the use of personal data necessary to operate OCS's
business and also to maintain, develop and improve its goods and services, and
to provide the best experience to customers.
4. Request for processing of personal
data
(1) Data Protection Laws
provide you with the following legal rights:
1) Request for access : You can request copies of
your personal data and details of how we process it.
2) Request for
rectification:
Rectifications to personal data will be undertaken wherever possible after due
review of the request.
3) Request
for erasure: You may request that we erase all or part of the personal data
we hold about you. We will consider your request and, where the data is no
longer required or the law does not permit us to continue to retain it, we will
erase it.
4) Request for data
portability: You
can request a copy of your personal data in a structured, common,
machine-readable format. This only applies to personal data which we obtain
from you and process on the basis of your consent or in order to perform a
contract, and which is processed by automated means.
5) Objecting: You can object to
processing which is carried out on the basis of our or a third party's
legitimate interests or for the purpose of direct marketing. We will stop
processing your information unless we have a strong reason to continue which
overrides your objection. If your objection is to direct marketing, we will
always stop.
6) Restrictions: You can restrict how we
process your personal data in certain circumstances. Where this applies, any
processing of your personal data (other than storing it) will only be lawful
with your consent or where required for legal claims, protecting certain rights
or important public interest reasons.
7) Withdrawal of consent: If we are relying on
consent to process your personal data, you have the right to withdraw that
consent at any time.
Please
note, the rights set out above are not absolute and do not apply in every
situation. There are also legal exemptions which apply in some situations and
mean a request may be refused. Of course, if a request is refused, we will
inform you of the reasons for this when we respond.
Records of requests made to us will be retained so
that we can ensure we have complied with our legal obligations.
(2) Method for submitting
a request
You can exercise your rights
free of charge (except in the case of unreasonable, excessive or repeated
requests in which case we may charge a fee or refuse the request). The method
for submitting a request and contact information are as follows.
Please send the required documents by postal mail to the
address below.
(Mailing address)
Overseas Courier Service (Deutschland)
GmbH
Fasanenweg 7D, 65451 Kelsterbach,
Germany
(3) Required
documents
written
application
Disclosure Request Form (for EEA/UK residents
Customer
requests for disclosure, etc., may not be acknowledged if any of the required
information is missing.
(4) Responding
to a request
We will respond without undue delay and usually within one
month. We may, in some cases, ask for identification or (if you are making the
request on behalf of a third party) proof of your authority to submit a
request. If your request is particularly complex or you have made a number of
requests, it may take longer to provide a detailed response. Please also bear
in mind that there are exceptions to the rights above and some situations where
they do not apply.
If you are not satisfied with our response to a data protection
request or if you think your personal data has been mishandled, then you have
the right to complain to a supervisory authority. Please see Part 9 of this
Chapter 2 ("Lodging a complaint with an authority") for further
details.
5. Data sharing which is necessary to
provide goods or services
OCS's
goods and services are provided with the assistance of other companies and
organizations and often OCS will need to share personal data with third parties
in order to run its business. These third parties include:
(a) Other
companies in the ANA Group
(b) Organizations with which OCS is
legally required to share personal data
including: government organizations, regulatory and law
enforcement authorities, judicial, customs and immigration authorities,
third-party organization, etc.
(c) Service
providers
Including: subcontractor for collection and delivery, cargo
handling, various service providers, providers with whom we have a marketing partnership, etc.
Where OCS instructs companies, contractors or service providers
to process data on its behalf, then it will ensure that it does so pursuant to
a contract which meets the requirements of applicable Data Protection Laws.
6. Marketing
communications
OCS
sends out marketing communications from time to time to notify interested
persons of news and provide details of goods and services which may be of
interest to them. OCS will only do this if the recipient has consented to
receive marketing or if they are an
existing
customer who purchased goods or services from OCS and were given the
opportunity to opt-out from marketing at the time
but
chose not to do so.
7. Where your personal data is stored and
transferred
OCS
is located in Japan and many of the service providers and other organizations
with whom we share your personal data will be located in jurisdictions outside
the EEA and UK. It should be noted that Japan has been recognized by the
European Commission as providing
adequate
protection for personal data.
When
transferring personal data to third parties OCS will ensure that it complies
with the requirements of Data Protection Laws, including the onward transfer
requirements of the EU-Japan adequacy decision and related Japanese laws.
However, you should be aware that recipients outside the EEA and UK may be
subject to national laws which do not necessarily provide equivalent protection
for your personal data. If you would like more information regarding where your
personal data is stored and transferred, please contact OCS using the details
set out in Part 12 of this Chapter 1 ("Submission of a request for
disclosure, etc.").
8. Retention of personal data
OCS retains customers' personal data until the purpose of use is
achieved. Particularly, OCS has set the retention period for personal data as
follows.
(1) Personal
data of customers using international
transportation service
Until completion of carriage and related services
as defined in the International conditions of
carriage.
(2) Other
personal data
Required period for the purpose which customers
have consented.
9. Lodging a complaint with an
authority
Customers have the right to lodge a complaint on the processing of
their personal data with the data protection authority having jurisdiction over
their residence.
(1) EEA residents: Please contact your national supervisory
authority, details of which can be found on the European Data Protection Board's website (Our Members | European Data Protection Board)
(2) UK
residents: Please contact the Information Commissioner's Office
10. The contact information of the controller and OCS's Data
Protection Officer
Overseas Courier Service (Deutschland) GmbH
Fasanenweg 7D, 65451 Kelsterbach,
Germany
Chapter 3 Handling of personal information of China residents by
OCS
Besides Chapter 1, Chapter 3
also applies to the handling of personal information of persons residing in the
People's Republic of China (hereinafter, "China") based on China's
Personal Information Protection Law and related regulations (hereinafter, “PIPL
etc.”). In the event that any provisions of this chapter contradict those of
chapter 1, the provisions of this chapter shall prevail.
1. Introduction
A guardian's consent or
permission must be obtained in the event that a customer under the age of 18
uses OCS's service and consents to this Privacy Policy. In the event that a
person such as a family member applies for OCS's service on behalf of the data
subject, the consent of the data subject (when he/she is under the age of 14,
his/her guardian) to this Privacy Policy must be obtained.
2. Collection of sensitive personal
information
OCS may handle
personal information such as your personal details that may be classified as
sensitive personal information under the PIPL, etc. for the purpose of use.
Since sensitive personal
information can negatively affect the interests of customers if it is leaked or
used unlawfully (for example, it is likely that individual dignity will be
damaged or that personal safety and asset security will be put at risk), OCS
will carefully manage such information and handle it in a lawful manner.
3. Retention period for personal information
OCS will retain the
customer's personal information until the purpose of use is achieved. In
particular, OCS sets the retention period for personal information as follows.
(1) Personal
data of customers using international transportation service
Until completion of carriage and related services
as defined in the International conditions of
carriage.
(2)
Other personal data
Shortest
period for the purpose which customers have consented.
4.Technology and measure to protect
customers' personal information
1. OCS takes security measures to protect customers'
personal information from leakage, alteration or loss. Specifically, OCS takes
the following
measures to protect customers' personal information.
・OCS establishes and implements an
internal management system and operational rules relating to the protection of
personal information.
・OCS conducts classification management for personal
information.
・OCS develops website with https and sets SSL encryption
to secure important customers' data (credit card information, etc.)
communication between the customers' web browser and the server.
・OCS uses encryption technology for protecting personal
information.
・OCS allocates access rights reasonably and controls
access, so that access by unauthorized persons to personal information will be
prevented.
・In order to raise employee
awareness of the importance of protecting personal information, OCS provides
education and training on security and privacy protection.
・OCS establishes emergency
responses for personal information incidents and prepares for their
implementation.
2. OCS will take
all reasonable and practicable steps to ensure that no irrelevant personal
information is collected. OCS will only retain customers' personal information
for the shortest period of time required to achieve the purposes stated in this
Privacy Policy, unless an extension of the retention period is permitted by
law.
3. In the event
of a personal information incident, OCS will promptly inform customers of the
relevant circumstances of the incident in accordance with the requirements of
PIPL, etc. and report to the regulatory authorities.
5. Request about handling of Personal
Information
In the event that OCS
receives a request regarding the personal information it holds of a customer
who is a resident of China, the request will be handled in a reasonable
timeframe and scope in accordance with PIPL, etc. and Chapter 1 "Article
11 Request about handling of Personal Information". In responding to the
request, OCS may confirm that it was submitted by the customer himself/herself.
1.
Request for withdrawal of consent
If the
handling of the customer's personal information is based on his/her consent,
the customer has the right to withdraw such consent. Personal
information items designated by the customer will be deleted in accordance with
the customer's request, wherever possible and appropriate. However, please note that such
deletion may prevent customers from being provided with services that they had
utilized, or may impede the provision of services in accordance with their
wishes.
2.
Requests for interpretation/explanation of Privacy Policy
Customers have the right to ask for the interpretation/explanation of
this Privacy Policy.
3. Methods for submission of
a request
Customers may submit a request by following methods.
1)
Submission of a request
(by post)
Please send the required documents by postal mail to the address below.
(Mailing address)
Overseas Courier Service
(Deutschland) GmbH
Fasanenweg 7D, 65451 Kelsterbach,
Germany
2) Required
documents
Written
application
Request for Disclosure Form <for Chinese residents>
Documents required for confirmation of
identification of individual, etc.
<For individuals>
① A Copy of
one of the followings: Official ID Card with a photo, such as Driver's License,
Passport, etc.
<For representatives>
In addition
to "<For individuals>," the following documents described in ①
and ② below are required.
1
Power
of Attorney (legal representatives must provide a certifying document)
2
Documents
to identify the representative (A Copy of one of the followings: Official ID
Card with a photo, such as Driver's License, Passport, etc.)
3) Contact Desk
Germany : +49-(0)617-705-6920
6. Provision to third parties and transfer
outside China
When OCS provides personal
information of customers to third parties (including the cases of provision due
to shared use and business entrustment that involves the transfer of such
information outside China), it will do so in accordance with PIPL, etc.
7. Change of purposes of use of personal
data
In the case of a change to
the purposes of use of personal information, OCS will announce the revised
Privacy Policy in advance on OCS website (www.ocs.co.jp) and OCS will
use personal information in accordance with the new purposes of use of personal
information after obtaining consent from customers.
8. Basic information of Controller of
personal information
Overseas
Courier Service (Deutschland) GmbH
Fasanenweg 7D, 65451 Kelsterbach, Germany
Chapter 4:
Handling of personal information of California residents by OCS
Last updated on July
1, 2025
Besides
Chapter 1, Chapter 4 also shall be applied to the handling of personal
information of persons residing in California, United States of America based
on the California Consumer Privacy Act of 2018 as amended under the California
Privacy Rights Act of 2020 (hereinafter "CCPA"). In the event that
any provisions of this chapter contradict those of chapter 1, the provisions of
this chapter shall prevail.
The terms used
in this chapter are based on the definitions provided in CCPA. For example, the
term "sale" means OCS's selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise communicating
orally, in writing, or by electronic or other means, a consumer's personal
information to a third party for monetary or other valuable consideration. The
term "sharing" means OCS's sharing, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise communicating
orally, in writing, or by electronic or other means, a consumer's personal
information to a third party for cross-context behavioral advertising, whether
or not for monetary or other valuable consideration. However, if OCS concludes
an appropriate agreement concerning the handling of personal information with a
third party, the activities mentioned above are not regarded as
"sale" from the perspective of CCPA.
1. Acquisition and use of personal information
Personal information collected by OCS in
the preceding 12 months or likely to be collected in the future is classified
as defined in the following table. OCS uses such information for the purposes
set forth in Chapter 1, Article 3 (Purpose of using personal information). It
will acquire such personal information directly from customers.
Type
of personal information collected |
Examples
of personal information |
Identifiers (name or symbol, etc. used
to uniquely identify a particular subject) |
The customer's name, address, telephone
number, fax number, mailing address, email address, passport information,
personal online ID, ANA Mileage Club customer number (10 digits), etc. |
Commercial information |
Usage record of international transportation service, purchases
of publications and daily necessities, etc., and information in detail of
enquiries, requests and complaints contained in correspondence with
customers, etc. |
Internet or other electronic network activity information |
Information such as that on how customers use the OCS website,
including cookies, advertising identifiers (IDFA/GAID), location information,
unique device identifiers, IP address, details on OS and browser type, etc.,
and website activity logs |
Professional or employment-related information |
Employment information (company name, division/department the
customer belongs to, title, address, telephone number, fax number) and
related information |
2. The disclosure of personal information
(1)
Sale of personal information
OCS will not
sell customers' personal information (including personal information concerning
minors) to any third parties, and has not sold the same in the past 12 months.
(2) The sharing of personal
information
The types of
personal information that OCS may share with third parties in the future, and
the types of personal information that OCS has shared with third parties in the
past 12 months and the types of third parties with whom OCS has shared personal
information during the said period are shown below.
OCS shares such personal information with third parties in order to conduct
marketing activities (including personalized advertisements), such as provision
of information on events and campaigns. OCS will not share the personal
information of a customer with a third party if OCS has actual knowledge that
the customer is a minor.
Type of personal information shared |
Example of personal information |
Type of third party OCS
shared personal information with in the past 12 months |
Internet or other electronic network activity information |
Information such as how customers use the OCS website and mobile
application, including details on cookies, advertising identifiers
(IDFA/GAID), location information, unique device identifiers, IP address,
details on OS and browser type, etc., and website activity logs |
Ad network |
(3) Disclosure
of personal information for business purposes
The types of
customers' personal information that OCS has disclosed in the past 12 months
for business purposes and the types of third parties to which such personal
information has been disclosed are shown below. OCS discloses these types of
personal information to third parties for the purposes specified in Chapter 1.
("3. Purpose of using personal information" and "7. Data
sharing")
Type of personal information disclosed |
Example of personal information |
Types of third parties to which the personal
information has been disclosed in the past 12 months |
Identifiers (name or symbol, etc. used to uniquely identify a
particular subject) |
The customer's name, address, telephone number, fax number,
mailing address, email address, passport information, personal online ID, ANA
Mileage Club customer number (10 digits), etc. |
Other companies in the ANA Group, subcontractor for collection
& delivery and cargo
handling, various service providers, , government
organizations, regulatory and law enforcement authorities, judicial, |
Commercial
information
|
Usage record of international transportation service, purchases
of publications and daily necessities, etc., and information contained in
correspondence with the customer. The details of enquiries, requests and
complaints contained in correspondence with customers, etc. |
Other companies in the ANA Group, subcontractor for collection & delivery and cargo handling, various service
providers, , government organizations, regulatory and law enforcement
authorities, judicial, customs and authorities, third-party organization,
etc. |
Internet or other electronic network activity information |
Information such as that on
how customers use the OCS website, including details on cookies, advertising
identifiers (IDFA/GAID), location information, unique device identifiers, IP
address, details on OS and browser type, etc., and website activity logs |
Other companies in the ANA Group, various service providers, government organizations, regulatory and law enforcement
authorities, judicial, customs authorities, third-party organization, etc. |
Professional or employment-related information |
Employment information (company name, division/department the
customer belongs to, title, address, telephone number, fax number) and
related information |
Other companies in the ANA Group, various service providers, government organizations, regulatory and law enforcement
authorities, judicial, customs authorities, third-party organization, etc. |
3. Sensitive personal information
OCS does not use or disclose
sensitive personal information of customers for any purpose other than certain
purposes permitted under the CCPA. OCS does not collect or process sensitive
personal information of customers for the purpose of inferring characteristics
about customers.
4. Retention of personal information
OCS retains customersʼ personal information until the purpose of use is
achieved. The period of retention shall be the period necessary
for the purpose of use agreed
to by the customer, and shall be determined according to the nature of the
information and the purpose of
retention, taking into
consideration our business needs, and other factors.
5.
Request about
handling of personal information
Customers living in
California have the following rights concerning their personal information:
(1) Right
to access
Customers have
the right to make a request to OCS for the disclosure of the following
information regarding their personal information collected/used/disclosed by
OCS within the 12 months before the date of request (hereinafter "Right to
access"), up to twice in 12 months.
・Type of the
customer's personal information collected by OCS
・Source of the
collection of such personal information
・Business or
commercial purposes for the collection of such personal information
・Type of third
party with which such personal information has been shared
・The customer's
specific personal information collected by OCS
・Type of the
customer's personal information disclosed by OCS for a business purpose
・Type of third parties to which each type of such personal
information has been disclosed
(2) Right
to delete
Customers have
the right to make a request to OCS for the deletion of their certain personal
information collected by OCS (hereinafter "Right to
delete").
(3)
Right to correct
Customers have
the right to request OCS to correct incorrect personal information held by OCS
(hereinafter the "Right to correct").
(4) Right to opt-out of sharing
Customers have
the right to direct OCS to stop sharing their personal information with a third
party (hereinafter the "Right to opt-out of sharing").
When, among
the rights set out above, exercising the right to access, the right to delete,
the right to opt-out of sharing, please contact us using any of the following
methods below. Once OCS receives such a request, it will be handled according
to the related laws and regulations within a reasonable timeframe and manner,
after confirming, through the procedures for individual identification
described below, that the request was submitted by the customer
himself/herself.
1) Submission of a request
Overseas Courier Service
(Deutschland) GmbH
Fasanenweg 7D, 65451 Kelsterbach,
Germany
Germany : +49-(0)617-705-6920
2) Procedures for individual identification
<For individuals>
Upon receiving a request for the exercise of the
right to access, the right to delete, the right to correct and the right to opt-out of sharing, OCS will ask the customer to submit
information sufficient to confirm that such request was submitted by such
customer himself/herself, such as his/her name and email address, and compare
the submitted information with the information held by OCS.
<For representatives>
In addition to the information required for the
identification of individual in "<For individuals>," the
customer needs to submit a certificate signed by him/her certifying that the
representative is authorized to exercise rights on his/her behalf. In addition,
OCS may ask the customer to directly contact OCS to confirm that he/she has
granted the representative authority to exercise the right to access, the right
to delete, the right to correct or the right to opt-out of sharing.
Chapter
5: Handling of personal data of Thailand residents
by OCS
1. Introduction.
This Chapter 5 provides
additional information about the collection, use, or disclosure
("processing") of personal data of customers and
other individuals in the
Kingdom of Thailand ("Thailand") in accordance with the Personal Data
Protection Act of Thailand B.E. 2562
(A.D. 2019)
("PDPA").
If consent is required for
processing of personal data relevant to the use of OCS's services of data
subjects who are minors, quasi-incompetents or incompetents under the law of
Thailand and cannot lawfully give consent by themselves, consent of the holder
of parental responsibility over the child, their curators or custodians (as the
case may be) shall also be obtained. If data subjects are under the age of 10,
only consent of the holder of parental responsibility shall be obtained.
If OCS is not aware that the
data subjects are minors, quasi-incompetent persons or incompetent persons
prior to the collection of their personal data, upon learning that we have
collected personal data of minors without the consent of the holder of parental
responsibility over the child (when it is required and the minors cannot
lawfully give consent by themselves), or from quasi-incompetent persons and
incompetent persons without the consent of their legal curator and custodian,
we will delete the personal data at the earliest convenience unless we can rely
on other legal grounds apart from consent for such processing.
The data subject's consent to
this Privacy Policy must be obtained in the event that a person such as family
member or an agent authorized to act on its behalf applies for OCS's service on
behalf of the data subject.
In the event that any
provisions of this Chapter 5 contradict those of Chapter 1, the provisions of
this Chapter 5 shall prevail.
2. The controller of personal data
The controller of your personal data is OCS.
OCS protects personal data
which is collected and used by controllers (who make decisions about how and
why your personal data is used) and processors (who act on the controller's
written instructions) on the basis of the PDPA.
3. Our legal basis for processing
personal data
OCS protects
your personal data by ensuring that it can only be used to the extent necessary
for specific purposes (as set out in Part 3 of Chapter 1 of this Privacy
Policy) and by requiring that there is a legal basis for each processing
activity on the basis of the PDPA.
OCS may
process customer personal data on one or more of the following legal basis:
(a)
When your
consent is obtained to the processing (Article 19 PDPA)
Consent will
usually only be relied upon for promotional and marketing related processing,
or in some cases, in relation to sensitive personal data.
(b) When processing is necessary in order to
perform or take steps to enter into a contract (Article 24(3) PDPA).
This is
typically why we process customer information which is essential to providing
our services, including a customer’s identity, contact, payment and travel
details, etc.
(c) OCS needs to process the information to
comply with a legal obligation (Article 24(6) PDPA).
This includes
the requirement to share personal data with customs and immigration authorities
or law enforcement, as well OCS's legal obligations towards its staff and
customers.
(d) The information is required to protect
your, or a third party’s, vital interests (Article 24(2) PDPA), for example in
the event of a medical emergency.
(e) It is in OCS's or a third party's
legitimate interests to process the personal data, and these interests are not
overridden by your fundamental rights regarding your personal data under the
law (Article 24(5) PDPA).
This includes
the use of personal data necessary to operate OCS's business and also to
maintain, develop and improve its goods and services, and to provide customers with the best possible experience to the extent permissible under
the PDPA.
4. Request for processing of personal data
(1) The PDPA
provides you with the following legal rights:
1) Request for
disclosure
You can request copies of your personal data and details of how we
process it.
2) Requests for
correction or updating
Corrections or updates to personal data will be undertaken
wherever possible after due review of the request.
3)Request for erasure
You may request that we erase, destroy or
anonymize all or part of the personal data we hold about you. We will consider
your
request and, where the information is no
longer required or the law does not permit us to continue to retain it, we will
delete it.
4) Transferring your personal data
You can request a copy of your personal data in a
structured, common, machine-readable format. This only applies to personal
data which we obtain from you and process on the basis of
your consent or in order to perform a contract, and which is
processed by automated means.
5) Objecting to processing
You can object to processing which is carried out on the
basis of our or a third party's legitimate interests or for the purpose of
direct marketing. We will stop processing your information
unless we have a legitimate reason to continue which overrides your
objection. If your objection is to direct marketing, we
will always stop.
6) Restricting
how your personal data is processed
You can limit how we process your personal data in certain
circumstances. Where this applies, any processing of your personal
data (other than storing it) will only be lawful with your
consent or where required for legal claims, protecting certain rights or
important public interest reasons.
7) The right to withdraw consent
If we are relying on consent to process your personal data,
you have the right to withdraw that consent at any time. However,
the
withdrawal of consent shall not affect the processing of
your personal data that you have already given consent legally before it
is withdrawn.
Please note,
the rights set out above are not absolute and do not apply in every situation.
There are also legal exemptions which apply in some situations and mean a
request may be refused. Of course, if a request is
refused, we will inform you of the reasons for this when we respond.
Records of requests made to us will be retained so that we can ensure we
have complied with our legal obligations.
(2)
Method for submitting a
request
You can
exercise your rights free of charge (except in the case where expenses may be
chargeable under the PDPA). The method for submitting a request and contact
information are as follows.
Please send the required documents by postal mail to the
address below.
(Mailing address)
Overseas
Courier Service (Deutschland) GmbH
Fasanenweg 7D, 65451 Kelsterbach,
Germany
(3)
Responding to a request
Written
application
Request for Disclosure Form <for Thai residents>
Customer requests for disclosure, etc.,
may not be acknowledged if any of the required information is missing.
(4)Responding to a request
We will
respond without undue delay and usually within thirty (30) days. We may, in
some cases, ask for identification or (if you are making the request on behalf
of a third party) proof of your authority to submit a request. If your request
is particularly complex or you have made a number of requests, it may take
longer to provide a detailed response. Please also bear in mind that there are
exceptions to the rights above and some situations where they do not apply.
If you are not
satisfied with our response to a data protection request or if you think your
personal data has not been processed appropriately, then you have the right to
file a complaint with the Personal Data Protection Committee of Thailand.
Please see Part 9 of this Chapter 5 ("Lodging a complaint with an
authority") for further details.
5. Data sharing which is necessary to provide goods or
services
OCS's goods and services are
provided with the assistance of other companies and organizations and often OCS
will need to share personal data with third parties in order to run its
business. These third parties include:
(a) Other
companies in the ANA Group
(b) Organizations
with which OCS is legally required to share personal data
including:
government organizations, regulatory and law enforcement authorities, judicial,
customs and immigration authorities, third-party organizations,
etc.
(c)
Service providers
including: subcontractor for collection & delivery,
cargo handling, various service providers, providers with whom we
have a
marketing partnership, etc.
Where OCS
instructs companies, contractors or service providers to process data on its
behalf, then it will ensure that it does so pursuant to a contract which meets
the requirements of PDPA.
6. Marketing communications
OCS sends out marketing
communications from time to time to notify interested persons of news and
provide details of goods and services which may be of interest to them. OCS
will only do this if the recipient has consented to receive marketing
communications.
7.
Where your
personal data is stored and transferred
OCS is located in Japan and many of the
service providers and other organizations with whom we share your personal data
will be located in jurisdictions outside Thailand.
When transferring personal
data to third parties, OCS will ensure that it complies with the requirements
of the PDPA and related Japanese laws.
However, you should be aware that
recipients outside Thailand may be subject to national laws which do not
necessarily provide
equivalent protection for your personal
data. If you would like more information regarding where your personal data is
stored and
transferred please contact OCS using the
details set out in Part 12 of this Chapter 1 ("Submission of a request for
disclosure, etc.").
8. Retention of personal data.
OCS retains customers' personal data
until the purpose of use is achieved. Particularly, OCS has set the retention
period for personal data as follows. For most other personal data, the
appropriate retention period will be determined based on the nature of the
information and the purpose for having it by reference to legal and accounting
requirements and our business needs.
(1) Personal
data of customers using international transportation
service.
Until completion of carriage and related services
as stipulated in the International conditions of
carriage.
(2) Other
personal data.
Required
period for the purpose which customers have consented.
Please note
that OCS may retain your personal data for a longer period than mentioned above
if it is for the purposes of the establishment, compliance, or exercise of
legal claims, the defense of legal claims, or the purpose for compliance with
the law.
9. Lodging a complaint with an authority
Customers have the right to lodge a
complaint on the processing of their personal data with the Personal Data
Protection Committee of Thailand.
10. The contact information of the
controller and OCS's Data Protection Officer
Overseas Courier Service (Deutschland) GmbH
Fasanenweg 7D, 65451 Kelsterbach, Germany
Handling
of information on the website
This
section sets out the OCS website's handling of personal data and other
information. For information on the handling of personal data
by
OCS as a whole, please refer to the OCS Privacy Policy.
1. Introduction
OCS
handles information on this website (hereinafter referred to as ‘this website’)
in accordance with the ‘OCS Privacy Policy’ as
follows,
and strives to operate and manage this website so that customers can use it
with peace of mind.
Customers
who use this website are deemed to have fully understood and agreed to the
following terms and conditions.
Scope of application
This
Privacy Policy applies when you use our website (ocs.co.jp domain) and does not
apply to websites operated by other companies. Our website provides links to
other websites in order to provide useful information and services to our
customers. The Privacy Policy does not apply to linked sites. We recommend that
you check the privacy protection statements of each site when you access them.
2. Security
Security technology that protects personal
information
When
customers provide us with personal information, we encrypt that information
using SSL (secure sockets layer) encryption technology or equivalent security
technology to prevent unauthorized access by third parties during transmission.
In addition, we strive to ensure the security of our customers' personal
information by implementing reasonable security measures such as firewalls and
anti-virus software to prevent the leakage, misuse, or alteration of personal
information due to unauthorized access by third parties.
How SSL (secure sockets layer) works
With
SSL, before customers send personal information, we conduct electronic security
exchanges (digital authentication and digital signatures) with them to mutually
authenticate each other before transmitting data. The exchanges between us and
our customers are scrambled with random numbers, preventing misdelivery
to third parties who attempt to steal data by impersonating our customers.
Furthermore,
information transmitted via SSL is encrypted using a combination of two
encryption methods: public key cryptography (RSA) and common key cryptography
(secret key cryptography). To decrypt this information, an electronic ‘key’ is
required. Even if the information is intercepted by a third party, it is
impossible to decrypt the encrypted information without the correct key. While
the number of keys is finite, attempting to systematically try all possible
keys to find the correct one would require an extremely long time, even when
using a computer for computational processing. Therefore, it is extremely
difficult for a third party to decrypt the information.
3. Collection of browsing information
About browsing our site
When you view our website, we collect the following information
in order to provide you with a comfortable service experience.
1.
Use of cookies*1
We collect cookies for the purpose of providing the following
information.
・
Login
information for web services provided by OCS
● Information on personalized pages for customers
● Registration information for various campaigns, etc.
● Browsing history information (using web beacons*2)
Customers can refuse to accept cookies at any time by changing
the settings of their Internet browser software. We recommend that you set your
browser to allow cookies only from websites you trust. However, please note
that without cookies, response speeds may be significantly reduced.
2.
Use of IP addresses*3
We collect IP addresses for the purpose of providing
information tailored to the customer's region. When a customer views our
website, we identify the region from which they are accessing based on their IP
address, but we do not identify the customer.
About email
distribution
In the course of sending emails to you, we
may obtain the following information
● HTML email open or preview status (using web beacons*2)
● Information on access to our website via email (HTML email and text email)
*1
What is a cookie?
1. Cookies are a feature that stores
information about users' use of this website on their computers. Information
collected through cookies does not include any personally identifiable
information such as email addresses or names.
2. Our company may provide information
collected through cookies to third parties to the extent necessary to achieve
the
purposes listed in ‘1. Use of Cookies *1’ of this Privacy
Policy.
3. Users may choose whether or not to use
cookies for each purpose, and shall set their preferences in accordance with
the
settings of the web browser they use. If users use this website
with cookies enabled, they shall be deemed to have consented to our use of
information regarding their use of this website.
*We recommend that you accept cookies in order to make full use
of the features of this website.
*2
What is a web beacon?
A web beacon is a mechanism for collecting information about
page views by embedding a small, invisible image (a 1×1 pixel GIF image) in a
web page or HTML-formatted email. This allows us to accumulate information
about your web page views and email openings/previews.
*3
What is an IP address?
It is a number automatically assigned to your computer when you
view various websites. Web servers (computers that provide homepages)
automatically recognize your computer from its IP address and communicate with
it.