Privacy Policy

This Privacy Notice describes the information handling and privacy practices of Assurant Japan KK and TWG Japan (Assurant group companies)  (hereinafter referred to as "Assurant" or “We”, “Us”, “Our” or “Company”) in connection with your submission of a New Buyer Application and your use of https://www.assurant.co.jp/new-reseller-application (the “Services”). We respect your concerns about privacy.  This Privacy Notice describes how We will collect, access, use, disclose, retain, transfer, otherwise process and protect personal information, in accordance with the Act on the Protection of Personal Information (Act No. 57 of 2003 as amended in 2020), when you use the site to access Our Services or to submit a New Buyer Application via the Service. For information about other services of Assurant Japan KK and TWG Japan. or their respective subsidiaries and affiliates, please refer to the respective privacy notices applicable to such services.

If you have any concern about providing information to Us or your information being used in any manner permitted by this Privacy Notice and the Terms of Use you should not use the Services.

When you submit a New Buyer Application We collect:

• Business Contact Information which includes the following: company name, business contact first and last name, address, e-mail address, fax number; and phone number;  
• Business Profile Information which includes the following: company website address, company type or structure, establishment dates, locations,  Tax ID, and parent company information;
• Business Accounts Payable Contact Information which includes the following: first and last name of company accounts payable contact, title, phone number, e-mail address and fax number;  
• Financial Information which includes, phone number,  bank name, SWIFT code and bank telephone number;
• Company Principals Information which includes: principal’s first and last name, title, address, country and signature;
• Business References which includes: business reference name, phone number address, country, email address, company account number and fax number;
• New Customer Setup Information includes: company location, company registration number, R2 certification information, first and last name of company contact who would receive bids and invoices and contact details (e.g., phone number and email address), shipping information, as well as a copy of contact’s government-issued identification card or driver’s license (US customers), copy of the identification page of contact’s government-issued passport (non-US customers).  Note: government-issued identification cards, driver’s licenses and passports may contain any of the following information: first and last names, date of birth, address,  birth country, country of residence, dates of issue and expiration, unique ID numbers (for example – passport number or driver’s license number), gender, eye color, hair color, height, signature, veteran or military status, etc.); and
• Device Information such as your Internet Protocol address,  the type of browser, devices and operating systems you use; identifiers associated with the device(s) you use to access the Services; and information regarding your internet service provider.

When you communicate with Us or contact Us in regard to your New Buyer Application  (for example – when you send us a message through Our “Contact Us” function) We may collect information that you provide to Us in your communications (such as the query or issue that you have raised).  

We collect the information described above from you and the device that you use to access the Services and from third parties such as service providers, affiliates, consumer reporting agencies and public records.   

With your permission We will access the information contained within your application. We will process your data in order to process your query and/or answer your questions.  You may report any problems or security concerns with the site by sending an email to [email protected].

2. How Do We Use Your Information?

We collect information from you to:

Fulfil a contract with you or take steps related to a contract with you including:

• Providing the Service, to you;
• Reviewing your application information; and
• Communicating with you.

We process information for purposes the fulfilment of a contract or  our legitimate interest in preventing fraud.

To support Our provision of the Services to you, in particular:

• To recognize you when you use our Service;
• To increase the security of Our networks and systems;
• For investigating complaints received from you and others about the Service, and tracking potential issues and trends to better serve you;
• For making decisions about, and implementing, reorganizations or sales of all or part of Our business;
• To monitor customer applications to prevent, investigate and/or report fraud, misrepresentation, or crime, in accordance with applicable law;

We process information for purposes the fulfilment of a contract or our legitimate interest in preventing fraud or with your consent, as applicable.  

To ensure our compliance with law such as:

• In response to requests by government or law enforcement authorities conducting an investigation; and
• Responding to complaints where We are under a legal or regulatory obligation to adhere to a complaints handling procedure.

We may communicate with you through email and other means available to Us. Examples of these communications include: (1) application status, and (2) Service-related communications. These messages will be sent to you based on your application information.  Please be aware that you cannot opt out of receiving Service-related messages from Us.

3. How We Share Your Information? 

We share your personal information with the following recipients under the following circumstances: 

• Affiliates.We share your personal information with Our parent company Assurant, Inc. and its affiliates and subsidiaries (meaning entities controlled by, controlling, or under common control with Assurant, Inc.) for the purposes stated in this Notice. For example, your enquiry may be handled by staff located within or outside Japan (such as in the United States). Your personal information may be shared with an Assurant group company, such as Hyla Mobile, Inc. for customer relationship management purposes (for example – when you enquire about the status of your application).
• Service Providers. We employ third party companies and individuals to facilitate the Service (for example - database hosting) within and outside Japan, in the United States and India. These third parties have limited access to your information only to perform these tasks on Our behalf and are obligated to Us. The personnel of such third parties who use your personal information is limited to those individuals which are authorized to do so on a need-to-know basis and as necessary to provide these business services to Us. We do not authorize such third parties to disclose or use it for other purposes.  Please see Our List of Service Providers to learn more about the service providers We use and the services that they provide to Us.
  
• Public Authorities. We may disclose your personal information to public authorities or other third parties as necessary to comply with regulatory oversight of Our business; to protect Our own and others’ rights and property, including protection of Our affiliates, customers and members of the public; if mandated by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws. 
• Investment/Change of Control: We may also disclose your personal information to parties acquiring part or all of Our assets, as well as to attorneys and consultants. If  any bankruptcy or reorganization proceeding is brought by or against Us, your information may be considered a company asset that may be sold or transferred to third parties.

4. Cookies and Analytics. 

We use cookies or use similar technologies (hereinafter “cookies”) on this site.  Please view our Cookie Notice to understand how we use cookies on this site. We do not use automatic decision making or profiling.

5.  Data processing Outside of Your Country

In providing the Service, and the site, personal information may be transferred to, and processed in, countries where data protection and privacy regulations do not offer the same level of protection as Japan and other parts of the world:

Sharing personal information with Our affiliates as noted in Section 3 involves transfers outside Japan to the US to provide the Service (for example – to respond to your application enquiry).

Sharing personal information with Our service providers involves transfers to the US or India (for example database hosting and application processing).

6. Consent 

We may process your personal information based on your consent, where required by law (for example – for transfers of your personal information outside of Japan). If We request your consent, We will inform you of the purposes for which your information will be processed. Wherever We rely on your consent, you can always withdraw your consent at any time with effect for the future by contacting Us via any means. 

7. Your Choices and Rights

If you are a resident of certain countries, including but not limited to the European Economic Area, the United Kingdom, or Switzerland you have certain data protection rights, which may be limited by law.

You may request access to, modify, correct, delete or limit the use and disclosure, where required by applicable law, of your account information or close your account. You can also request additional information We may have about your account.

For Buyers Located in the European Economic Area, United Kingdom or Switzerland

General rights

You have the following rights with regard to the data processed by us: 

• The right of access to your personal data stored by us in accordance with Art. 15 GDPR;
• If necessary, the right to rectify incorrect or complete correct personal data stored by us in accordance with Art. 16 GDPR;
• the right to erasure (“right to be forgotten”) with regard to your personal data stored by us in accordance with Art. 17 GDPR;
• the right to restrict the processing of your personal data pursuant to Art. 18 GDPR;
• the right to data portability in accordance with Art. 20 GDPR;
• the right to object to the processing of your personal data pursuant to Art. 21 GDPR (see 4.2 immediately below);
• the right to revoke any consent granted pursuant to Art. 7 para. 3 GDPR;
• the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR.

Right of objection pursuant to Art. 21 GDPR.

You have the right, pursuant to Art. 21 GDPR, to object to the processing of your personal data by us or by a third party on the basis of a legitimate interest (in particular for the purposes of usage analysis and the needs-based design of the mobile app), insofar as there are reasons to do so which result from your particular situation. We no longer process the relevant personal data unless we can prove compelling grounds for processing worthy of protection which outweigh your affected interests, rights and freedoms, or if the processing serves the assertion, exercise or defense of legal claims.

You can exercise any of your rights by contacting Us via any means. In order to safeguard your personal information from unauthorized access, We may ask that you provide sufficient information to identify yourself prior to providing access to your personal information. 

In certain situations, and subject to applicable laws, including data protection laws, We may not be able or obliged to comply with all or part of your request. For example, We may not comply with an access request if doing so would reveal personal data about another person, or comply with a deletion request relating to information which We are required by law to keep or have compelling legitimate interests in keeping. 

If you have unresolved concerns, you have the right to complain to an EU data protection authority (‘supervisory authority’) where you live, work or where you believe a breach may have occurred.

Legal Basis We Rely On

We process information about you in regard to your New Buyer application where such processing is necessary for performance of a contract, or steps taken to enter into a contract, with you. Further, we may share information about you with your consent, where it is necessary to carry out the Service or as required by law, and We will always let you know when We make significant changes to this Privacy Notice. We protect your personal information and will only provide it to third parties: 

(1) with your consent on basis of Article 6 para. 1 sentence 1 lit. a GDPR;
(2) where it is necessary to carry out your instructions on basis of Article 6 para. 1 sentence 1 lit. b GDPR;
(3) as reasonably necessary in order to provide the Service on basis of Article 6 para. 1 sentence 1 lit. b GDPR;
(4) to Our service providers (as described in Section 3.2) in connection with providing the Service on basis of Article 6 para. 1 sentence 1 lit. b GDPR;(5) when We reasonably believe it is required by law, subpoena or other legal process on basis of Article 6 para. 1 sentence 1 lit. c GDPR;
(6) as necessary to enforce our Terms of Use, to protect the rights of the Company, or to prevent physical harm or financial loss on basis of Article 6 para. 1 sentence 1 lit. f GDPR; or
(7) as part of a reorganization or sale of all or part of Our business on basis of Article 6 para. 1 sentence 1 lit. f GDPR.

8. Links to other Websites

The site may contain links to other web sites that may have online information practices different from Ours. We are not responsible for the privacy and security practices of those websites, and We encourage you to learn about the privacy and security practices of those web sites if you choose to access and use them.

9. Data Retention

We keep your information for as long as your application is active and for up to 7 years from the initial submission of your application. In addition, We may keep certain information even after your application is processed  if it is necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this agreement.

10. Security Procedures

We have measures in place to restrict access to information to those employees and individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the personal information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide information collected through the Service to keep such information safeguarded and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.

11. Additional Notice for California Consumers

This section of our Privacy Notice applies to Consumers who reside in the State of California and is included to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  It applies to Our processing of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA (“Personal Information”).  

      - Information We Collect.  

We describe the Personal Information we have collected from consumers and the sources from which we collect this information, in the twelve (12) months preceding the effective date of this Privacy Notice, in the section of our Privacy Notice titled “What Information Do We Collect.” The information we collect includes the following:

Identifiers such as company name, first and last name, address, e-mail address, fax number and phone number, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number or other similar identifiers. 

Personal Records under Cal. Civil Code § 1798.80(e) such as name, signature, Social Security number, passport number, driver's license or state identification card number, physical characteristics, address, telephone number, insurance policy number, employment, employment history, bank account number, SWIFT code and other financial information. 

Characteristics of Protected Classifications under California or Federal Law such as age (40 years or older),  national ancestry, national origin, citizenship, gender, veteran or military status. 

Commercial Information such as customer account details, records of personal property, products or services purchased or obtained, transaction records. 

Internet and other Electronic Network Activity Information such as Internet Protocol address,  browser, devices and operating system types; device identifiers; and information regarding your internet service provider.

Geolocation Data such as data relating to your computer or device when you interact with the Services. 

Audio, Visual, or other Sensory Data including but not limited to customer submitted photographs. 

Professional or Employment-related Information such as current employment and employment history. 

Inferences from Personal Information Collected such as Inferences drawn from any of the information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behavior and abilities. 

For information regarding the purposes for which we collect and use the Personal Information we collect, please see “How Do We Use Your Information?”

We have disclosed Personal Information in all or substantially all of the categories identified in this Additional Notice for California Consumers for various business purposes. For more information about the categories of Personal Information we have disclosed, the categories of entities with which we have disclosed this information, and the purposes for which we have disclosed the information, please see “How We Share Your Personal Information.”

In the last 12 months we have not sold any Personal Information. 

We do not sell any Personal Information to third parties for a business or commercial purpose, and we have not sold any Personal Information to third parties for a business or commercial purpose within the past 12 months. Additionally, we do not sell the Personal Information of minors under the 16 years of age. 

       -Your Rights and Choices 

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise your rights.

Exercising CCPA Rights

To exercise the rights afforded to you under the CCPA, please submit a verifiable consumer request to us by either:

• Visiting https://www.assurant.com/dataprotection/consumer-page; or
• Calling us at 1-800-280-9577                                                         

Only you or a registered agent may make a verifiable consumer request related to your Personal Information. If applicable, you may also make a verifiable consumer request on behalf of your minor child.  You may only make a verifiable consumer request for access or disclosure twice within a 12-month period, and the request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  

In order to process your request safely and protect your Personal Information, it is required that you go through an identification verification process that will ask you for certain required information (including but not limited to your name, your date of birth, the last four digits of your SSN, your email address, your Assurant product, your address, your photo, and a copy of your photo ID). In the instance that your identification can not be verified, you will be contacted. We cannot respond to requests if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us.

Response Timing and Format 

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and the extension period in writing. Any disclosures we provide will only cover the 12-month period before the date the verifiable consumer request was received. If we cannot process your request, we will explain the reasons why we cannot comply with the request. All responses will provide your Personal Information in an easy to read format.

We will not charge a fee to process or respond to your request provided, however, in certain circumstances we may charge a fee if permitted under applicable law. 

Deletion Request Rights

You have the right to request that we delete Personal Information that we collected from you, subject to certain exceptions. Please note that even if you make a request to delete your Personal Information, applicable law may permit or require us to retain Personal Information that was collected to complete transactions and services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, to cooperate with law enforcement and for other legally permissible reasons. 

Right to Know About Personal Information Collected, Disclosed, or Sold

If we use your Personal Information for a business purpose or if we sell your Personal Information, you have the right to request the following to be disclosed: 

• The categories of Personal Information that the business collected about you;
• The categories of Personal Information that the business sold about you and the categories of third parties and/or service providers to whom the Personal Information was sold;
• The categories of Personal Information that the business disclosed about you for a business purpose.

Authorized Agent

Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require you to verify your own identity in response to a request even if you choose to use an agent. We may choose to deny a request from an agent that does not submit proof that they have been authorized by a consumer to act on their behalf.

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA rights. This means, unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services, or a different level or quality of goods or services.

12. Contact, Data Controller and Data Protection Officer

If you have questions or comments about this Privacy Notice, please contact Us online or by postal mail.

• For users within the Asia-Pacific region:
  

We welcome your questions or comments regarding this Notice. Please write to Us at for Assurant Japan KK, Data Protection Officer, Marunouchi Trust Tower Main Building, 10th Floor 1-8-3 Marunouchi, Chiyoda-ku Tokyo, 100-0005, Japan, and for TWG Japan, Data Protection Officer, Marunouchi Trust North Tower Building, 19th Floor 1-8-1 Marunouchi, Chiyoda-ku Tokyo, 100-0005, Japan or send Us an email at [email protected].

• For users within the United States, Latin America, Middle East and Africa:

We welcome your questions or comments regarding this Notice. Please write to Us at Assurant Privacy Office, 260 Interstate North Circle SE, Atlanta, Georgia 30339, USA or send Us an email at [email protected].

• For users within the European Economic Area, UK or Switzerland 

Assurant is the data controller of the personal information provided to or collected by the Hyla Mobile New Buyer Application site. Assurant has appointed an EU Data Protection Officer. Customers who feel that the rights afforded to them under the GDPR or applicable data protection law have been infringed, or that the data controller is processing personal information in contravention of the GDPR or applicable data protection law, may submit complaints or inquiries to: 

Data Protection Officer, Lifestyle Services Group Limited, Emerald Buildings, Westmere Drive, Crewe, Cheshire, CW1 6UN, United Kingdom, or send Us an email at [email protected].

You also have the right to file a complaint directly with the local Supervisory Authority, as relevant, under EU data protection law. 

13.  Changes to this Privacy Notice

We may update this Notice from time to time. As We may make changes to this Notice, We suggest that you review this Notice each time you access and use this site. Please review changes carefully. If any changes are made to this Privacy Notice, We will revise the Effective Date that is indicated on the Privacy Notice. 

Effective Date: September 30, 2022

List of Service Providers

This List of Service Providers identifies the third party service providers (who are not considered to be part of the Assurant group companies) We use in connection with the HYLA Mobile New Buyer Application site:

Cookie Notice

We use cookies and other online tracking devices (such as web beacons, action tags, Local Shared Objects (“Flash cookies”) and single-pixel gifs) all of which We refer to as “cookies” for the purposes of this cookie notice, to help Us recognize you, improve your experience, increase security and measure use and effectiveness of Our website.  Cookies are small text files that are placed on your computer by websites that you visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them). 

Improve User Experience

We use cookies and similar technologies, to help Us recognize you, improve your experience, increase security, and measure use and effectiveness of Our Services.  Long duration cookies may be used when accessing the website. These are pieces of information or data sent and stored to your browser or mobile device for record-keeping purposes. We use this information to analyze traffic patterns and improve the Service. If you prefer not to accept cookies into your browser, the help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, disabling cookies may result in certain parts of the website and resources not operating correctly or prevent you from taking full advantage of some of the features of the Service.  

Some browsers offer a “Do Not Track” (“DNT”) signal whereby you may indicate your preference regarding tracking and cross-site tracking. Although We do not currently employ technology that recognizes DNT signals, We will only process your Personal Information in accordance with this Notice. 

Analyze Website’s Performance

We collect Personal Information, on an individual and collective basis, to track and analyze preferences and trends, improve the quality of the Service,  evaluate functionality and services, and improve Our Service. We collect information when you use Our website, and may use third party analytics tools to evaluate user traffic.  For example, We collect log in information about devices used to access Our Service, including IP addresses.

What types of cookies are used on this website?

We use first party cookies on this Website.  The cookies used on Our website can be categorized in the following ways: 

• Strictly Necessary cookies: These cookies enable necessary functionality such as security, network management and accessibility. You may disable these cookies by changing your browser settings, but this may impact how the website works. 
• Performance cookies: These cookies collect information about how users use a website, for instance which pages users go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a user. The information these cookies collect is anonymous and only used to improve how a website works.
• Analytics cookies: These cookies collect and report information on how you use our website, and help us improve our Service. 

Some of Our Website pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow Us to count users who have visited these pages. Web beacons collect only limited information which including a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides. 

By using Our website, you acknowledge that We place these types of cookies on your device as set forth in this Cookie Notice.  The table below explains the types of cookies We use and why. 

How do I change my cookie settings?

If you prefer not to accept cookies into your browser, the help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, disabling cookies may result in certain parts of the website and resources not operating correctly or prevent you from taking full advantage of some of the features of the Service. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

The following links show how to disable cookies in different browsers:

• Setting cookie preferences in Internet Explorer
• Setting cookie preferences in Firefox
• Setting cookie preferences in Chrome
• Setting cookie preferences in Safari web and iOS.

This Cookie Notice should be read in conjunction with Our Privacy Notice If you have any questions or concerns about the Cookies Notice or its implementation you may contact Us at [email protected]. 

Effective date:  September 30, 2022