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In view of the importance of protecting personal information and to further enhance customer trust in the insurance business, we comply with the Act on the Protection of Personal Information (Personal Information Protection Act), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (My Number Act), other relevant laws and regulations, guidelines from relevant government agencies, and guidelines for the proper handling of specific personal information, and strictly and appropriately handle personal information while taking appropriate security management measures.

We thoroughly educate and guide our employees to ensure proper handling of personal information, and respond promptly to complaints and consultations regarding the handling of personal information. We also review and improve appropriate measures related to our handling of personal information and security management as needed.

1. Acquisition and Use of Personal Information

We acquire and use personal information within the scope necessary for business operations and by lawful and fair means.
(Excluding individual numbers and specific personal information described in section 7 below.)

2. Purpose of Use of Personal Information

We receive consignment of insurance business from insurance companies and use the acquired personal information (for individual numbers and specific personal information, please see section 7 below) within the scope necessary to perform such business.
We have transactions with multiple insurance companies, and may use the acquired personal information to propose products and services of insurance companies with which we have transactions.
Additionally, we operate an automobile sales business and use the acquired personal information within the scope necessary to perform such business.
The specific purposes of use of personal information by our company are as follows, and we will not use it for any other purposes.

• Provision of automobile sales business and related services
• Provision of non-life insurance, life insurance and related services handled by our company

Changes to the above purposes of use will be made within a reasonably recognized scope as having considerable relevance. When making changes, we will notify the individual in principle by written document (including electromagnetic records; the same applies hereinafter) or publish on our company's website.
The purposes of use by insurance companies that consign insurance business to our company are stated on the insurance companies' websites (below).

[Insurance Companies with which we have Transactions]

＜Non-Life Insurance Companies＞

• ■　Mitsui Sumitomo Insurance Co., Ltd.（https://www.ms-ins.com）
• ■　Sompo Japan Insurance Inc.（https://www.sompo-japan.co.jp/）
• ■　Tokio Marine & Nichido Fire Insurance Co., Ltd.（https://www.tokiomarine-nichido.co.jp）

＜Life Insurance Companies＞

• ■　Mitsui Sumitomo Aioi Life Insurance Company, Limited（https://www.msa-life.co.jp）

3. Security Management Measures for Personal Data

To prevent leakage, loss or damage of personal data (including individual numbers and specific personal information described in section 7 below) that we handle, and for other security management of personal data, we implement sufficient security measures such as establishing handling regulations related to security management and implementation systems, and take appropriate measures to ensure accuracy and currency necessary to achieve the purpose of use. In the unlikely event that a problem occurs, we will promptly take appropriate corrective measures.

We have separately established internal regulations regarding security management measures for personal data, the specific contents of which are mainly as follows. For questions regarding security management measures, please contact the inquiry counter in section 10 below.

(1) Establishment of Basic Policy

To ensure proper handling of personal data, we have formulated this basic policy regarding 'compliance with relevant laws and guidelines', 'matters related to security management measures', 'windows for questions and complaint handling', etc., and review it as necessary.

(2) Establishment of Handling Regulations for Security Management of Personal Data

We have established regulations on handling methods, responsible persons/personnel and their duties, etc., for each stage of acquisition, use, storage, provision, deletion/disposal, etc., and review them as necessary.

(3) Organizational Security Management Measures

• Establishment of personal data management supervisors, etc.
• Establishment of security management measures in employment regulations, etc.
• Operation in accordance with handling regulations for security management of personal data
• Establishment of means to confirm the handling status of personal data
• Establishment and implementation of inspection and audit systems for the handling status of personal data
• Establishment of systems to respond to leakage incidents, etc.

(4) Human Resource Security Management Measures

• Conclusion of non-disclosure agreements for personal data with employees
• Clarification of employees' roles and responsibilities
• Thorough dissemination, education and training of security management measures to employees
• Confirmation of compliance status with personal data management procedures by employees

(5) Physical Security Management Measures

• Management of personal data handling areas, etc.
• Prevention of theft of equipment and electronic media
• Prevention of leakage when carrying electronic media
• Deletion of personal data and disposal of equipment and electronic media

(6) Technical Security Management Measures

• Identification and authentication of personal data users
• Setting management divisions for personal data and access control
• Management of access rights to personal data
• Measures to prevent leakage and damage of personal data
• Recording and analysis of access to personal data
• Recording and analysis of operating status of information systems handling personal data
• Monitoring and auditing of information systems handling personal data

(7) Supervision of Contractors

When consigning the handling of personal data, we select those who handle personal data appropriately, and to ensure implementation of security management measures at contractors, we have established handling regulations for external consignment and review them periodically.

(8) Understanding of Foreign Environments

We implement security management measures based on understanding the systems related to the protection of personal information in countries where personal data is handled.

4. Provision of Personal Data to Third Parties and Acquisition from Third Parties

(1) We will not provide personal data (for individual numbers and specific personal information, please see section 7 below) to third parties without prior consent of the individual, except in the following cases:

• ① When based on laws and regulations
• ② When necessary for the protection of a person's life, body or property and it is difficult to obtain the consent of the individual.
• ③ When particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the individual.
• ④ When cooperation is necessary for a national agency, local government, or a person entrusted by them to perform affairs prescribed by laws and regulations, and obtaining consent from the individual would hinder the performance of such affairs.
• ⑤ When the third party is an academic research institution, etc., and the third party needs to handle the personal data for academic research purposes (including cases where part of the purpose of handling the personal data is for academic research purposes, excluding cases where there is a risk of unjustly harming individual rights and interests).

(2) When personal data is provided to third parties or acquired from third parties (including cases where personally related information is acquired as personal data), we confirm the details of provision/acquisition and record and store matters prescribed by law such as the names of recipients/providers.

5. Provision of Personally Related Information to Third Parties

(1) Except as prescribed by law, when it is anticipated that a third party will acquire personally related information as personal data, we will not provide such information without confirming that the third party has obtained consent from the individual of the personally related information to acquire such information.

(2) Except as prescribed by law, when we provide personally related information to third parties based on the confirmation in the preceding paragraph, we confirm and record matters related to such provision (when, to what kind of recipients, what kind of personally related information was provided, how the third party obtained consent from the individual, etc.).

6. Handling of Sensitive Information

Regarding specially required personal information (including race, creed, social status, medical history, criminal records and history, crime victim information, etc.) and personal information related to labor union membership, family origin and registered domicile, healthcare and sex life (sensitive information), we will not acquire, use or provide to third parties in principle, except in the following cases:

• (1) When based on laws and regulations, etc.
• (2) When necessary for the protection of a person's life, body or property
• (3) When particularly necessary for improving public health or promoting the sound growth of children
• (4) When cooperation is necessary for a national agency, local government, or a person entrusted by them to perform affairs prescribed by laws and regulations
• (5) When acquiring, using or providing sensitive information of employees, etc. regarding affiliation or membership in political/religious organizations or labor unions within the scope necessary to perform insurance premium collection operations, etc.
• (6) When acquiring, using or providing sensitive information to the extent necessary to perform insurance payment operations involving inheritance procedures, etc.
• (7) When acquiring, using or providing sensitive information within the scope necessary for business operations based on the consent of the individual due to the necessity of ensuring appropriate business operations of the insurance business

7. Handling of Individual Numbers and Specific Personal Information

We will not acquire or use individual numbers and specific personal information for purposes other than those specifically stated in laws and regulations. Additionally, we will not provide individual numbers and specific personal information to third parties except in cases specifically stated in the My Number Act.

8. Acquisition, Use and Provision of Information Linked to Identifiers such as Cookies

Cookies are text-format information stored in a web browser sent from a website when browsing the website. Web beacons are a mechanism that sends information when a customer views a page or email by embedding small images in web pages or emails. This website stores and uses customer information using cookies, web beacons or similar technologies (hereinafter referred to as 'Cookies, etc.').

We use Google Analytics provided by Google LLC as a service that can statistically collect and analyze identifiers stored in Cookies, etc. For information collection and handling by Google Analytics cookies and the privacy policy of services provided by Google, please check the sites below.

Additionally, customers can opt out of Google Analytics using the browser add-on for opting out.

■ Google Analytics

Information collection and handling by cookies in services provided by Google
（https://policies.google.com/technologies/partner-sites?hl=en）

Google Privacy Policy
（https://policies.google.com/privacy?hl=en）

Opt out of Google Analytics
（https://tools.google.com/dlpage/gaoptout）

9. Disclosure, Correction, Suspension of Use, etc. of Retained Personal Data Based on the Personal Information Protection Act

Regarding requests for disclosure (including disclosure of confirmations and records), correction or suspension of use, etc. of retained personal data (including individual numbers and specific personal information in section 7 above) based on the Personal Information Protection Act, we will process procedures after confirming that the requester is the individual. We will refer to the relevant company for retained personal data of insurance companies and other companies. If, as a result of necessary investigations into our company's retained personal data, information about the individual is inaccurate, we will change it to accurate information based on the results.

Please note that a prescribed fee will be charged for the above disclosure procedures. If you wish to process the procedures, please contact the inquiry counter below.

10. Notes Regarding Inquiries

In order to properly understand and smoothly respond to your inquiry, we may verify the information you have provided.

Please be advised that we reserve the right to decline responses to inquiries that contain false or malicious content and disrupt our business operations or work environment. We appreciate your understanding.

11. Contact Information

Website Inquiry Counter

TOHO Automobile Co., Ltd. Kansai Branch Public Relations Division, Contact: Shinohara
TEL 06-6652-2405

Personal Information Handling Inquiry Counter

TOHO Holdings Co., Ltd. General Affairs Division
TEL 06-6452-0785

Japan Automobile Dealers Association (Certified Personal Information Protection Organization) Consumer Consultation Office
TEL 03-5733-3105

Revised November 1, 2025

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