• • Privacy policy
• Acquisition and collection purpose about personal information
• Provision of personal information for third parties
• Name of an authorized personal information protection organization and contact information for solution of complaints
• Inquiries about complaints and consultation about personal information disclosure, correction, deletion etc.

TD SYNNEX Corporation
President Shigetaka Kunimochi

TD SYNNEX Corporation (hereinafter referred to as “TD SYNNEX”), a total distributor of IT products such as hardware and software, in consideration of the importance of personal information, TD SYNNEX establishes and implements a personal information protection management system and strive to comply with laws and regulations for personal information protection. TD SYNNEX ensures to implement the following items to strengthen trustworthy relationships with business partners and customers.

1. Comply with laws, regulations and guidelines

Regarding the handling of personal information including personal numbers and specific personal information, TD SYNNEX complies with the prescribed laws and regulations and the guidelines established by the government and the specified personal information protection committee, and other related standards. TD SYNNEX shall establish regulations on personal information protection and thoroughly handle personal information appropriately.

2. Appointment of a personal information protection supervisor and education

TD SYNNEX appoints a personal information protection supervisor to properly implement activities related to personal information protection and appropriately handles personal information. In addition, TD SYNNEX educates all our employees to properly handle personal information and supervise them properly.

3. Appropriate acquisition and utilization of personal information

When acquiring personal information from customers, joint guarantors, business partners, employees etc.either directly or indirectly TD SYNNEX manifests the purpose in advance, comply with relevant laws, regulations, and contracts, take measures to utilize the personal information only within the scope of the purpose, and also take measures to prevent them from leaking.

4. Limitation of disclosure and safety management

TD SYNNEX keeps personal information confidential, properly manage them so that TD SYNNEX do not exceed the approved scope of usage or requested scope based on laws and regulations, and stipulate preventive and corrective actions in its regulations against inappropriate usage, loss, destruction, falsification, leak and inappropriate access. When disclosing personal information to outside based on the approved scope of usage, TD SYNNEX monitor supervise the information being handled under the strict management.

5. Review and improve of outsourcing Regarding outsourcing

TD SYNNEX will thoroughly consider proper protection of personal information. When executing an outsourcing contract, TD SYNNEX shall evaluate and examine the eligibility as a partner of outsourcing and while also considering the protection of personal information about the contents of the contract.

6. Improvement of audit system

TD SYNNEX establishes internal audit system to properly manage personal information.

7. Inquiries, complaints and consultation

We set up a inquiry window to accept customer’s inquiries, complaints for consultation and respond appropriately.

8. Continuous improvement

TD SYNNEX always comprehend changes in laws and regulations, social norms and information technology, review the management system appropriately, and strives for the continousimprovement.

An inquiry window for any inquiries, complaints and consultation regarding handling of personal information

PMS (personal information protection management system) bureau

  　TEL 03-5665-8551　　FAX 03-5665-8530　　　E-mail：privacy@synnexinfotec.co.jp

Established: February 14, 2005
Revised: August 31, 2016

• TD SYNNEX comply with the personal information protection laws in terms of acquisition of personal information and use appropriate means for the acquisition.
• When it is necessary for us to acquire personal information directly from the parties themselves through writing or a website, TD SYNNEX will clarify the purpose of use in advance and collect the information with consent.
• TD SYNNEX may acquire personal information from the parties themselves in a way other than directly in writing, to the extent of the purpose of use announced below.
• Regarding our business and services, the purpose of using the personal information are as follows.

• Provision of information on products and services and sales suggestion
• Notifications of information to ECNex users etc., correspondence of products/services and other inquiries/requests etc.
• Products delivery
• Notifications of exhibitions, seminars, and other events as well as replies to the inquiries
• Clerical work such as billing, collection, payments
• Other clerical work, such as inquiries and response
• Creation of statistics documents
• Requests, contacts and responses concerning the investigation of the planning and use of products/services.
• Management of licensed products purchase procedures and license contract execution
• Inspection, maintenance, and repair
• RoHS investigation, material investigation, investigation on the status according to electrical appliances and material safety act, environment certificate, safety investigation export regulations investigation, investigation on agencies of designated chemical substance, various requests on investigation of unapplied/compliance certificates
• Performance of contracts (Sales transaction etc.)

• Notifications of exhibitions, seminars, and other events as well as replies to the inquiries
• Management of licensed products purchase procedures and license contract execution
• Confirmation of products maintenance
• Creation of statistics documents
• Contact, inquiries on products procurement etc.
• Performance of contracts (Sales transaction etc.)

• Registration to core systems
• Recruitment
• Other clerical work including contacts, inquiries and responses
• Safety management actions for prevention of disaster and crime
• RoHS investigation, material investigation, investigation on the status according to electrical appliances and material safety act, environment certificate, safety investigation export regulations investigation, investigation on agencies of designated chemical substance, requests on investigation of unapplied/compliance certificates
• Performance of contracts (Labor management, payment of salary, employee education etc.)

TD SYNNEX may provide the products purchaser’s personal information for the suppliers(outsourcers) for performance of the contract in relation to the sales transactions (products shipment, repair, aftersales support etc.).
Details are following.

1. Purpose (products shipment, repair, and after support)
2. Personal Information that are expected to be provided for third parties
   • 1) Purpose of provision of personal information to third parties such as identification, licensed contracts, products shipment, repair, maintenance, and after support etc.
   • 2) Items of personal information to be provided (name, address, telephone number, E-mail address, order information etc. of the products purchaser.
   • 3) Means or methods of providing personal information (Web order, FAX, e-mail delivery, mailing etc.)
   • 4) The type of organization and the attributes (vendor, software/hardware vendor, repairer, maintenance company etc.) of the parties receiving the information on providing the information.
   • 5) Contracts on handling personal information (Personal information protection and NDA execution)
3. Outsourcing of handling of personal information (TD SYNNEX may outsource handling of personal information to professional common carriers and repair companies for products shipment and data management.)
4. A liaison window for notification, disclosure, correction of purpose of use of personal information and addition, deletion/use or rejection of third party provision
   
   • A liaison window for inquiries
5. If there is a request from products purchased party themselves not to provide their information to third parties, TD SYNNEX will stop providing the personal information of the parties themselves to our vendors. However, please keep in mind that this may cause troubles to for product shipping.
6. Regarding acquisition of personal information by a method that the party themselves cannot easily recognize.
   TD SYNNEX do not acquire personal information by a method which cannot be easily recognized by the parties themselves.

TD SYNNEX may provide personal information to third parties as an exceptional measure in the following cases.

• a） When it is required by applicable laws
• b） When it is necessary to protect life, body and property of individual and it is difficult to obtain the consent from the person him or herself prior to the disclosure
• c） When it is required to enhance public hygiene or promote children’s sound growth and it is difficult to obtain the consent the person him or herself prior to the disclosure
• d） When it is necessary for cooperating with national authorities, local government or individual or business operator entrusted by either of the former two in executing the affaires stipulated by laws and regulations and which obtaining the consent of the person him/herself likely to impede the execution of the affairs concerned.

　JIPDEC

Contact information for solution of complaints

　JIPDEC

• • Address
    Roppongi First Building, 9-9 Roppongi 1-chome, Minato-ku Tokyo, 106-0032 Japan
  • Phone:
    03-5860-7565
    0120-700-779

(Web:http://www.jipdec.or.jp/protection_org/complaint_processing.html)

Inquiries about complaints and consultation about personal information disclosure, correction, deletion etc.

Request for disclosure, correction, deletion, use and stop provision

When requesting personal information disclosure, please download a request form of personal information disclosure, fill in the prescribed items and send the form by mail to a liaison window for complaints and consultation on personal information written above. Requests on personal information disclosure are accepted not only by principals but also by proxies.

• Note1. In order to confirm your identity, fill out our registration information (name, address, and contact information etc.) form or send us a copy of ID. When your proxy requests the disclosure, please provide a proxy statement and your ID.
• Note2. When you prefer a response by mail for the disclosure request, please enclose a stamp of fee of JPY600. When you request correction, addition, deletion suspension of provision to third parties, it is free of charge.