Who we are
National Australia Bank Group ("NAB Group") is an international financial services group that provides a comprehensive and integrated range of financial products and services. NAB Group's businesses are located in Australia, New Zealand, New York, United Kingdom, Hong Kong (SAR), Singapore and Japan. NAB Group also has a representative office in China and India. National Australia Bank Limited ("NAB") and its Tokyo Branch ("NAB Tokyo") each observe all relevant laws relating to customers' personal information.
At NAB Tokyo we will not use personal information for purposes other than intended purposes without the consent of the customer and will take personal data security measures and make every effort to prevent unauthorised disclosure of personal data. If we receive a complaint from a customer, we will take reasonable steps to resolve the situation at the earliest stage. We approach the protection of personal data fairly and in good faith.
Respecting Your Privacy
This notice applies to your dealings as our customer at NAB Tokyo. The confidentiality and privacy of your information is important to us. Depending on the type of customer you are, where you reside and how we store and process your information, you may be covered by Japanese laws regulating the confidentiality of your banking information and/or the Japan Personal Information Protection Act ("Japanese Act") and/or the Hong Kong Personal Data (Privacy Ordinance) and/or the Australian Privacy Act. If these laws do apply to you, then NAB complies with the relevant privacy principles those laws have established with respect to you and your personal information or personal data (collectively "personal data"). NAB also complies:
- with the Hong Kong Association of Banks Code of Banking Practice with regard to personal customers' dealings with our Hong Kong Branch; and
- with the Singapore Code of Consumer Banking Practice with regard to personal customers' dealings with our Singapore Branch.
These Codes contain standards of service and conduct relating to the use and disclosure of certain customer information.
Your Information
We and/or our officers, employees, contractors and agents collect information to assist us in our relationship with you. This information is collected from you, from the transactions performed on your behalf and/or from other persons and organisations. If you do not provide the information we need we may not be able to provide you with the product or service you have requested. We may also be required by law to collect information from or about you for certain purposes (for example, to identify you).
The types of information collected include but are not limited to:
- Information which identifies you;
- Information which relates to your financial affairs, business, employment, income or assets;
- Information which arises or is required in connection with the transactions you do with us or through us;
- Information which helps us to process applications made by you for particular products and services and to manage our exposures if you borrow funds from us or provide security;
- Information relevant to product development or marketing.
Obtaining Personal Information
NAB Tokyo will obtain personal information by fair and proper means.
Using & Disclosing Your Information
In this section:
"Services" means products, services and/or credit facilities provided by us to you from time to time including in connection with your use of accounts and facilities you have with us (including, without limitation, the making or receiving of a payment by us on your behalf).
"Regulation" or "Regulations" means any laws and policies including, without limitation, any subordinate instrument and the acts, practices and policies of local or foreign governments and their instrumentalities whether or not having the force of law.
A "Regulatory Authority" means a local or foreign government or instrumentality.
We and our officers, employees, contractors and agents(including third parties to whom NAB outsources the handling of all or any part of personal information), may collect, compile and/or use your information including any personal data (collectively "Data") and any information relating to your account, transactions or dealings with us or effected by us on your behalf or otherwise in relation to any of your accounts (collectively "Account Information") for the following purposes:
- opening accounts for all kinds of financial products and processing applications for financial products and services;
- checking a principal's identity under the Customer Due Diligence Law of Japan and the Foreign Exchange and Trade Law of Japan and checking whether the principal qualifies to use financial products or services;
- administering deposit transactions, loan transactions and periodic transactions;
- making decisions about loan applications and loan extensions;
- making decisions about the appropriateness of providing Services, such as in light of the principle of relevance under Japanese law;
- providing information to third parties to the extent required for NAB Tokyo's operations, such as providing personal information to authorised or affiliated persons or to credit reference agencies when engaging in the business of providing credit;
- providing information to third parties to the extent required for NAB Tokyo's operations, such as providing personal information to authorised or affiliated persons or to credit reference agencies when engaging in the business of providing credit;
- carrying out activities relating to the outsourcing of all or part of the processing of personal information;
- fulfilling obligations and exercising rights pursuant to contracts with the customer or laws;
- researching and developing Services such as by conducting market research and data analysis;
- sending out a variety of notifications about other available Services, such as by sending direct marketing communications;
- actioning transaction cancellations and follow-up management of transaction cancellations;
- processing customer transactions properly and efficiently;
- establishment and operation of the Services or in connection with administering any aspect of our relationship;
- management of local and global risk and credit exposures and/or establishing ongoing creditworthiness including conducting credit checks, assisting financial or other organizations to do so and/or providing banker's or credit references;
- matching for whatever purpose (whether or not with a view to taking any adverse action against you) any Data and/or Account Information with other data;
- involving the maintenance, review and development of our business systems, procedures and infrastructure including testing or upgrading our computer systems;
- involving our payment system including its interface or interaction with the payment systems of other financial institutions, merchants and payment organisations;
- designing financial services or related products;
- marketing, improving and/or furthering the provision of financial services or related products to you by us, or by our partners, contractors or third party service providers;
- determining the amount of indebtedness owed to or by you;
- enforcement of obligations including, without limitation, collection of amounts owed by you or by any other person providing security for your obligations;
- doing what is necessary to meet regulatory, compliance or legal obligations including making disclosure under the requirements of any Regulation or for any purpose which NAB reasonably considers necessary or desirable in connection with any Regulations or Services and you agree to provide all additional information required for such purpose;
- retaining your Data and Account Information in central databases (including those located overseas) for purposes including monitoring NAB or NAB Group's capital requirements and/or exposures and complying with Regulations;
- enabling those who may be interested in acquiring parts of our business or our rights or obligations in respect of you or your obligations to us, or the Services, to evaluate that business or those rights, obligations or Services;
- any other purposes agreed with you.
We and our officers, employees, contractors and agents may disclose, transfer (whether within or outside Japan), and/or exchange your Data and/or Account Information to or with such persons as we or they may consider necessary including the following persons for the purposes set out above, with your consent or in the manner permitted under applicable laws (such as the Japanese Act):
- any agent, contractor or service provider who provides operational, administrative, telecommunications, computer or, without limitation, other services to us in connection with the operation of our business;
- NAB's head office (Melbourne), any of its branches (such as NAB's Hong Kong branch) and any member of the NAB Group;
- credit reference agencies and/or, in the event of any default by you, debt collection agencies;
- any person (including all Regulatory Authorities or other banks whether within or outside the country in which you bank with us) when we reasonably consider that such disclosure is required by law or pursuant to the directives of such Regulatory Authorities or is necessary or desirable in connection with any Regulations or Services;
- any actual or proposed assignee of, or participant or sub-participant or transferee of, all or any part of our assets or business or our rights or obligations in respect of you or the Services;
- any person in connection with any bankruptcy proceeding, civil rehabilitation proceeding or other analogous proceeding relating to you and/or your property;
- any person whom we reasonably believe is entitled to your property in the event that you are a company that has been liquidated, struck off from any applicable register or otherwise no longer in existence or if you are a bankrupt;
- any person under a duty of confidentiality to us including without limitation any auditors, lawyers or other professional advisors;
- other banks or intermediaries or Regulatory Authorities involved in the process of sending or receiving any payment or instruction to or from or in connection with you;
- any person providing a guarantee or security in connection with your obligations; and/or without limitation
- any other person in accordance with our general policy on use and disclosure of Data and Account Information and/or as described in statements, circulars, notices or other terms and conditions made available by us to you from time to time.
We are managed, operate and process Data and Account Information internationally and across corporate boundaries and we have centralised certain of our processing and data storage functions in order to provide the Services to you efficiently at the time you need them. Your Data and Account Information may be processed and/or stored in Japan or in other countries in which we operate. Unless we can process and store your Data and Account Information at our central processing centres we are unable to handle your banking or other transactions. Under conditions of confidentiality, National Australia Bank Limited does the processing and storage of your Data and Account Information. At present, the centralised processing centres are located in Singapore, Hong Kong and Australia. Over time Australia will become the central location for processing and storage of your Data and Account Information. Our employees and contractors are subject to the applicable laws and Codes of Conduct which deal with the confidentiality and privacy of your Data and Account Information.
Handling of Sensitive Information
Pursuant to the Guideline for Protection of Personal Information in the Financial Sector (Financial Services Agency Announcement No.67 of 2004, "FSA Guideline"), NAB Tokyo will not collect, use or provide any third party with, your information regarding political views, religions (which means religions and religious thoughts and beliefs), participation in trade union, race and ethnicity, family origin and domicile, health, medical care and sexual preference, and criminal record ("Sensitive Information"), except in cases listed on the FSA Guideline. Further, as the purpose of use of Sensitive Information is limited under the Enforcement Regulation of the Banking Law of Japan (the "Ordinance"), NAB Tokyo will not use Sensitive Information other than in the cases permitted by the Ordinance.
Marketing Our Products and Services
You can tell us not to share your Data and Account Information within our group of companies for marketing purposes. It is your choice to tell us if you do not want us to market to you in any way or in a certain way, for example by telephone, but not by mail.
Your Rights
You may do the following things in respect of any of your Data and Account Information that is protected by the Japanese Act, the Hong Kong Personal Data (Privacy) Ordinance and/or the Australian Privacy Act:
- check whether we hold personal data about you and the right of access (with some exceptions) to such data;
- require us to correct any personal data relating to you which you establish is inaccurate;
- ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by us;
- ask us to cease to use or to erase personal data identifying you retained by NAB Tokyo on the basis that such personal data has been handled in violation of Article 16 or such personal data was acquired in violation of Article 17 of the Japanese Act. We will comply with any suchreasonable request (with some exceptions).
Any request to do or have done any one or more of the above things (which you may or may not be entitled to do, depending on who you are and in which country you deal with us) or to raise any concern you have regarding the privacy of your Data and Account Information should be made to us in writing and addressed to the Privacy Policy Inquiries Desk named below. We are entitled to charge a reasonable fee for fulfilling any data access request.
Certified Personal Information Protection Organization
NAB Tokyo. is a member of All Banks Personal Data Protection Council. The Personal Credit Information Center of All Banks Personal Data Protection Council accepts complaints and inquiries about the handling of personal information by its members.
Visit the All Banks Personal Data Protection Council at: http://www.abpdpc.gr.jp
For complaints and inquiries you can telephone 03-5222-1700 or visit the office of the Consumer Relations Office (ginko-torihiki -soudansho).
Customer Inquiries and Complaints
Direct all applications relating to the disclosure, correction, and discontinuation of the use of, personal information as well as any other questions about your personal information to the telephone number given below:
Privacy Policy Inquiries Desk:
Retail and Private Banking
National Australia Bank Limited, Tokyo Branch
2-1-1, Mitsui Nigokan, Nihonbashi Muromachi
Chuo-Ku, Tokyo 103-0022
Telephone: 03-3241-8975
Reception hours: 9:00a.m. to 5:00p.m.
(Excluding weekends and Japan bank holidays)
Modifications
The above information may be modified as a result of amendments to the law and other reasons. In that case, a notice will be posted at the NAB Tokyo branch in locations such as office information desks.
Modification on September 4 , 2006 (Descriptions of Certified Personal Information Protection Organization and Customer Inquiries and Complaints)
Modification on September 30, 2007 (Telephone number for Privacy Policy Inquiries Desk)
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