Last Updated: April 1, 2024

AIG Japan Holdings Kabushiki Kaisha (“AIGJH” or “We”) is committed to protecting the privacy of the individuals we encounter in conducting our business. AIGJH appropriately handles Personal Information and Individual Number in compliance with Japanese Personal Information Protection Law, “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures” (Number Act) and other Personal Information protection related laws and regulations as well as takes appropriate security control measures considering the importance of Personal Information protection. We collect the Personal Information and Individual Number through proper and fair means to the extent necessary to conduct our operation.
We will handle Personal Information and Individual Number that we collect both through our website and through other means (for example, from telephone calls, e-mails and other communications with us), in accordance with this Privacy Policy. We will not use the Personal Information illegally or in such an inappropriate manner as prompting wrongful actions.

*Specific Personal Information means Personal Information that has Individual Number in its content.
*For the handling of Personal Information other than Specific Personal Information, please refer to “1. Handling of Personal Information” below.
*For Specific Personal Information, please refer to “2. Handling of Specific Personal Information” below.

1. Who To Contact About Your Personal Information

   If you have any questions about our handling of your Personal Information, Pseudonymously Processed Information and Anonymously Processed Information, please contact us at the following.

   [Contact information for inquiries]
   AIG Japan Holdings Kabushiki Kaisha
   Compliance Office
   Tel: 03-5400-4000
   Reception time: 9:00 a.m. - 5:00 p.m. except weekends, holidays and year-end and new year holidays

2. Personal Information That We Collect

   Depending on your relationship with us (for example, person relating to our business), your Personal Information that we collect may include: We may record, videotape or store information (including, but not limited to, audio and video) provided to us via telephone, email or another communication means.

   • General Personal Information
     Your name; address; telephone details and Email address, etc.

3. How We Use Personal Information (“Purpose of Utilization”)

   We use this Personal Information to:

   1. ①Business management, financial management and other business incidental thereto as follows;
      For example, we will do the following activities:

      • Verify identity;
      • Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks;
      • Comply with applicable laws and regulatory obligations, including laws outside your country of residence, such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence); and
      • Do any other activities ancillary to any of the above.

   2. ②Introduce information regarding a variety of products and services including those offered by AIG group companies in Japan and their affiliated companies, etc.
      For example, we will do the following activities:

      • Provide marketing information based on customer preferences (including information regarding other products and services offered by our third-party trading partners);
      • Change the screen display on our website by posting information and advertisement customized to each of our customers; and
      • Introduce a variety of campaigns, seminars, events, etc.

   3. ③Academic study/ research
      We shall make use of it in the following ways, for example;

      • Aggregate/ analyze the gathered information and utilize it for dissemination of information or in making proposals.

4. Provision of Personal Data to third party and acquisition thereof from third party

   1. ①AIGJH does not provide your Personal Data to third party except when;

      • You give consent;
      • We provide the data to our contractors (such as information vendors including entities located abroad) within the scope that is necessary to achieve the purpose of use; and
      • The AIGJH has to provide your Personal Information in accordance with laws and regulations, etc.

      *For details on the provision of Personal Data to a third party located abroad, see （８） Other important information below.

   2. ②Except as provided in laws and regulations,

      AIGJH will keep records on matters relating to the provision of Personal Data provided to a third party (what Personal Data provided, when, to whom and how it was provided, etc.), and will confirm and record matters relating to the acquisition of Personal Data (Incl. cases where Personally Referable Information was obtained as Personal Data) acquired from a third party (what Personal Information acquired, when, from whom and how it was acquired by the third party, etc.).

5. Sharing of Personal Data

   In the following cases, AIG group companies in Japan may share Personal Information. In these cases, each company shall manage your Personal Information with responsibility.

   1. ①AIG group companies in Japan

      We may share Personal Data with other AIG member companies in Japan.

      [Sharing of Personal Information in detail]
      Name, Address, Telephone number, E-mail address, etc.

      [Purpose of the sharing]

      • Notice and provision on product or service of the group companies
      • Enhancement of product and service
      • Other operation incidental to each AIGJH’s business

      [Companies which share the information]

      • AIG group companies in Japan
        Please refer the URL below.
        http://www-510.aig.co.jp/about-us/companies.html

   2. ②AIG group companies

      AIG group companies can have access to and use of Personal Information only when necessary to fulfill the management or internal control purpose as stated below.

      [Sharing of Personal Information in detail]
      Name, Address, Telephone number, E-mail address, etc.

      [Purpose of the sharing]
      To fulfill the internal control related necessity such as appropriate management, compliance, risk management and internal audit.

      [Companies which share the information]
      AIG, Inc. and its consolidated subsidiaries stated in the disclosed financial statements. *
      * consolidated subsidiaries: Please see Exhibit 21 of Form 10-K which is available via the website of the SEC.
      https://www.sec.gov/Archives/edgar/data/5272/000000527224000023/q42023exhibit21.htm

   3. ③The following company shall be the party responsible for the management of the sharing of the Personal Data with the AIG member companies.

      AIG Japan Holdings Kabushiki Kaisha
      Kamiyacho MT Building, 4-3-20 Toranomon, Minato-ku, Tokyo, 105-0001
      James Nash, President and CEO

      [AIG group]
      American International Group, Inc. (AIG) is a leading global insurance organization. AIG member companies provide insurance solutions that help businesses and individuals in approximately 70 countries and jurisdictions protect their assets and manage risks. For additional information, visit our website at www.AIG.com. AIG common stock is listed on the New York Stock Exchange.
      In Japan, AIG companies such as AIG General Insurance Company, Ltd., American Home Assurance Co., Ltd., JI Accident & Fire Insurance Co., Ltd., AIG Partners KK and Techmark Japan KK are providing their services.

6. Handling of Sensitive Information

   AIGJH does not acquire, use or provide to third parties sensitive information including special care-required personal information specified in the “Act on the Protection of Personal Information (Personal Information Protection Act),” “Guidelines for Protection of Personal Information in the Finance Sector,” and other relevant laws and regulations (hereinafter collectively referred to as the “Sensitive Information”), except in the following cases:

   1. ①Cases required based on laws and regulations, etc.
   2. ②Cases required for the protection of the life, body or property of individuals, and cases particularly required for the improvement of public health or promotion of sound development of children; and
   3. ③Cases required for the cooperation with government institutions or local public bodies or persons entrusted by the foregoing in performing their duties prescribed by the laws and regulations.

7. Security Management

   AIGJH takes appropriate measures to keep Personal Data of its customers up-to-date and accurate. We also take appropriate security control measures such as prevention of leakage, loss,　or damage etc. of the Personal Data, which are necessary to manage the Personal Data as well as regularly inspections on our in-house rules for handling it, organizational framework and employees and developing the training system for handling it. In addition, we have introduced mechanisms, etc. to prevent unauthorized access from outside, taking sufficient security measures.

   For details on our security management measures, for the personal data in our possession, please see “Security Control measures we take in handling Personal Data in possession.”

   Incidentally, if you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. (See the “Who to Contact About Your Personal Information” above Section (1).)

8. Other Important Information

   1. ①AIGJH takes reasonable steps to ensure that the Personal Information we handle is reliable for its Purpose of Utilization, and as accurate and complete as is necessary to carry out the purposes described in this Privacy Policy. AIGJH will retain Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
   2. ②When AIGJH provides Personal Data　(including Personal Information planned to be handled as Personal Data. The same applies hereinafter.) to a consignee in accordance with outsourcing contract, the consignee will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Data. Any service provider that handles Personal Data on behalf of AIGJH is expected to use the strict security standards. In the event of incident, if any, concerning Personal Data, AIGJH will respond expeditiously and appropriately. In addition, we will regularly make necessary and appropriate inspections on the entrusted service provider including inspections on their supervision on subcontractors, etc. to check if it’s carried out sufficiently, in the case of multi-tiered entrusting.
      For example, we entrust the handling of the Personal Data in such cases as follows:
      
      • Activities related to the development, maintenance and operation of the information system
   3. ③Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries. We may transfer information internationally to AIG group companies, consignees, business partners and governmental or public authorities.
   4. ④In the event we provide any Personal Information to a third party (except for parties that have established a system conforming to the standards prescribed in the Rules for Personal Information Protection Committee regarding the handling of Personal Data) which is located in a foreign country (except for foreign countries which are specified in the Rules for Personal Information Protection Committee as having such a system for the protection of Personal Information as is considered to be on the same level as the system in Japan for protecting the rights and interests of individuals), we obtain from the principal an agreement that it acknowledges the provision of such information or an agreement that we provide such information in accordance with the relevant provisions of this Privacy Policy, with the exception of cases prescribed in each item of Article 27, paragraph 1 of the Personal Information Protection Act. Provision of Personal Information by AIGJH to an operating entity in a foreign country which is assumed in this Privacy Policy includes the following:
      
      • Information provision upon obtaining a principal’s consent.
        

        Reasons for provision	When providing personal data to academic institutes in foreign country for the purpose of academic study/ research
        Names of the countries in which the parties to which the data is provided are located	USA
        Whether the party to which the data is provided has the personal information protection system in place	https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america/

      • Following is an example of possible case of Personal Data provision to a third party in foreign countries from insurance companies under AIG Group in Japan.
        

        Reasons for provision	Provision of personal data in association with the ceding to a reinsurance company in a foreign country
        Names of the countries in which the parties to which the data is provided are located	USA (Because reinsurance company shall be determined from the viewpoint of diversifying risks in underwriting insurance, the final destination country of the data transfer may not be specified at the time of underwriting or consent)
        Whether the party to which the data is provided has the personal information protection system in place	https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america/

      • Provision of Personal Data to a consignee in a foreign country relating to an outsourcing contract; and
        

        Major activities commissioned	Development, maintenance and operation of systems
        Names of the countries in which the parties to which the data is provided are located	USA

      • Use of Personal Data jointly with AIG group companies abroad.
        See (5) “Sharing of Personal Data” above for details.

9. Continuing Improvement Concerning Handling of Personal Information

   AIGJH reviews periodically our handling of Personal Information and continues to make efforts for better handling of Personal Information.

   When content of this privacy policy is revised, the revision will be notified promptly or publicized in our website.

10. Request to Notify, Disclose, Correct and Cease Using etc, with respect to Personal Data

    • When AIGJH is requested to notify, disclose, or correct, etc. (i.e. correct, make addition, delete), or cease using, etc. (i.e. cease using, erase) of your Personal Data, AIGJH, upon identification of yourself, will respond to such request to the extent it does not hamper AIGJH business. If AIGJH is not able to respond, it will provide you with the reason. AIGJH may charge you its prescribed service fee for your request for notification and request for disclosure of the purpose of use.
    • Please refer to “(1) Who To Contact About your Personal Information” about specific procedures for such request.

11. Other Information We Collect Through Our Website

    “Other Information” is any information that does not reveal your specific identity, such as:

    • Browser information;
    • Information collected through cookies, pixel tags and other technologies;
    • Demographic statistics information and other information provided by you; and
    • Aggregated information

12. Other Information We Will Collect

    We and our third-party consignees may collect other Information in a variety of ways, including:

    1. ①Through your internet browser:

       Certain information is collected by most websites, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, time of the visit and the page(s) visited. We use this information for purposes such as calculating our website usage levels, helping diagnose server problems, and administering our website.

    2. ②Using cookies:

       Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to recognize your computer and to collect information such as internet browser type, time spent on our website, pages visited, language preferences. We may use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while visiting our website, or to gather statistical information about the usage of our website. Cookies do not include contact information on any customer.
       Cookies further allow us to present to you the advertisements or offers that are most likely to appeal to you. We may also use cookies to track your responses to our advertisements and we may use cookies or other files to track your use of other websites.
       You can refuse to accept other cookies we use by adjusting your browser settings.
       However, if you do not accept these cookies, you may experience some inconvenience in your use of our website and some online products.

    3. ③Using pixel tags, web beacons, clear GIFs or other similar technologies:

       These may be used in connection with some website pages and HTML-formatted e-mail messages to, among other things, track the actions of our website users and e-mail recipients, measure the success of our marketing campaigns and compile statistics about our website usage and response rates.
       We use Adobe’s Omniture analytics service, which uses cookies and web beacons to help us understand more about how our website is used by consumers so we can continue to improve it.

    4. ④From you:

       Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you.

    5. ⑤By aggregating information:

       We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).

    Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “(12) Other Information We Collect” section of this provision, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

13. Handling of the Personally Referable Information

    We define as the Personally Referable Information the information that does not fall under any of Personal Information, Pseudonymously Processed Information, or Anonymously Processed Information among the information, etc. set forth in above mentioned “(11) Other Information We Collect Through Our Website” with which the relevant person cannot be identified.
    We may provide the Personally Referable Information to a third party; however, if it is considered the third party receiving the information will obtain it as the Personal Data, we will not provide it to that third party without obtaining principal’s consent.
    In addition, in the case that we receive the Personally Referable Information, we also will not do so without the principal’s consent if we intend to obtain it as the personal data.

14. Handling of Pseudonymously Processed Information

    1. ①Preparation of Pseudonymously Processed Information

       We will take the following actions when we prepare Pseudonymously Processed Information (meaning information relating to an individual which is processed by taking measures specified in laws and regulations so that individual cannot be identified unless reconciled with other information):

       • To process the information in an appropriate manner in accordance with the standards prescribed in the laws and regulations;
       • To take security control measures to prevent the leakage of information, including the information about deletion related to the Pseudonymously Processed Information, in accordance with the standards stipulated in laws and regulations; and
       • To publicize the purpose of use of the Pseudonymously Processed Information prepared.

    2. ②Provision of Pseudonymously Processed Information

       We may provide the Pseudonymously Processed Information prepared to our third-party service provider and our partner which will share said information.

15. Handling of Anonymously Processed Information

    1. ①Preparation of Anonymously Processed Information

       AIGJH will take the following actions when it prepares Anonymously Processed Information (information relating to an individual that can be produced from processing Personal Information so as neither to be able to identify a specific individual by taking action prescribed in the laws and regulations nor to be able to restore the Personal Information):

       • To process the information in an appropriate manner in accordance with the standards prescribed in the laws and regulations;
       • To take security control measures for preventing any leakage of deleted information and method of processing, in accordance with the standards prescribed in the laws and regulations;
       • To publicize the purpose of use of the Anonymously Processed Information prepared;
       • To publicize the items of information contained in the Anonymously Processed Information; and
       • Not to do any acts for identifying the individual of Personal Information which was used as the source of preparation.

    2. ②Provision of Anonymously Processed Information

       In providing the Anonymously Processed Information to a third party, AIGJH will publicize the item of information which is contained in the Anonymously Processed Information to be provided and the method of provision, as well as clearly indicate that the information provided to the said third party is the Anonymously Processed Information.

1. Appropriate Collection of Specific Personal Information

   AIGJH will collect your Specific Personal Information through legal and fair means. Unless stated by the laws and regulations, AIGJH will not request you to provide us your Specific Personal Information.

2. Handling and Scope of Use (Purpose of Use) of Specific Personal Information

   AIGJH will handle your Specific Personal Information which we collect, only to the extent limited by the laws and regulations and to the extent of the following purposes of use which are prescribed by AIGJH. AIGJH will not collect Specific Personal Information beyond the said scope or provide it to a third party except as permitted by the laws and regulations:

   1. ①Purpose of use

      AIGJH will use the Specific Personal Information which we collect, for the purpose of conducting the following business operations which are prescribed by the laws and regulations:

      • Preparation of the report on payment of remuneration/fees, etc., real estate rentals, and consideration for purchase of real estate, etc.

   2. ①Exceptions

      AIGJH may also use the Specific Personal Information in the following case based on the laws and regulations:

      • If required for the protection of the life, body or property of an individual, and if there is agreement of the individual or it is difficult to obtain the agreement of the individual

3. Other Matters

   In addition, the above Sections 2.(1) and 2.(2), Sections 1. (1), 1.(7), 1.(8)①・②, 1.(9) and 1.(10) will be applied mutatis mutandis to the handling of Specific Personal Information.

1. Third Party Websites

   This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which our website contains a link. The inclusion of a link on our website does not imply endorsement of the linked site by us or by our group companies.

2. Changes to This Privacy Policy

   We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.

AIG Japan Holdings Kabushiki Kaisha
Kamiyacho MT Building, 4-3-20 Toranomon, Minato-ku, Tokyo, 105-0001
James Nash, President and CEO