OCS is committed to maintaining a secure information environment for its customers.
Customers’ personal information is essential in order for us to provide fully satisfactory services.
We recognize the importance of the information received from our customers, and make efforts to take the utmost care in handling such information.
In order to have our customers utilize OCS with a sense of safety and trust, we educate our executives and employees
thoroughly about laws and company regulations related to personal information, and have established our company’s structure
to include measures for safety, thereby doing our utmost for appropriate management and use of each customer’s personal information.
Chapter 1. Handling of Personal Information by OCS
- Introduction
This Privacy Policy explains how and why the personal information of customers and other individuals obtained
by OCS America Inc. (“OCS”, “we”, “our” or “us”) is used.
Please read this Privacy Policy carefully before providing personal information to OCS or using our products or services.
Chapter 1 of this Privacy Policy provides an overview of how we use your personal information. Chapters 2, 3 and 4 provide
territory-specific information for customers in the European Economic Area /United Kingdom, the People’s Republic of China and
the State of California (U.S.A), respectively.
Additional policies may apply to certain OCS products or services, details of which will be provided alongside the terms of such service.
- Scope of application
The Privacy Policy will apply when customers and other individuals provide personal information to OCS or use OCS’s services and products.
- Purpose of using personal information
OCS utilizes personal information obtained from its customers for the following purposes:
- Acceptance of offer, provision and communication with respect to OCS’s services and products
- Guidance, provision, and management of other services and products offered by ANA
- All operations incidental or related to purposes (1) and (2) above
- Implementation of questionnaires concerning services and products, etc., offered by OCS
- Development of new services and products
- Guidance, operation, management and information provision for various events and campaigns
- Notification of services and products offered by OCS
- Guidance, operation, management and notification of services, products, events and campaigns
of ANA and ANA Group companies and partner companies
- Response to inquiries and requests
* In addition to the above-mentioned purposes, personal information will be utilized for the purposes described
in Chapter 1 Article 7 (Data sharing) below.
- Acquisition of personal information
OCS will obtain the following personal information by fair and appropriate means for the purpose of achieving the previously mentioned purposes.
- Identity, contact and payment information, etc.
The customer’s name, address, telephone number, fax number, email address, employment information (company name, division/department
the customer belongs to, title, address, telephone number, fax number), mailing address, payment information including details of
credit/debit card and other payment methods, etc.
- Details of enquiries and complaints to OCS
Details of enquiries, requests and complaints contained in correspondence with customers, (including their cause and resolution), etc.
* We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given
to us, for training purposes, for crime prevention and to improve the quality of our customer service.
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IT and system data, including about the usage of the OCS website and mobile application
Information on the use of OCS website and mobile application including cookie and action log on the website, etc.
OCS will never obtain and use information of a sensitive nature to the customer (hereinafter, “sensitive information”), such as information
on race, beliefs, social standing, history of illness, crime records, and history of having been afflicted by crime, unless required by laws
and regulations or by the consent of the customer.
- Choice by the customer
As a rule, OCS obtains personal information by the volition of the customer. Customers may experience disadvantages if they refuse to provide
their personal information, such as being unable to make use of the various services provided by OCS, or being unable to receive campaign notices
and other OCS information because a part of the functions of OCS’s system become inoperable and thereby unavailable.
Please note that customers may change their contact information as well as their decision on whether or not they wish to receive email
magazines at any time they wish, in a manner designated separately by OCS.
- Disclosure and provision of information to a third party
OCS will not disclose or provide personal customer information to any third parties except under the following circumstances.
Also, customers’ personal information including sensitive information will not be disclosed or provided to third parties under any circumstances,
unless allowed by laws and regulations or by consent of the customer. Note that provision of information to data sharing partners and business
entrusted companies are not deemed to constitute disclosure or provision to third parties.
- Customer consent has been obtained.
- Disclosure or provision is required within the scope allowed by laws or regulations.
- Disclosure is required to protect human life, health, or property in cases where obtaining customer consent is difficult.
- Disclosure is required to cooperate with the public affairs of national or local governments, and when obtaining customer
consent is likely to hinder the administration of public affairs.
- Disclosure or provision of information as statistical data (in a format that does not disclose the customer’s identity).
- Provision of information as a result of the succession of business due to a merger, company split, transfer of business or otherwise.
- (7) Provision of information in accordance to procedures based on laws and regulations, under the condition that the following
information can be easily checked by the customers themselves through the OCS website, etc., and that the customers have not declared
their wish to refuse provision of their information.
- The purpose of obtaining information is to provide such information to a third party
- Specific personal data items to be provided to a third party
- The means by which such personal information is provided to a third party
- Provisions of information will be suspended upon the customers’ request
- Methods for accepting requests from customers
- Data sharing
OCS may share customer information as follows.
Scope of entities that data can be shared
ANA Group companies
Purpose of use by the user
- For provision of air transportation services, travel services including tours and hotels, and other products/services handled by
OCS or companies that share data
- For sending of direct mail and information on products/services, and distribution of questionnaire(s) to customers, etc. by
OCS or companies that share data
- For sales Analysis, other research/studies, and development of new products/services, etc. by OCS or companies that share data
- For delivery and transfer of data when we receive inquiries, application for use or other offers from customers regarding products/services provided
by OCS or companies that share data
- For appropriate and smooth fulfillment of other transactions with customers by OCS or companies that share data
- For business management/internal management by the ANA Group
Items of personal information to be shared
The customer’s Customer number, the customer’s name, address, telephone number, fax number, email address,
employment information (company name, division/department the customer belongs to, title, address, telephone number, fax number),
mailing address, content of transactions, ANA Mileage Club membership number, payment information including details of credit/debit card
and other payment methods, details of enquiries, requests and complaints contained in correspondence with customers, information on the
use of OCS website and mobile application, including cookie and action log on the website, etc.
Party responsible for management of personal information
ANA Holdings Inc.
- Business entrustment
In providing products and services to customers, OCS may entrust a part of its business operations to third parties to which personal information
may also be disclosed to the extent required to achieve the purpose of the entrustment. In these cases, OCS will implement appropriate measures
in managing and supervising such third parties to safeguard the handling of customers’ personal information, including establishing agreements
on the handling of such personal information.
- Transfer to outside of Japan
If OCS provides customers’ personal information to third-party business operators outside of Japan, including business entrusted companies and
data sharing partners, OCS will take necessary and appropriate measures to comply with laws and regulations.
- Management of personal information
In receiving customers’ personal information, OCS will manage such information according to the strictest standards and take the utmost care
to prevent leaks, loss, or alterations. OCS ensures that the board members and employees are properly trained regarding appropriate handling
to safeguard the security of information identifying individual customers. An appropriate retention period for personal information will be
established in accordance with the purpose for which such information is used. After the purpose of the information has been achieved,
OCS will dispose of the information in question by appropriate methods.
- Request about handling of Personal Information
If OCS receives a request from a customer, submitted in the manner specified, for the disclosure, correction, deletion, addition, discontinuance,
or erasure (“disclosure, etc.”) of the customer’s personal information stored in a database held by OCS, the request will be handled according
to the laws and regulations as follows, within a reasonable timeframe and scope, after confirming that the request was submitted by the customer
themselves.
- Request for disclosure
Personal information items or purpose of usage will be disclosed in accordance with the customers’ request.
- Request for correction, deletion, or addition
Correction, deletion, or addition of personal information will be undertaken wherever possible after due review of the request.
- Request for discontinuance or erasure
The use of personal information items designated by the customer will be discontinued, and the relevant information erased if so desired,
in accordance with the submitted request. However, please note that such requests may prevent customers from being provided with services
that they had utilized, or may impede the provision of services in accordance to their wishes.
OCS may not be able to fulfill the customers’ requests if compliance with such requests would seriously impact OCS’s business operations, or result
in a violation of laws and regulations.
- Submission of request for disclosure, etc.
The method for submitting requests for disclosure, etc. or notification of purpose of use of personal information (“requests for disclosure, etc.”)
received by OCS from customers, and contact information are as follows.
Request for disclosure, etc.
- Method for submitting request
Please send the required documents by postal mail to the address below.
Address:
OCS America Inc.
22912 Lockness Avenue, Torrance, CA 90501
Attn: HR Department
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Required documents
Application form
Form requesting disclosure, etc.
Customer requests for disclosure, etc., may not be acknowledged if any of the required information is missing.
Documents required for confirmation of identification of individual, etc.
< For individuals >
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Copies of two from the following: driver’s license, passport, Green card, Social Security Card.
< For representatives >
In addition to “< For individuals >,” the following documents described in (1) and (2) are required.
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Power of Attorney (legal representatives must provide a certifying document)
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Documents to identify the representative (copies of two from the following: driver’s license, passport,
Green card, Social Security Card.
- Modification of the Privacy Policy
OCS may make modifications to this Privacy Policy. If modifications are made, details will be posted on the OCS website
(https://www.ocsworld.com)
Chapter 2. Handling of personal information of EEA and UK residents by OCS
- Introduction
This Chapter 2 provides additional information about the handling of personal information of customers and other individuals
in the European Economic Area (“EEA”) and/or the United Kingdom (“UK”) in accordance with EU General Data
Protection Regulation 2016/679 (“GDPR”) and the UK Data Protection Act 2018 (“DPA 2018”) and other national and international
data protection and privacy laws (together, “Data Protection Laws”).
Please note that the UK’s laws are similar to those in the EEA, and customers from both jurisdictions have very similar rights. Accordingly,
references to the GDPR in this Chapter should also be read as references to corresponding UK law.
A guardian’s consent or permission must be obtained in the event that a customer under the age of 16 uses OCS’s service and consents to this
Privacy Policy. The data subject’s consent to this Privacy Policy must be obtained in the event that a person such as family member apply for
OCS’s service on behalf of the data subject.
In the event that any provisions of this Chapter 2 contradict those of Chapter 1, the provisions of this Chapter 2 shall prevail.
- The controller of personal information
The controller of your personal information is OCS.
OCS protects personal information which is collected and used by controllers (who make decisions about how and why your personal
information is used) and processors (who act on the controller’s written instructions) on the basis of Data Protection Laws.
- Our lawful basis for processing personal information
OCS protects your personal information by ensuring that it can only be used to the extent necessary for specific purposes (as set out in
Part 3 of Chapter 1 of this Privacy Policy) and by requiring that there is a lawful basis for each processing activity
on the basis of Data Protection Laws.
OCS may process customer personal data on one or more of the following lawful bases:
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When your consent is obtained to the processing (Article 6(1)(a) GDPR)
Consent will usually only be relied upon for promotional and marketing related processing, or in some cases, in relation to
sensitive personal data.
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When processing is necessary in order to perform or take steps to enter into a contract (Article 6(1)(b) GDPR).
This is typically why we process customer information which is essential to providing our services, including a customer’s
identity, contact, payment and travel details, etc.
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OCS needs to process the information to comply with a lawful obligation (Article 6(1)(c)).
This includes the requirement to share personal information with customs and immigration authorities or law enforcement,
as well OCS’s legal duties towards its staff and customers.
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The information is required to protect your, or a third party’s, vital interests (Article 6(1)(d)), for example in the
event of a medical emergency.
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It is in OCS’s or a third party’s legitimate interests to process the personal data, and these interests are not overridden
by your rights under Data Protection Laws (Article 6(1)(f) GDPR). This includes the use of personal information necessary
to operate ANA’s business and also to maintain, develop and improve its products and services and provide the best possible
customer experience.
- Request about processing of personal information
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Data Protection Laws provide you with the following legal rights:
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Request for disclosure: You can request copies of your personal information and details of how we
process it.
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Request for correction or updating: Corrections or updates to personal information will be undertaken
wherever possible after due review of the request.
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Request for erasure: You may request that we delete all or part of the personal information we hold about you.
We will consider your request and, where the information is no longer required or the law does not permit us to continue to
retain it, we will delete it.
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Transferring your personal information: You can request a copy of your personal information in a structured,
common, machine-readable format. This only applies to personal information which we obtain from you and process on the basis
of your consent or in order to perform a contract, and which is processed by automated means.
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Objecting to processing: You can object to processing which is carried out on the basis of our or a third
party’s legitimate interests or for the purpose of direct marketing. We will stop processing your information unless we have
a strong reason to continue which overrides your objection. If your objection is to direct marketing, we will always stop.
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Restricting how your personal information is processed. You can limit how we process your personal information
in certain circumstances. Where this applies, any processing of your personal information (other than storing it) will only be
lawful with your consent or where required for legal claims, protecting certain rights or important public interest reasons.
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The right to withdraw consent. If we are relying on consent to process your personal information, you have the
right to withdraw that consent at any time.
Please note, the rights set out above are not absolute and do not apply in every situation. There are also legal exemptions which apply
in some situations and mean a request may be refused. Of course, if a request is refused we will inform you of the reasons for this when
we respond.
Records of requests made to us will be retained so that we can ensure we have complied with our legal obligations.
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Method for submitting request
You can exercise your rights free of charge (except in the case of unreasonable, excessive or repeated requests in which case we may
charge a fee or refuse the request). The method for submitting request and contact information are as follows.
Please send the required documents by postal mail to the address below.
Address:
OCS America Inc.
22912 Lockness Avenue, Torrance, CA 90501
Attn: HR Department
(Required documents)
Form requesting disclosure etc. (for EEA/UK residents).
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Responding to a request
We will respond without delay and usually within one month. We may, in some cases, ask for identification or (if you are making the
request on behalf of a third party) proof of your authority to submit a request. If your request is particularly complex or you have
made a number of requests, it may take longer to provide a detailed response. Please also bear in mind that there are exceptions to
the rights above and some situations where they do not apply.
If you are not satisfied with our response to a data protection request or if you think your personal information has been mishandled,
then you have the right to complain to a supervisory authority. Please see Part 9 of this Chapter 2 (“Lodging a complaint with an
authority”) for further details.
- Data sharing which is necessary to provide products or services
OCS’s products and services are provided with the assistance of other companies and organizations and often OCS will need to share personal
information with third parties in order to run its business. These third parties include:
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Other companies in the ANA Group
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Organizations with which OCS is legally required to share personal information including: government organizations, regulatory and
law enforcement authorities, judicial, customs and immigration authorities, third-party organization, etc.
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Service providers
including: subcontractor handling cargo, airlines, various service providers, providers with whom we have a marketing partnership, etc.
Where OCS instructs companies, contractors or service providers to process data on its behalf, then it will ensure that it does so pursuant to
a contract which meets the requirements of applicable Data Protection Laws.
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Marketing communications
OCS sends out marketing communications from time to time to notify interested persons of news and provide details of products and services
which may be of interest to them. OCS will only do this if the recipient has consented to receive marketing or if they are an existing customer
who purchased products or services from OCS and were given the opportunity to opt-out from marketing at the time but chose not to do so.
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Where your personal information is stored and transferred
OCS is located in United States of America and many of the service providers and other organizations with whom we share your personal information
will be located in jurisdictions outside the EEA and UK.
When transferring personal information to third parties OCS will ensure that it complies with the requirements of Data Protection Laws. However,
you should be aware that recipients outside the EEA and UK may be subject to national laws which do not necessarily provide equivalent protection
for your personal data. If you would like more information regarding where your personal information is stored and transferred please contact
OCS using the details set out in Part 12 of this Chapter 1 (“Submission of request for disclosure, etc.”).
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Retention of personal information
OCS retains customers’ personal information until the purpose of use is achieved. Particularly, OCS has set the retention period for personal
information as follows.
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Customer’s Personal information
Until completion of transportation and related services stipulated in Conditions of Carriage for International Baggage
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Other personal information
Required period for the purpose which customers have consented
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Lodging a complaint with an authority
Customers have the right to lodge a complaint on the processing of their personal information with the data protection authority having
jurisdiction over their residence.
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EEA residents: Please contact your national supervisory authority, details of which can be found on the European Data Protection
Board’s website (https://edpb.europa.eu/about-edpb/board/members_en)
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UK residents: Please contact the Information Commissioner’s Office (www.ico.org.uk)
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The contact information of the controller and OCS’s Data Protection Officer.
Controller: Overseas Courier Service Co., Ltd.
Address: 3-9-27 Tatsumi, Koto-ku, Tokyo, Japan
Chapter 3. Handling of personal information of China residents by OCS
Besides Chapter 1, Chapter 3 also shall be applied to the handling of personal information of persons residing in the People's Republic of
China (hereinafter, "China") based on China Cyber Security Law and related regulations. In the event that any provisions of this chapter
contradict those of chapter 1, the provisions of this chapter shall prevail.
- Introduction
A guardian's consent or permission must be obtained in the event that a customer under the age of 18 uses OCS's service and consents to
this Privacy Policy. The data subject's consent to this Privacy Policy must be obtained in the event that a person such as a family member
applies for OCS's service on behalf of the data subject.
- Retention period for personal information
OCS will retain the customer's personal information until the purpose of use is achieved. In particular, OCS sets the retention period for
personal information as follows.
- Customer’ personal information
Until the completion of transportation and related work stipulated in the Conditions of Carriage for International Baggage.
- Other personal information
Required period for the purpose which customers have consented.
- Technology and measure to protect customers’ personal information
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OCS takes security measures to protect customers' personal information from leakage, loss or damage. Specifically, OCS takes the
following measures to protect customers' personal information.
・ OCS develops website with https and sets SSL encryption to secure important customers' data (credit card information, etc.)
communication between the customers' web browser and the server.
・ OCS uses encryption technology for protecting personal information.
・ OCS sets access control for protecting unauthorized person from accessing personal information.
・ In order to raise employee awareness of the importance of protecting personal information, OCS provides education and training
on security and privacy protection.
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OCS will take all reasonable and practicable steps to ensure that no irrelevant personal information is collected. OCS will only
retain customers' personal information for the period of time required to achieve the purposes stated in this Privacy Policy,
unless an extension of the retention period is required or permitted by law.
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In the event of personal information being at risk, OCS will promptly inform customers of the relevant circumstances of the
incident in accordance with the requirements of laws and regulations and report to the regulatory authorities.
- Request about handling of Personal Information
In the event that OCS receives a request of the customer's personal information held by OCS from a resident of China, the request
will be handled according to the related laws and regulations within a reasonable timeframe and manners besides Chapter 1 Article 11
(Request about handling of Personal Information), after confirming that the request was submitted by the customer himself/herself.
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Request for withdrawal
Personal information will be deleted or suspended in accordance with the customer's request, wherever possible and appropriate,
after due review of the request.
However, please note that such requests may prevent customers from being provided with services that they had utilized, or may
impede the provision of services in accordance with their wishes.
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Methods for submission of requests
Customers may submit requests by following methods.
- Submission of requests
Please send the required documents by postal mail to the address below.
Address:
9F, Building 4, No.269 Tongxie Road, Changning District Shanghai
Postal Code: 200335
OCS (SHANGHAI) CO.,LTD.
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Required documents
Application form
Form requesting disclosure, etc. (for China residents)
Customer requests for disclosure, etc., may not be acknowledged if any of the required information is missing.
Documents required for confirmation of identification of individual, etc.
< For individuals >
(1) Copies of any two of the following: driver’s license, passport, health insurance certificate(masking insurance
card numbers and identification symbols / numbers of insured individuals), basic resident registration card with photo,
pension insurance booklet, physical disability certificate, resident card or special permanent resident certificate,
certificate of seal registration, Individual Number Card (front page only), identification card issued by the Chinese government
< For representatives >
In addition to “,” the following documents described in (1) and (2) below are required.
(1) Power of Attorney (legal representatives must provide a certifying document)
(2) Documents to identify the representative (copies of two from the following: the representative’s driver’s license, passport,
health insurance certificate(masking insurance card numbers and identification symbols / numbers of insured individuals),
basic resident registration card with photo, pension insurance booklet, physical disability certificate, resident card or
special permanent resident certificate, certificate of seal registration, Individual Number Card (front page only),
identification card issued by the Chinese government)
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Contact Desk
China 4008-82-8888 (Charged)
Email: privacy@ocschina.com
- Transfers
When OCS share personal information of customers or entrust it to third parties within the scope of the purposes of use, OCS may transfer
personal information to companies that can share data or entrustee(s) and such third parties will handle it. Third parties to whom OCS will
disclose the personal information of the customers include those located outside China, the customers shall be deemed as having consented to
the following matters by consenting to the Privacy Policy:
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In the case that the country which the third party is located outside China does not have the same data protection laws as China,
many of the rights provided in China to the data subjects will not necessarily be provided.
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The customers' personal information may be provided for the purposes specified above to the subsidiaries and affiliates of OCS or
third parties outside China.
- Change of purposes of use of personal data
In the case of a change to the purposes of use of personal information, OCS will announce the revised Privacy Policy in advance on OCS website
(www.ocsworld.com) and OCS will use personal information in accordance with the new purposes of use of personal information after obtaining
consent from customers.
- Basic information of Controller of personal information
OCS (SHANGHAI) CO., LTD.
Address: 9F,Building 4, No.269 Tongxie Road,Changning District Shanghai
Postal Code: 200335
Tel.: 4001-18-8588 (Person in charge of handling personal information)
Email: privacy@ocschina.com
Chapter 4. Handling of personal information of California residents by OCS
Last updated on December 1, 2022
Besides Chapter 1, Chapter 4 also shall be applied to the handling of personal information of persons residing in California, United States of
America based on the California Consumer Privacy Act of 2018 (hereinafter “CCPA”). In the event that any provisions of this chapter contradict
those of chapter 1, the provisions of this chapter shall prevail.
The terms used in this chapter are based on the definitions provided in CCPA. For example, the term “sale”, among others, means OCS’s selling,
lending, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic
or other means, a consumer’s personal information to another business or a third party for monetary or other valuable consideration. However,
if OCS concludes an appropriate agreement concerning the handling of personal information with another business or a third party, the activities
mentioned above are not regarded as “sale” from the perspective of CCPA.
- Acquisition and use of personal information
Personal information collected by OCS in the preceding 12 months or likely to be collected in the future is classified as defined in the
following table. OCS uses such information for the purposes set forth in Chapter 1, Article 3 (Purpose of using personal information).
It will acquire such personal information directly from customers.
| Type of personal information collected |
Example of personal information |
| Identifiers (name or symbol, etc. used to uniquely identify a particular subject) |
The customer’s name, address, telephone number, fax number, mailing address, email address, passport information, and ANA Mileage Club membership number, etc. |
| Additional data subject to the California Customer Records statute (personal information categories in Cal. Civ. Code Sec. 1798.80(e)) |
Credit card number and payment information including details of credit/debit card and other payment methods, etc. |
| Commercial information |
Credit card expiration date, usage history of credit card and related information, usage history of OCS services, details of purchase from OCS, details of enquiries, requests and complaints contained in correspondence with customers, etc. |
| Internet or other electronic network activity information. |
Information on the use of OCS website and mobile application including cookie and action log on the website, etc. |
| Professional or employment-related information |
Employment information (company name, division/department the customer belongs to, title, address, telephone number, fax number) and related information |
- The sharing of personal information
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Sale of personal information
OCS will not sell customers' personal information (including personal information concerning minors) to any third parties, and
has not sold the same in the past 12 months.
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Disclosure of personal information for business purposes
The types of customers’ personal information that OCS has disclosed in the past 12 months for business purposes and the types of
third parties to which such personal information has been disclosed are shown below.
- Request about handling of Personal Information
Customers living in California have the following rights concerning their personal information:
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Access right
Customers have the right to make a request to ANA for the disclosure of the following information regarding their personal
information collected/used/disclosed by OCS within the 12 months before the date of request (hereinafter “Access Right”),
up to twice in 12 months.
・ Type of the customer’s personal information collected by OCS
・ Source of the collection of such personal information
・ Business or commercial purposes for the collection of such personal information
・ Type of third party with which such personal information has been shared
・ The customer’s specific personal information collected by OCS
・ Type of the customer’s personal information disclosed by OCS for a business purpose
・ Type of third parties to which each type of such personal information has been disclosed
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Deletion right
Customers have the right to make a request to OCS for the deletion of their certain personal information collected by OCS
(hereinafter “Deletion Right”).
When exercising the Access Right or Deletion Right, please contact the following. Once OCS receives such a request, it will
be handled according to the related laws and regulations within a reasonable timeframe and manner, after confirming, through
the procedures for individual identification described below, that the request was submitted by the customer himself/herself.
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Submission of requests
OCS America Inc.
22912 Lockness Avenue, Torrance, CA 90501
Phone: 1-877-222-2627(Toll-free)
Email: info@ocsworld.com
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Procedures for individual identification
< For individuals >
Upon receiving a request for the exercise of the Access Right or Deletion Right, OCS will ask the customer to submit
information sufficient to confirm that such request was submitted by such customer himself/herself, such as his/her name
and email address, and compare the submitted information with the information held by OCS.
< For representatives >
In addition to the information required for the identification of individual in “<For individuals>,” a power
of attorney (legal representatives must provide a certifying document) needs to be submitted. In addition, OCS may ask
the customer to directly contact OCS to confirm that he/she has granted the representative authority to exercise the
Access Right or Deletion Right.
As a rule, OCS will not treat customers who have submitted such requests in a discriminatory manner, such as changing
their services. Even so, please note that deletion requests may prevent customers from receiving services which they
have been provided with, or may impede the provision of services that are in accordance with their needs.