Privacy Policy and Consent (Sydney)

Last updated: 2 August 2023

About this Privacy Policy

Japan Bank for International Cooperation (ABN 42 268 873 941) (hereinafter "JBIC") recognises the importance of your personal information and privacy, and believes that it is our duty to properly manage and protect your personal information.

With a view to protecting your personal information, JBIC will conduct its operations in Australia in a manner whereby JBIC complies with the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) (the “Privacy Act”), by which JBIC is bound.

The purpose of this privacy policy (“Privacy Policy”) is to inform you about the way in which JBIC collects, uses, holds and discloses your personal information in Australia when JBIC conducts its operations, as well as when you interact with JBIC. It also sets out your rights and what you can do to control your personal information and protect your privacy in Australia.

About JBIC

JBIC is a policy-based financial institution incorporated in Japan under the Japan Bank for International Cooperation Act 2011 (with Corporate Number 0100-01-145977 and ARBN 643 848 524) and is wholly owned by the Government of Japan. 

JBIC’s registered office address is 4-1, Ohtemachi 1-chome, Chiyoda-ku, Tokyo 100-8144, Japan and its representative office address in Australia is Suite 4102, Level 41, Gateway Tower, 1 Macquarie Place, Sydney NSW 2000 Australia. 

Your Consent

You consent to your personal information being used in accordance with this Privacy Policy if you undertake any one or more of the following activities in Australia:

• a. providing JBIC with your personal information for any reason; or
• b. participating in, or submitting, an online enquiry to JBIC via email or through the JBIC website <https://www.jbic.go.jp/><https://www.jbic.go.jp/en/> (“Website”).

What personal information does JBIC collect about you?

Personal information

“Personal information” as this term is defined in the Privacy Act, means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. Any time the term “personal information” is used in this Privacy Policy, JBIC is referring to this legal definition of the term. Personal information includes information that could identify you either directly (e.g. your name) or indirectly (e.g. your IP address). 

The personal information JBIC collects in Australia depends upon your dealings with JBIC and the particular purpose that is being fulfilled. JBIC’s collection of personal information in Australia is limited to what is relevant and reasonably necessary for us to perform one or more of our functions or activities.

Depending on the personal information you provide or share with JBIC in Australia, the personal information JBIC collects about you may include:

• a. personal identifiers such as your name and date of birth;
• b. contact details such as work email addresses, telephone numbers, fax numbers;
• c. information relating to your work, including company name, company address, department, title, work history;
• d. other information such as educational background and qualifications;
• e. photographs; and
• f. financial details such as your bank account number and information about your transactions and payment with JBIC. 

Sensitive information

Under certain circumstances, JBIC may need to collect “sensitive information” about you. Sensitive information is a subset of personal information, and is generally afforded a higher level of privacy protection under the Privacy Act. Sensitive information might include any information or opinion about your racial or ethnic origin, political opinions, political association, religious or philosophical beliefs, membership of a trade union or other professional body, sexual preferences, criminal record, or health information.

If JBIC collects your sensitive information, for example health information included in your job application during any recruitment process, JBIC will do so only with your consent, or where JBIC is otherwise required or authorised by law. JBIC will take appropriate measures to protect the security of this information.

Other, indirect information we may collect about you:

The types of indirect personal information JBIC may collect about you include:

• a. information that you provide third parties and reasonably expect that information to be provided to us; and
• b. details of your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour (including through cookies or tracking technologies).

We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to feedback surveys or aggregated information about how our Website is used.

How does JBIC collect your personal information?

JBIC will collect your personal information in Australia through proper and lawful means. When JBIC collects your personal information (including sensitive information), JBIC will notify you of the purposes for the collection, use, and / or disclosure that are within the necessary scope of JBIC's operations, and obtain your consent to collect, use and / or disclose your personal information.

Information JBIC collects from you

Generally, the main way JBIC collects personal information about you is when you directly give it to JBIC. As part of JBIC’s relationship and dealings with you, JBIC will collect your personal information through the following touchpoints:

• a. when you contact JBIC;
• b. when you use or enquire about JBIC’s products or services; 
• c. when you provide business cards to JBIC;
• d. when you enter into a contract with JBIC; and
• e. when you engage with JBIC in any other way.

Where certain personal information is essential to JBIC to perform its services, this will be indicated at the time this personal information is collected (for example, indicated by an asterisk in an information collection form). If you do not provide this essential information, this may affect the services that JBIC can provide to you. Other personal information requested may be optional and allows JBIC to get to know you better and to improve JBIC’s communications and services to you.

Information JBIC collects from other sources

JBIC may also collect your personal information from other sources including publicly available sources or from third parties, such as:

• a. recruitment agencies;
• b. referees nominated by you; or
• c. your representatives.

Unsolicited information

From time to time, we may receive personal information that is additional to information that we have solicited or information that we have not taken active steps to collect. This is known as ‘unsolicited personal information’ and can include:

• a. misdirected correspondence received by us;
• b. information about another individual shared with us in the course of providing our services; 
• c. promotional material containing personal information sent to us by an individual promoting the individual’s business or services; or
• d. court documents for proceedings to which we are a party or may have an interest.

If we receive unsolicited personal information and we decide that we are not permitted to collect it in accordance with the APPs, we will take reasonable steps to destroy or de-identify the information as soon as practicable, unless it is unlawful or unreasonable to do so.

Anonymity and pseudonymity

Where practical and possible (and in accordance with relevant laws), we will allow you to interact with us anonymously or by using a pseudonym. However, we note that your interaction with JBIC and most of JBIC’s services will require your personal information.

For what purposes does JBIC collect, use and / or disclose your personal information?

For personal information which JBIC collects from you in Australia, please note that such personal information collected may be used for the following purposes, and will be used within the scope that is necessary to achieve such purposes:

• a. processing your application / interest in any loan, equity participation, and guarantee operations, including but not limited to, the carrying out of due diligence or other screening activities in accordance with any legal or regulatory risk management procedures that may be required by law or that may have been put in place by JBIC;
• b. facilitating and / or managing relationships between you and JBIC;
• c. dealing in any matters relating to the services and / or products which you are entitled to under the relevant Terms of Engagement with JBIC (including the mailing of correspondence, statements, invoices, reports or notices to you, which could involve disclosure of certain personal information about you in order to bring about the delivery of the same);
• d. carrying out instructions or responding to any enquiries by you in a proper and efficient manner;
• e. carrying out verification checks on your identity in accordance with any applicable laws or policies of JBIC;
• f. to send you invitation to events (such as seminars) organised by JBIC;
• g. to provide you with marketing, advertising and promotional information, materials and / or documents relating to the products and / or services that JBIC may be selling, marketing, offering or promoting, whether such products or services exist now or are created in the future;
• h. to issue and collect surveys and questionnaires for general marketing research (including statistical processing and analysis of such outcomes);
• i. managing JBIC's databases;
• j. to improve JBIC's service operations to enhance your user experience;

(together, the "Purposes").

Direct Marketing

JBIC may from time to time, communicate with you directly to promote opportunities or events. We may send you messages or advertisements about these communications via our Website, your email, SMS, phone or mail, in compliance with applicable marketing laws (including the Spam Act 2003 (Cth)).  

On each communication, JBIC will advise how you may unsubscribe or opt out of receiving such communications. You may, at any time, request not to receive direct marketing communications from JBIC and JBIC will comply with that request. 

Disclosure of your personal information to third parties and overseas recipients

In order to enhance JBIC’s operations and advance the abovementioned Purposes, JBIC may disclose your personal information to other members of the JBIC group as well as to the following third-party service providers or agents (some of which may be situated outside of Australia), including:

• a. JBIC affiliated entities on a confidential basis for the performance of our contracts and / or in compliance with our legislative and regulatory requirements;
• b. third-parties for auditing and accounting purposes;
• c. where disclosure is required under applicable law, including disclosure to regulators, courts and law enforcement agencies as necessary;
• d. third-parties when the purpose of such disclosure is reasonably expected by you and is related to one or more of the Purposes;
• e. third-parties or agencies when JBIC reasonably believes the disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety;
• f. a public agency when such disclosure is in the public interest; and
• g. in other circumstances where we have your express consent to do so.

When disclosing your personal information to third parties, JBIC will select a trustworthy subcontractor, enter into a suitable contractual agreement with the subcontractor which requires the subcontractor to only use or disclose the information for the purposes of the contract, provide adequate supervision over the handling and administering of the personal information, and provide adequate forms of protection over such personal information.

As JBIC operates its business primarily in Japan and has representative offices in many countries across the world, your personal information may be accessible outside of Australia, including by overseas recipients in Japan, Singapore, China, Thailand, Vietnam, Indonesia, Philippines, India, Russia, United Kingdom, France, Turkey, United Arab Emirates, United States, Argentina, Mexico, and Brazil in connection with the Purposes.

If you consent to disclosure of your personal information as described above, JBIC is not required to take reasonable steps to ensure that such organisations do not breach the APPs in relation to the disclosed information, JBIC will not be liable under the Privacy Act, and you will not be able to seek redress under the Privacy Act. The overseas organisation may not be subject to any privacy obligations in their own country that are similar to the APPs, you may not be able to seek redress in the overseas jurisdiction, and the overseas recipient could be subject to foreign laws that compel disclosure to third-parties, such as overseas authorities. 

Having been informed of the possibility that such disclosures may occur, you consent to that disclosure by undertaking the type of activities specified above which indicate your consent.

How JBIC holds and protects your personal information

JBIC will take reasonable steps to ensure that the personal information that JBIC holds about you (both electronically and physically) is kept confidential and secure, including by:

• having a robust physical security of our premises and databases / records;
• taking measures to restrict access to personnel who need that information in order for JBIC to be able to provide JBIC's products and services; and
• having technological measures, such as computer passwords, data back-up, anti-virus software and firewalls.

JBIC will constantly educate its employees about the protection and proper management of your personal information to ensure that its employees properly handle such personal information in their daily operations.

JBIC will periodically audit and inspect whether the measures taken to ensure the protection and proper management of personal information are sufficient.

JBIC will only keep personal information for as long as it is needed for any purpose for which it was collected. JBIC will destroy or anonymise all personal information within JBIC’s possession or under JBIC’s control in a secure manner as soon as it is reasonable to assume that:

• a. the purpose for which that personal information was collected is no longer being served by the retention of such personal information; and
• b. retention is no longer necessary for any other legal or business purposes.

Continuous Improvement

JBIC will continuously improve how JBIC manages your personal information as necessary.

How to access and correct your personal information

JBIC will endeavour to keep your personal information accurate, complete and up to date.

If you wish to make a request to access and / or correct the personal information JBIC holds about you, you should make a request in writing and JBIC will deal with such a request by following the procedure outlined below:

• a. For a request to access your personal information, JBIC will provide you with the relevant personal information within a reasonable time from such a request being made. When making such a request, JBIC will ask you to verify your identity before JBIC can give you access to your information. JBIC will be entitled to charge you a reasonable fee for the handling and processing of this request.
• b. For a request to correct your personal information, JBIC will correct your personal information as soon as practicable after the request has been made. When making such a request, JBIC will ask you to verify your identity before JBIC can allow you to correct your information. JBIC shall also send the corrected personal information to every other organisation to which the personal information was disclosed by JBIC within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose. Notwithstanding the preceding sentence, JBIC may, if you consent, send the corrected personal information only to specific organisations to which the personal information was disclosed by JBIC within a year before the date the correction was made. JBIC will not be responsible for any loss arising directly or indirectly from any inaccurate and / or incomplete information provided to JBIC by you.
• c. For a request to withdraw your consent for the collection, use and / or disclosure of personal information, JBIC will process such a request within a reasonable time from such a request being made, and thereafter refrain from collecting, using and / or disclosing your personal information in the manner stated in your request.
• d. All requests should be directed in writing to JBIC's Data Protection Officer (Chief Representative, Representative Office in Australia).

Cookies

The Website uses cookies. A cookie is a small text file that is stored on your device when you visit websites. It represents information to the website that assists with providing you a better browsing experience. Cookies provide information in relation to your browsing behaviour, but generally will not identify you. 

JBIC uses cookies to improve your experience of the website. If you do not wish to use the cookies, you can amend the settings on your internet browser so it removes or blocks cookies (other than those essential for the operation of the website). This will not prevent you from accessing or using the Website. However, please note that removing or blocking the cookies can affect your browsing experience and the Website’s functionality.

JBIC’s cookie policy is available at https://www.jbic.go.jp/en/cookie-policy.html.

Links to other websites

The Website may contain links to other websites operated by third parties.  JBIC makes no representations or warranties in relation to the privacy practices of any third-party provider or website. JBIC is not responsible for the privacy policies or the content of any third-party provider or website, or for any practices on linked websites that might breach your privacy.

Inquiries and complaints

For inquiries or complaints about how JBIC handles, processes or manages your personal information, please contact JBIC's Data Protection Officer (Chief Representative, Representative Office in Australia) in writing. Note JBIC may require proof of your identity and full details of your request before JBIC can process your inquiry or complaint.

Please allow up to 30 days for JBIC to respond to your complaint

It will not always be possible to resolve a compliant to everyone's satisfaction. If you are not satisfied with JBIC's response to a complaint, you have the right to contact the Office of the Australian Information Commissioner (at www.oaic.gov.au) to lodge a complaint.

Data Protection Officer contact details

If you wish to contact JBIC's Data Protection Officer (Chief Representative, Representative Office in Australia), please use the following contact details:

By email: B0380@jbic.go.jp
By phone: +61-2-9293-7980
By mail: Suite 4102, Level 41, Gateway Tower, 1 Macquarie Place, Sydney NSW 2000 Australia

Updates to the Privacy Policy

JBIC reserves the right to periodically change or update this Privacy Policy from time to time. Updated versions of this Privacy Policy will be posted on our Website. Please ensure that you review our Website regularly to be advised of updates.

If at any point we decide to use personal information in a manner materially different from that stated at the time it was collected, we will notify individuals by email or via a prominent notice on our website, and where necessary we will seek the prior consent of individuals.

This Policy was last updated on: 2 August 2023