JDM Company LLC (hereinafter referred to as "the Company") recognizes the importance of personal information entrusted to us by our business partners and customers. As a business operator handling personal information in connection with the provision of goods or services to persons located in Japan, the Company complies with Japan's Act on the Protection of Personal Information (個人情報保護法, hereinafter the "APPI") and the guidelines of the Personal Information Protection Commission (個人情報保護委員会), and appropriately handles personal information as set forth below.
1. Name, Address, and Representative of the Business Operator
Name: JDM Company LLC (a legal entity organized under the laws of the Russian Federation)
Registered Head Office: 13 Gogolevskaya str., Partizansk, Primorsky Krai, Russian Federation
Business Office: Office 5, 6 Shoshina str., Vladivostok, Primorsky Krai, Russian Federation 690089
Representative: Sergey Khryapin, General Director
2. Personal Information Acquired
Through our inquiry form, email, telephone, messengers (WhatsApp, WeChat), exchange of business cards, and other means, the Company acquires company names, department names and job titles, full names, name readings (furigana), email addresses, telephone numbers, inquiry details, and other information provided by you.
3. Purposes of Use
- Responding to inquiries and consultations
- Communications regarding business transactions, and the conclusion and performance of contracts
- Counterparty due diligence and verification for legal compliance (including screening against sanctions lists)
- Sending materials and information
- Compliance with applicable laws and regulations
The Company will not handle personal information beyond the scope necessary to achieve the purposes of use stated above.
4. Provision of Personal Data to Third Parties
Except in the following cases, the Company will not provide personal data to any third party without obtaining the prior consent of the individual concerned:
- Where required or authorized by laws and regulations
- Where necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual concerned
- Where it is necessary to cooperate with a state organ, a local government, or an individual or entity entrusted by either in executing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of such affairs
With respect to inquiries regarding business transactions, the Company may provide your contact details and related information to the Japanese entity designated by us after obtaining your consent.
5. Entrustment of Handling
Within the scope necessary to achieve the purposes of use, the Company may entrust operations relating to email, information systems, and similar functions to external service providers. In such cases, the Company will exercise necessary and appropriate supervision over the entrusted parties.
6. Handling of Personal Data in a Foreign Country (Understanding the External Environment)
The Company handles personal data in the Russian Federation. The Russian Federation has enacted Federal Law No. 152-FZ ("On Personal Data") as comprehensive legislation governing the protection of personal data. At the same time, according to surveys published by Japan's Personal Information Protection Commission, the country has legal frameworks that obligate telecommunications operators and certain other entities to store information domestically within the country, as well as laws permitting government authorities to access personal information held by business operators. In accordance with Section 10-7 ("Understanding the External Environment") of the APPI Guidelines (General Rules), the Company understands these legal frameworks and implements the security control measures set forth in the following section.
7. Security Control Measures
- Formulation of Basic Policy: We have formulated this Policy to ensure the proper handling of personal data.
- Organizational Security Control Measures: We appoint a person responsible for the handling of personal data and limit both the personnel authorized to handle personal data and the scope of personal data handled.
- Human Security Control Measures: We require personnel handling personal data to execute confidentiality undertakings and provide necessary training.
- Physical Security Control Measures: Documents containing personal data are stored in locked locations, and measures are taken to prevent theft or loss of devices used to handle personal data.
- Technical Security Control Measures: We implement access controls and take measures to protect information systems from unauthorized external access and malicious software.
- Understanding the External Environment: As described in the preceding section, we implement security control measures based on an understanding of the legal systems of the country in which personal data is handled.
8. Requests for Disclosure, etc. of Retained Personal Data
When a request is made by an individual or their authorized representative for notification of the purpose of use, disclosure (including disclosure of records of provision to third parties), correction, addition, or deletion, suspension of use or erasure, or suspension of provision to third parties with respect to retained personal data, the Company will respond without delay in accordance with applicable laws and regulations after verifying the requester's identity. Please submit requests by email to the contact desk below. No handling fee is charged.
9. Use of Cookies and Similar Technologies
This website does not use web analytics tools or cookies for advertising purposes. Please note that this website uses an external font delivery service (Google Fonts) to display text, and information such as your IP address is transmitted to that service when viewing pages.
10. Contact Desk for Inquiries and Complaints
Personal Information Inquiry and Complaint Desk, JDM Company LLC
E-mail: d.cherkashin@jdmcompany.jp (Inquiries in Japanese, English, and Russian are accepted)
11. Revision of This Policy
The Company may revise this Policy in response to amendments to laws and regulations or other circumstances. Any revised Policy will take effect from the time it is posted on this website.
Enacted: November 2026
Sergey Khryapin, General Director, JDM Company LLC