YARUKI Switch Group Holdings Personal Information Protection Policy

Established: November 17, 2023
Last revised: January 24,2024

YARUKI Switch Group Holdings Co., Ltd. (Hereinafter referred to as "our company".) recognizes that the protection of personal information and specific personal information is an important responsibility of our company. Therefore, based on the Personal Information Protection Philosophy and the code of conduct that we have established, we hereby declare that we will build a personal information protection management system to realize the policies described below, and that the entire company will work to continuously improve the system while constantly recognizing the latest trends in IT technology, changes in social requirements, and changes in the business environment.

1. Our company will acquire, use, and provide personal information appropriately in consideration of the content and scale of its business, and will not handle personal information beyond the scope necessary to achieve the specified purpose of use. We will also take measures to achieve this.
2. Our company complies with laws and regulations, national guidelines, and other regulations concerning the handling of personal information.
3. Our company has established regulations and systems to prevent the risk of personal information leakage, loss, or damage by taking reasonable safety measures, and will continuously improve them. In addition, we will promptly take corrective measures in the event of an emergency.
4. Our company will respond promptly and sincerely to complaints and consultations regarding the handling of personal information.
5. We will continuously improve our personal information protection management system by reviewing it in a timely and appropriate manner in light of changes in the environment surrounding our company and actual circumstances.

YARUKI Switch Group Holdings Co., Ltd.,
President and Representative Director, Naoshi Takahashi

Contact for inquiries regarding the Personal Information Protection Policy and for complaints and consultations regarding Personal Information (including Retained Personal Data)

Hatchobori Daiichi Seimei Building, 2-24-2, Hatchobori, Chuo-ku, Tokyo 104-0032
YARUKI Switch Group Holdings Co., Ltd. Contact for Personal Information
Telephone: 03-6858-1198

Matters Concerning Handling of Personal Information

Please review the following information regarding the handling of personal information.

１．Name and address of the business, name of the representative:
　Name: YARUKI Switch Group Holdings Co., Ltd.
　Address: Daiichi Seimei Building, 2-24-2 Hacchobori, Chuo-ku, Tokyo 104-0032, Japan
　Representative: President and CEO, Naoshi Takahashi

２．Personal Information Administrator:
　YARUKI Switch Group Holdings Co., Ltd., Head of Legal Affairs and Risk Management Division

３．Purpose of Use of Personal Information:
　We will use the acquired personal information for the following purposes:

(1) Customers’ personal information
・ We use customers’ personal information to provide services for our company's business administration, to contact them, to provide related after-sales services, and to inform of new products and services.

(2) Personal information of the person who made an inquiry or request for information
・ The personal information of the person who made an inquiry about each business of our company will be used to answer the inquiry.・ It will be used to send the requested materials.

(3) Personal information of our company shareholders
・ We use personal information of our company shareholders for communication, provision of various information, shareholder management and related and incidental business.

(4) Personal information of job applicants
・ It is used for job selection and communication.

(5) Information of our company's officers and employees
・ This information is used for human resources and labor management, business management, benefits, health management, security management, and internal analysis.

(6) Information on officers of each company within our group
・ Will be used for the entrusted management and administration tasks from each company within our group.

（７）Individual Number information provided
・ Used for procedure such as "social insurance" and "tax" specified by law.

４．Third-party provision of personal information
　　Except when there is consent from the individual concerned or when required by law, the personal information provided in this instance will not be disclosed to third parties.

５．The entrustment of personal information
　　Our company, for the purpose of efficient business operations and providing better services to our customers, outsources certain aspects of its operations to external entities. In some cases, we may entrust personal information to these business outsourcing partners. In such instances, we carefully select outsourcing partners who are recognized for handling personal information appropriately. Through contracts and agreements, we establish provisions for the proper management and confidentiality of personal information, ensuring necessary measures for the prevention of leakage and maintaining its security.

６．The disclosure and inquiries regarding acquired personal information.
　 At the request of the individual, we will respond to requests for notification, disclosure, provision of records to third parties, correction, addition, deletion, suspension of use, or erasure of the purposes of use of personal information acquired by our company through this matter (referred to as 'disclosure, etc.'). The contact point for such disclosure requests is the 'Contact Point for YARUKI Switch Group Holdings Co., Ltd. Personal Information' as mentioned above.

７．The voluntary nature of providing personal information
　　Whether customers provide personal information to our company is at their discretion. However, if required information is not provided, it may result in the inability to provide certain services in an appropriate manner.

８．The information automatically collected as a result of accessing our company's website.
　　For the purpose of ensuring the security of visited websites and improving user services, our company may collect information about those who have browsed using cookies.

Dissemination of Matters Concerning Retained Personal Data and Third-Party Provided Records

YARUKI Switch Group Holdings Co., Ltd. (Hereinafter referred to as "our company".) will disseminate the following matters regarding requests for disclosure of retained personal data, etc. (Notification of the Purpose of Use, Disclosure, Correction, Addition or Deletion of Contents, Suspension of Use, Erasure and Suspension of Provision to Third Parties) and requests for disclosure of Third-Party Provided Records.

1. Purpose of use of retained personal data

(1) Personal information obtained directly by our company
・ We use customers’ personal information to provide services in our company's business management operations, to contact, to provide related after-sales services, and to inform of new products and services.

(2) Personal information of the person who made an inquiry or request for materials
・ The personal information of the person who made an inquiry about each business of our company is used to answer the inquiry.・ It is used to send the requested materials.

(3) Personal information of our company shareholders
・ We use personal information of our company shareholders for communication, provision of various information, shareholder management and related and incidental business.

(4) Personal information of job applicants obtained directly by our company
・ Used for job selection and related communication etc.

(5) Information of our company's officers and employees
・ This information is used for human resources and labor management, business management, benefits, health management, security management, etc.

(6) Individual Number information of our company’s employees and dependents
・ Used for procedure such as "social insurance" and "tax" specified by law.

2. About Certified Personal Information Protection Organizations in our company

There are no Certified Personal Information Protection Organizations in our company.

3. Disclosure Procedures

If you have a request for disclosure, please contact the contact desk regarding the personal information. We will send you an explanation of the necessary procedures and the necessary application documents.

4. Measures Taken for Safety Management of Retained Personal Data

Our company has established rules on the handling of personal information, specific personal information and rules on safety measures and has taken the following measures.

(1) Organizational Safety Management Measures
・ We have established a policy on the handling of personal information, and as a personal information protection policy, we have made it known throughout the company and published it on our web page for the general public to obtain.・ For each stage of acquisition, use, storage, provision, deletion, disposal, etc., we have established procedures for handling personal information, including the handling method, the person responsible, the person in charge, and their duties, and we have compiled them into a written regulation and have made them known throughout the company.・ We regularly conduct self-inspections on the handling status of personal information, and we regularly conduct internal audits from an impartial standpoint by other departments and outsiders.・ We restrict the number of officers and employees who handle individual personal information.

(2) Personnel Safety Management Measures
・ Regular training is provided to officers and employees on the points of attention concerning the handling of personal information.・ A pledge on confidentiality is obtained from officers and employees.

(3) Physical and technical safety measures
・ In order to prevent personal information from being viewed by employees other than the person in charge of handling it or by other unauthorized persons, the areas where it is handled are limited.・ In the areas where personal information is handled, management of the entry and exit of officers and employees is conducted.・ Personal information is stored in lockable cabinets and on servers that restrict access.・ Firewalls are installed to prevent unauthorized external access to servers. In addition, measures are taken against computer viruses and other unauthorized software.・The following measures are taken when personal information is transferred.
- When media is transferred, we use a method that records the delivery or hand deliver it directly.
- For electronic data communication, we take measures against leakage such as encryption.