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Kitamura Holdings Co., Ltd. (hereinafter referred to as "KHD") acknowledge that the protection of personal information is an important social responsibility of KHD and declare that KHD will handle the personal information of KHD’s customers and business partners (hereinafter referred to as the "Customers") appropriately and safely.
Under this declaration, KHD announce the Privacy Policy (hereinafter referred to as the "Policy") hereunder.

1. 1　Definition and Scope of Personal Information

   "Personal Information" in the Policy shall mean information about an individual and the information that can identify a specific individual by certain information contained in such information (which is the same meaning as Article 2 of the Personal Information Protection Act). However, the Policy shall not be applied to the Personal Information which is hyperlinked to websites included in the latest website operated by KHD (hereinafter referred to as the "KHD Website") or which is registered in any other websites which KHD is not directly operated Personal information registered on linked websites and other websites that are not directly managed by KHD.

2. 2　Compliance with Laws and Regulations Concerning Personal Information, National Guidelines and Other Norms

   KHD, as a company to receive the important Personal Information from the Customers, shall comply with the laws and regulations concerning the handling of Personal Information Protection, guidelines and policies given by various competent authorities based on the Act on the Protection of Personal Information, and other norms related to Personal Information Protection (hereinafter referred to as "Related Laws").

3. 3　Appropriate Acquisition of Personal Information

   1. (1) KHD shall handle Personal Information acquired by lawful and fair means.

   2. (2) When acquiring Personal Information directly from the Customers, KHD shall clearly indicate to the Customers the necessary matters such as the purpose of use of Personal Information and obtain consents. When acquiring personal information indirectly from a third party, KHD shall confirm whether the provider of such information has obtained Personal Information properly from the Customer, and KHD shall announce the necessary matters such as the purpose of use of personal information on the KHD Website.

   3. (3) KHD will not acquire specific sensitive Personal Information that falls under the following. Provided however, this shall not apply if the acquisition of such Personal Information is required by the Related Laws.

      1. Information on ideas, beliefs or religions
      2. Race, ethnicity, family origin, permanent domicile (excluding information on the prefecture where you are located), information that causes physical or mental disorders, criminal records, and other social discrimination
      3. Information on workers' right to organize, collective bargaining, and other acts of collective action
      4. Information related to participation in collective demonstrations, exercise of petition rights, and other exercise of political rights
      5. Information on health care or sex life

   4. (4) KHD has introduced access analysis tools and advertising analysis tools provided by third party companies for the purpose of improving websites and services. These tools use cookies (an industry standard technology in which a web server identifies Customers’ browser, and it shall be the same hereinafter.) and measure the Customer’s use of the KHD Website, the number of times showing and clicking advertisements, the display of contents and advertisements tailored to the Customer and provide social media functions. In addition, the measured data is provided to third party companies in data analysis, advertisement distribution, and social media. Cookies can identify the Customers’ browser, but not the Customer individually.

4. 4　Purpose of Use of Personal Information

   The acquired Personal Information will be used to the extent necessary for the execution of business within the scope of the following purposes of use. In addition, when entrusting the handling of Personal Information to a third party, KHD will supervise the third party to fulfill the appropriate use of Personal Information.

   1. To confirm and respond to the content of inquiries or opinions from the Customers
   2. To contact with, handle and manage the Customers (including business operators who may become business partners) for the course of business and transactions
   3. To manage and guide shareholders stipulated in laws and regulations such as the Companies Act
   4. To provide information on recruitment and recruitment selection
   5. For other purposes incidental to the above purpose of use

5. 5　Prohibition of the Use of Personal Information other than the Purpose

   KHD will not use Personal Information beyond the scope necessary to achieve the specified purpose of use for any purpose. In addition, in order to prevent the use of Personal Information for purposes other than the purpose, KHD conducts daily inspections, internal audits, etc. of the management system of Personal Information.

6. 6　Appropriate Provision of Personal Information to Third Parties

   Except the following cases, KHD will properly manage the acquired Personal Information and will not provide or disclose it to any third parties other than the Customers without obtaining their consent in advance.

   1. When based on laws and regulations
   2. When it is necessary for the protection of human life, body or property, and it is difficult to obtain the consent of the person.
   3. When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the person.
   4. When it is necessary for KHD to cooperate with a national organization, local public entity, or a person entrusted thereto with carrying out the affairs prescribed by laws and regulations, and there is a risk that obtaining the consent of the person will interfere with the execution of the affairs.

7. 7　Ensuring the accuracy of the contents of personal information

   KHD will endeavor to keep the contents of Personal Information as accurate and up to date as possible to the extent necessary to achieve the purpose of use.

8. 8　Prevention of Leakage, Loss or Damage of Personal Information

   In order to prevent leakage, loss or damage of Personal Information through unauthorized access, etc., KHD will take the following safety management measures. In the wake of any deficiencies in safety management, KHD will promptly take corrective action.

   1. Store Personal Information in the information system that has been subjected to measures against unauthorized access and acquire and monitor access logs.
   2. Store papers and electric media which record Personal Information in the locked space.
   3. Take physical safety control measures to prevent unauthorized intrusion to Offices and server rooms
   4. Acknowledge that contractors who are entrusted with the processing and storage of protection of Personal Information are done adequately and conduct necessary supervision.

9. 9　Supervision of Employees and Contractors

   1. (1) To properly manage Personal Information, KHD will conduct necessary education and training, etc. for persons engaged in the business of handling Personal Information and conduct appropriate supervision.

   2. (2) When outsourcing to entrust the handling of Personal Information to an outside party, KHD shall manage and supervise to handle Personal Information appropriately by the consignee by concluding agreements including, but not limited to a confidentiality agreement.

10. 10　Continuous Improvement of Personal Information Protection Management System

    To appropriately use and thoroughly protect Personal Information, KHD will periodically verify and continuously improve KHD’s Personal Information Protection management system in accordance with changes in business environment and social conditions, advances in information security technology, and the enactment and revision of laws and regulations.

11. 11　Inquiries about Personal Information

    1. (1) Responding to complaints and consultations
       When KHD receive complaints, consultations regarding the handling of Personal Information, KHD respond as quickly and appropriately as possible at the following complaints and consultation desks regarding Personal Information.

    2. (2) Requests for Personal Information
       When KHD receive requests notification, disclosure, correction, addition, deletion, suspension of use, suspension of provision to third parties, or erasure of the purpose of use related to Personal Information, KHD will process upon confirmation of the identity of the person.

    3. (3) Regarding complaints, consultations and various claims set forth in Paragraph 1 and the preceding paragraph of this Article, please contact below.

       Shinjuku i-Land Wing 13F, 6-3-1 Nishishinjuku, Shinjuku-ku, Tokyo 160-0023
       Kitamura Holdings Co., Ltd.
       Personal Information Protection Office
       Email: info@kitamura-group.co.jp
       (Business hours will be from 10:00 to 18:00 on weekdays.)

Kitamura Holdings Co., Ltd.
Shinjuku i-Land Wing 13F, 6-3-1 Nishishinjuku, Shinjuku-ku, Tokyo 160-0023
Kazuhiro Fukumoto