Handling of Personal Information

1. Business Operators which Handle Personal Information
   Ad-Sol Nissin Corporation
   4-1-8 Konan Minato Ward, Tokyo
   Representative Director and President Toshiaki Shinozaki
2. Personal Information Management System
   We have established internal rules for the handling of personal information and have appointed a person responsible for the management of personal information in each department under the supervision of the Personal Information Protection Manager, who is responsible for our handling of personal information.
3. Collection and Purpose of Use of Personal Information
   The personal information we hold and its purposes of use are as follows.
   Personal information received from our clients will be handled only to the extent necessary to achieve the purpose of use.
   
   1. Personal information of persons who inquire about our business, services, etc.
      - To respond to inquiries
   2. Personal information of users of our services
      - To provide the necessary support for the use of our services
      - To conduct surveys on our services
   3. Personal information of outsources of our development business
      - To execute our business operations through the fulfillment of contracts
   4. Personal information of shareholders
      - To send business activity reports, etc. to shareholders
   5. Personal information of employment applicants
      - To conduct screening procedures for employment applicants
   6. Personal information of our employees
      - To provide employee benefits and manage employees
4. Provision of Personal Information to Third Parties
   We will not disclose or provide personal information of our clients to third parties except in the following cases:
   
   1. When providing personal information in accordance with laws and regulations, including in the case of investigations conducted by a public agency in accordance with laws and regulations
   2. When providing personal information necessary for judicial proceedings (including quasi-judicial proceedings)
   3. When providing personal information is necessary to protect the life, health, property or other important interests of our customers or the public
   4. When providing personal information to our agents, subcontractors and the like, who are obligated to maintain confidentiality to us, to the extent necessary to carry out the purpose of use
5. Provision of Personal Information to Third Parties Located in Foreign Countries
   In the course of performing entrusted services, the Company may re-entrust part of the operations involving the handling of personal information to third parties located in foreign countries. In such cases, personal data may be provided to those third parties to the extent necessary to achieve the purposes described under "Purpose of Use."
   When re-entrusting such operations to a third party located in a foreign country, the Company will provide the necessary information to its business partner (the entrusting party) and consult with them in advance. The Company provides personal data only to third parties located in foreign countries that have implemented measures equivalent to those required under the Act on the Protection of Personal Information of Japan.
   (1) Name of the Foreign Country
   　　Socialist Republic of Vietnam
   (2) Personal Information Protection System in the Foreign Country
   Information regarding the personal information protection system of the above country is available in the Personal Information Protection Commission's report: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_vietnam/
   The Company has implemented appropriate security control measures after understanding the personal information protection system of that country.
6. Outsourcing the Handling of Personal Information
   We outsource some of our operations related to personal information to outside companies. We consider managing our contractors to be of the utmost importance, and when outsourcing our operations, we select contractors recognized as having a sufficient level of protection for personal information, and clarify the obligations considered necessary through contracts with them and other means.
   In addition, we require the outsource to handle personal information appropriately and continuously supervise and audit them as necessary in order to safely manage such information.
7. Security Control Measures
   As a PrivacyMark-certified company, we implement organizational, human, physical, technical, and external security measures to prevent incidents involving the handling of personal information.
   (1) Organizational Security Measures
   
   1. We have established an organizational framework for the protection of personal information.
   2. We have established security policies, rules, and procedures based on our Information Security Policy and operate them accordingly.
   3. We conduct self-inspections by personnel handling personal information, internal audits, and management reviews, and implement improvements based on the results.
   (2) Human Security Measures
   
   1. We provide employees with regular education and training regarding the appropriate handling of personal information and the implementation of our Personal Information Protection Management System.
   2. Employees are required to submit confidentiality pledges regarding the handling of personal information.
   3. We have entered into confidentiality agreements with business partners and subcontractors.
   (3) Physical Security Measures
   
   1. Security levels are defined, and access to facilities is controlled through IC card-based entry and exit management.
   2. Dedicated rooms for handling personal information are established.
   3. Measures are implemented to prevent the theft, loss, or unauthorized disclosure of equipment, electronic media, and other assets containing personal information.
   4. We ensure the secure deletion of personal information and the safe disposal of equipment and electronic media.
   (4) Technical Security Measures
   
   1. Strict access control measures are implemented.
   2. We have introduced mechanisms to protect against unauthorized access and malicious software from external sources.
   (5) Understanding of the External Environment
   
   1. When handling personal information in foreign countries, we identify and understand the personal information protection systems of the relevant countries and implement appropriate security control measures accordingly.
8. Requests for Notification of Purpose of Use, Disclosure, Correction, Addition or Deletion, Suspension of Use, Erasure, Suspension of Provision to Third Parties, and Disclosure of Records of Provision to Third Parties of Personal Information
   We accept requests from individuals regarding their personal information.For inquiries regarding such requests, please contact the Personal Information Consultation Desk below. Please contact the Personal Information Consultation Desk for details regarding the applicable procedures.
9. Personal Information Protection Manager
   Ad-Sol Nissin Corporation
   Information Systems Dept.
   General Manager Masayuki Nakayama
10. Contact Point for Inquiries Regarding Personal Information
    4-1-8 Konan Minato Ward, Tokyo
    Ad-Sol Nissin Corporation
    Human Resources Dept. (Personal Information Consultation Desk)
    Contact
11. Authorized Personal Data Protection Organization
    Name of the Authorized Personal Information Protection Organization and Contact Point for Filing Complaints Regarding the Handling of Personal Information
    　Name of the Authorized Personal Information Protection Organization
    　　Japan Institute for Promotion of Digital Economy and Community
    　Contact Point for Complaint Resolution
    　　Personal Data Protection Complaints Office
    　Address
    　　Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032, Japan
    　Telephone Numbers
    　　+81-3-5860-7565
    　　0120-700-779 (Toll Free)
    　(Note) This is not a contact for enquiries about our products or services.