TOMOEGAWA CORPORATION and the Tomoegawa Group companies (“the Company, etc.”) comply with laws and ordinances regarding the protection of personal information of the countries where the Company, etc. are located as well as the General Data Protection Regulation (GDPR) (“Privacy Laws and Ordinances”) in handling the personal information collected from you, as well as collect and use personal information appropriately. This Privacy Policy explains the types of personal information the Company, etc. gather from you, why the Company, etc. use personal information and its legal grounds, businesses that share personal information with the Company, etc., storage of personal information, security measures taken by the Company, etc., the rights you can exercise regarding the use of personal information by the Company, etc., how changes may be made to this Privacy Policy, and who to contact at the Company, etc.

• Name of your group or organization, your address, your name, your contact information such as e-mail address.
• History of access of the Company’s website (including name of internet service provider, access date and time, and IP address). The Company’s website uses cookies.

• To implement liaison, contracts and negotiation, etc. necessary for business deals
• To provide information on the products, services or exhibits of the Company, etc.
• To respond to complaints regarding the products and services of the Company, etc.
• To use in marketing activities carried out by the Company, etc.*
• To contact and provide information to applicants in the recruitment and hiring process carried out by the Company, etc.

• When the Company, etc. uses any information, including your interests, preferences and browsing history, acquired from any third party other than us by linking to your personal data already in our possession, the Company, etc. will obtain your prior consent and use such combined information within the purposes of use listed above.

Formulation of basic privacy policy

This policy is set to ensure proper handling of personal data and inform you of contact information for inquiries and complaints.

Establishment of rules concerning handling personal information

• Formulation of personal information protection rules applicable to each stage of acquisition, use, storage, provision, deletion and removal regarding handling methods, persons in charge/personnel and their responsibilities.

Organizational safety control measures

• Assignment of persons in charge of handling of personal data
• Limitation of the scope of personnel who may handle personal data and the scope of personal data handled by such personnel
• Establishment of systems to report to supervisors in case of occurrence of violation, or the likelihood of violation, of applicable laws and regulations or company rules
• Establishment of systems to conduct periodic self-inspections of the status of handling personal information

Personnel safety control measures

• Periodic provision of information and education with employees on matters that require attention to handle personal information
• Provision of matters related to confidentiality of personal information in the employment rules

Physical safety control measures

• Restriction of entry of employees to the areas where personal information is handled, limitation of bringing equipment, and prevention of unauthorized persons from accessing personal information
• Taking measures for prevention of theft or loss of equipment, electronic media and documents, etc. by which personal information is handled
• Taking measures to prevent personal information from being easily identified when carrying equipment and electronic media, etc. by which personal information is handled in the office or elsewhere

Technical safety control measures

• Implementation of access control to limit the scope of personnel and personal information to be handled
• Introduction of structures to protect the information systems that handle personal information from unauthorized external access or illegal software

International transfer

At present, the Company, etc. does not entrust handling of personal information to any person overseas or does not receive personal information from any third party overseas, etc. If such handling occurs, the Company, etc. will take necessary safety control measures based on comprehension of the systems for protecting personal information in such relevant countries. The Company, etc. will also release relevant information on our website, etc. and revise this policy.

All of your personal information that the Company, etc. collected will be shared within the Tomoegawa Group and among its partner businesses in order to support the above purposes. The name, address and name of representative of a company responsible for the management of jointly-used personal data are as shown at the end of this privacy policy.

The Company, etc. will not retain the personal information they collected for a period beyond the limit necessary for fulfilling the purposes for which it was collected. In addition, if the personal information becomes unnecessary in light of the purposes for which it was collected, the Company, etc. will erase the relevant personal information.

• Right to access, correct, erase, and restrict use of personal information
• Right to file a complaint regarding the handling of personal information
• Right of data portability (right to directly transfer your personal information)

This Privacy Policy may be subject to change due to revisions of Privacy Laws and Ordinances or the circumstances of the Company’s website. If changes are made to this Privacy Policy, they will be posted on the Company’s website to notify you of the changes. The changes will be indicated at the top using track changes. A summary of the changes will also be posted if significant changes are made.。

• When disclosing personal information is likely to harm the life, body, property or other rights or interests of the person or third parties
• When disclosure is likely to significantly impede the proper execution of the business of the Company, etc.
• When disclosure violates the laws and regulations

President and CEO Yoshio Inoue
TOMOEGAWA CORPORATION
2-1-3 Kyobashi, Chuo-ku, Tokyo, Japan