PRIVACY POLICY｜Kanematsu KGK corp.

PRIVACY POLICY

Established on December 1, 2024
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Kanematsu KGK Corp. recognizes the importance of protecting personal information (as defined by the “Act on the Protection of Personal Information” and the “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures”) and hereby establishes the following privacy policy. We ensure thorough compliance by officers and employees and strive to protect the rights and interests of individuals.

1. Acquisition of Personal Information
We acquire personal information through lawful and fair means.

2. Specification of Purpose of Use
We specify the purpose of use of personal information as much as possible when handling it.

3. Use of Personal Information
Except as required by law, personal information will be used within the scope of the purposes notified to the individual or publicly disclosed in the section “Handling of Personal Information” below.

4. Contractors
When providing personal information to contractors to fulfill the purpose of use, we will appropriately manage and supervise the contractors to ensure the safety of the personal information.

5. Provision to Third Parties
Except as required by law, we will not provide personal information to third parties without the individual's consent.

6. Management of Personal Information
We implement sufficient security measures to prevent unauthorized access, loss, destruction, falsification, or leakage of acquired personal information, and strive for appropriate and reasonable safety management.
When personal information is no longer necessary, such as after the statutory retention period, it will be promptly discarded or deleted.

7. Pseudonymized Information
We create pseudonymized information in accordance with laws so that individuals cannot be identified unless matched with other information.
We take necessary measures to prevent leakage of deleted information and ensure its safe management.
We do not match pseudonymized information with other data for the purpose of identifying individuals.
We disclose the items of personal information included in pseudonymized information as required by law.
We do not provide pseudonymized information to third parties unless permitted by law.

8. Anonymized Information
We take necessary measures to ensure that anonymized information cannot identify individuals or be restored to the original personal information.
We do not match anonymized information with other data for the purpose of re-identifying individuals.
We disclose the items of personal information included in anonymized information as required by law.
When providing anonymized information to third parties, we disclose the items and methods of provision and clearly indicate that the information is anonymized.

9. Related Information
We do not provide related information (limited to those forming part of a personal information database) to third parties if it is expected that the third party will acquire it as personal data, unless the following conditions are confirmed in advance:
(1) The individual has consented to the third party acquiring the information as personal data.
(2) In the case of provision to a foreign third party, the individual has been informed in advance of the personal information protection system in that country, the measures taken by the third party, and other relevant information.

10. Requests for Disclosure of Personal Information
If an individual wishes to request notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, or disclosure of records of third-party provision of their personal information, we will respond promptly in accordance with applicable laws and regulations.

11. Organization・Structure
We provide training to officers and employees on the protection and proper handling of personal information and ensure appropriate handling of personal information in daily operations.

12. Compliance with Laws and Review
We comply with applicable laws, regulations, and guidelines related to personal information, and review and improve our initiatives under each of the above items as necessary to further enhance the protection of personal information.

Kanematsu KGK Corp.
President
Hiroshi Kimura

Handling of Personal Information

Purpose of use of personal information
Personal information acquired by our company will be used within the scope of the following purposes, unless otherwise permitted by law:

Communication with customers and notifications/greetings based on social customs
Conclusion, execution, and management of contracts between customers and our company
Provision of information regarding our products and services
Research, analysis, and studies related to our business
Invitations to events such as exhibitions and seminars
Reporting of results to individuals who cooperated with or participated in surveys and events
Provision of products and services via direct mail, email distribution, and fax communication
Provision of corporate information and necessary contact for job applicants and prospective employees
Responses to inquiries from customers
Shareholder-related operations and management of shares
Responses to the exercise of rights by shareholders
Payroll calculation and payment for employees
Safety management for employees
Personnel management for employees
Other operations related or incidental to the above

Security Measures for Personal Data
We implement the following security measures for the personal data we obtain. Personal data is retained only for the period necessary to achieve the purposes of use described above. The specific retention period is determined based on the purpose of use, the nature of the personal data, legal requirements, and business necessity.

Establishment of Basic Policy
To ensure the proper handling of personal data, we have established a basic policy that includes the name of the business operator, compliance with relevant laws and guidelines, matters related to security measures, and contact points for inquiries and complaints.
Organizational Security Measures
We appoint a person responsible for handling personal data, establish internal rules for the secure handling of personal data, and build a system for reporting to the responsible person in the event of any actual or suspected violations of laws or internal rules.
Personnel Security Measures
We provide regular training to employees on precautions regarding the handling of personal data.
Physical Security Measures
We manage entry and exit to areas where personal data is handled and implement measures to prevent unauthorized access to personal data by individuals without proper authority.
Technical Security Measures
We implement access controls to limit the scope of personnel and databases handling personal data, and introduce systems to protect personal data from unauthorized access and malicious software.
Understanding of External Environments
We implement appropriate security measures based on an understanding of the personal information protection systems in the countries where personal data is stored.

Joint Use of Personal Data
Our company may jointly use customers’ personal data as follows:

Items of Personal Data Subject to Joint Use
Company name, address, name, department, position, telephone number, email address
Scope of Joint Users
Our company and affiliated companies listed in our securities reports
Purpose of Use by Joint Users
The same purposes as stated in our “Purpose of Use of Personal Information,” and related to the business of each joint user
Name, Address, and Representative of the Company Responsible for Managing Personal Data.

Kanematsu KGK Corp.
Museum Tower Kyobashi, 1-7-2 Kyobashi, Chuo-ku, Tokyo 104-8510
Representative Director and President: Hiroshi Kimura

Procedures for Requesting Disclosure of Retained Personal Data

If you wish to request notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, or disclosure of records of third-party provision regarding personal data retained by our company, please complete the designated request form for disclosure of retained personal data and send it along with the required documents to the contact address below by postal mail or email.

Contact Information
To:
Kanematsu KGK Corp.
Museum Tower Kyobashi, 1-7-2 Kyobashi, Chuo-ku, Tokyo 104-8510
Personnel ＆ General Affairs Department – Personal Information Handling Officer
Email: somubu@kgk-j.co.jp

Required Documents
When submitting your request, please include a copy of your identification document (driver’s license, passport, or health insurance card).
If your address has changed, please also include a copy of the reverse side of the health insurance card or driver’s license.
In addition to the above documents, we may request other documents from you as necessary.

Fees
If your request concerns notification of the purpose of use or disclosure of personal data, you may be required to pay a handling fee.
Upon receiving your completed "Request Form for Disclosure of Retained Personal Data" and the required documents, and once any applicable handling fee has been paid, we will respond to your request in accordance with applicable laws and regulations.

Inquiries Regarding Personal Information
For consultations or inquiries regarding personal information, please contact: Kanematsu KGK Corp.
Museum Tower Kyobashi, 1-7-2 Kyobashi, Chuo-ku, Tokyo 104-8510
Personnel ＆ General Affairs Department – Personal Information Handling Officer
Email: somubu@kgk-j.co.jp

Established: December 1, 2024