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• TSUKUI Group’s Privacy Policy
• Purposes of using personal information

TSUKUI Group’s Privacy Policy

The TSUKUI Group* recognizes its legal and social responsibilities as a company that handles personal information (including specific personal information as defined by Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (the “Number Act”) and strives to protect and manage the personal information based on the following policy.

*TSUKUI Group refers to TSUKUI CORPORATION, TSUKUI STAFF CORPORATION,TSUKUI CAPITAL CORPORATION,DIGITAL LIFE CORPORATION,Grasol Co.,Ltd.,TSUKUI PLAN VIETNAM COMPANY LIMITED,akarie Co.,Ltd.,Yuiyui Co.,Ltd..

1. The Group will handle personal information under the principle of respecting the personality of an individual.
2. The Group will comply with applicable laws and regulations including the Act on the Protection of Personal Information and the Number Act as well as the guidelines and other codes for the proper handling of personal information.
3. After obtaining your consent, the TSUKUI Group will appropriately obtain and use personal information only for carrying out its operations to provide its services. The Group will obtain and use specific personal information only by such method and within the scope of such purpose as stipulated in the Number Act.
4. If the Group asks you to provide your personal information, the Group will inform you of the purpose of use on the websites of TSUKUI Group companies or by separate notification.
5. The Group will take appropriate security control actions, as described below, against unauthorized access, leakage, destruction, alteration, and other similar acts made to your personal information.
   1. Formulation of Basic Policy
      The Group has established this Basic Policy to ensure the appropriate handling of personal information and to specify a contact point for questions and complaints.
   2. Development of regulations regarding the handling of personal data
      For each stage of personal information management, including acquisition, use, preservation, provision, deletion, and disposal, the Group has formulated regulations regarding handling methods, the persons responsible/persons in charge, and their duties.
   3. Systematic safety management measures
      The Group has established a person responsible for the handling of personal data, clarified the scope of the personal data to be handled when handling personal data, and provided the person responsible for the management of personal information with a reporting and communication system for cases where certain facts and signs stipulated in the Personal Information Protection Act and the internal regulations are identified.
   4. Human safety management measures
      Matters related to maintaining confidentiality of personal information shall be clearly stated in the Employment Regulations. Employees are also provided with regular training on important matters regarding handling personal information.
   5. Physical safety management measures
      The Group has taken measures to prevent theft, loss, etc. of devices, electronic media and documents used for handling personal information. In addition, when carrying equipment, electronic media, etc. used for handling personal information, including when moving within business locations, measures are taken to ensure that personal information is not easily revealed.
   6. Technical safety management measures
      Access control is implemented to limit the persons in charge and the scope of personal information handled.
6. The Group will promptly respond to inquiries and requests for matters including disclosure regarding your personal information in accordance with the laws and regulations.
7. The Group will not provide or disclose your personal data to a third party unless you have given your consent or there is a valid reason. For specific personal information, the Group will not provide or disclose it to a third party except as stipulated in the Number Act.
8. The TSUKUI Group may share personal data (excluding specific personal information) within the Group for group business management, as well for the introduction and provision of products and services to customers, including the decision making associated with that.
   1. Personal data to be shared: name, address, telephone number, email address, gender, date of birth, and other information described in the contract, services provided, and billing information of the customer (user, family member, guarantor, underwriter, etc.) held by the TSUKUI Group.
   2. Scope of shared users: TSUKUI Group
   3. The entity responsible for the management of personal data: the company that originally acquired the respective personal data
      (Please refer to the following page for the TSUKUI Group companies and their representatives.)
   • TSUKUI CORPORATION
   • TSUKUI STAFF CORPORATION
   • TSUKUI CAPITAL CORPORATION
   • DIGITAL LIFE CORPORATION
   • Grasol Co., Ltd.
   • TSUKUI PLAN VIETNAM COMPANY LIMITED
   • akarie Co.,Ltd.
   • Yuiyui Co.,Ltd.
9. TSUKUI Group creates anonymously processed information which is processed so that customers cannot be identified, for joint research projects with other companies and joint development of products and services with other companies. Such anonymously processed information created will be provided to a third party using a secure transmission method.
10. The Group will respond sincerely to any complaints and consultations regarding personal information.
11. The Group will thoroughly enhance employee education and maintain the appropriate management system for protecting personal information.
12. The Group will continually review the contents of this policy and strive to improve and enhance it.

Purposes of using personal information

1. Any and all matters related to management control and supervision of the TSUKUI Group’s management.
2. Any and all matters related to the planning and drafting of the TSUKUI Group’s management strategies.
3. Any and all matters related to the exercise of shareholders’ rights and the performance of the Company’s duties under the Companies Act.
4. Any and all matters related to employee recruitment, labor management, payroll, and other personnel operations.
5. Any and all matters related to requests for information materials, inquiries, etc. from customers, etc.
6. Other operations incidental or related to each of the above items.