Nikko Co., Ltd. (hereinafter referred to as the "Company") has established and published this Privacy Policy regarding the appropriate protection and use of personal information, in accordance with the Act on the Protection of Personal Information (hereinafter referred to as the "Act"). 1. Basic Policy In addition to complying with relevant laws and regulations, the Company shall adhere to the matters stipulated in this Policy to ensure the appropriate protection and use of the personal information of our customers and others. Furthermore, to adapt appropriately to the advancement of the information society, we will continuously strive to improve our management systems and initiatives for the protection of personal information. 2. Management of Personal Information The Company shall implement appropriate security management measures to prevent the loss, alteration, and leakage of personal information. We will educate all executives and employees who handle personal information on the importance of privacy protection and will exercise appropriate supervision over any external contractors entrusted with handling personal information. The key security management measures are as follows: (Formulation of Basic Policy) We have formulated a basic information security policy to ensure the proper handling of personal data. (Organizational Security Measures) We have appointed managers and personnel responsible for handling personal data, clearly defined their roles, and continuously audit, evaluate, review, and improve the handling status. Department heads conduct regular checks and implement audits, including providing guidance to employees who violate internal rules. In the event of a personal data leak or signs thereof, we have established a reporting system to the Personal Information Protection Administrator and regularly check on entrusted contractors. (Rules for Handling Personal Data) We have established regulations for handling personal data that define procedures, responsibilities, and duties at each stage: acquisition/input, transfer/transmission, use/processing, storage/backup, and deletion/disposal. (Human Security Measures) We prevent personal data leakage by concluding confidentiality agreements with employees upon hiring and with external contractors. Department managers are appointed to disseminate these rules and conduct internal training for all employees. (Physical Security Measures) We strictly enforce locking mechanisms and manage the entry and exit of employees in areas where personal data is handled. (Technical Security Measures) We implement access controls to limit the scope of personnel and the personal information databases they handle. We have introduced mechanisms to protect information systems handling personal data from external unauthorized access and malicious software. (Understanding the External Environment) We implement security management measures after understanding the legal systems regarding the protection of personal information in foreign countries where our personal data is managed. 3. Handling of Personal Information 1) Name of the Business Operator Handling Personal Information Nikko Co., Ltd. 1013-1 Eigashima, Okubo-cho, Akashi, Hyogo, Japan Tomomi Nakayama, President and Representative Director 2) Purpose of Use The Company will specify the purpose of use for personal information and use it only within the scope necessary to achieve that purpose, except as required by law. The specific purposes of use are detailed in the separate "Detailed Rules on the Purpose of Use of Personal Information." (117 KB) 3) Proper Acquisition The Company will acquire personal information by proper and lawful means within the scope necessary to achieve the purposes specified in Section 2 above. 4) Joint Use The Company may jointly use acquired personal information with its subsidiaries and affiliates under the following conditions: Items of Personal Information for Joint Use: Name, company name, department, title, address, telephone number, fax number, email address, etc. Scope of Joint Users: Subsidiaries and affiliates of the Company. (A list is available here: https://www.nikko-net.com/en/company/group.html) Purpose of Joint Use: The purposes stated in Section 2 above. Party Responsible for Management: Nikko Co., Ltd. 5) Provision to Third Parties The Company will not provide personal information to third parties without obtaining the prior consent of the individual, except as stipulated by law. 6) Procedures for Disclosure Requests The Company will respond appropriately and promptly to procedures for disclosure requests, etc., as stipulated by the Act. 7) Inquiries The Company will respond appropriately and promptly to opinions and requests regarding the handling of personal information. For inquiries regarding our handling of personal information and security measures, or for complaints and disclosure requests, please contact the following desk: Contact Desk: General Affairs Section, Human Resources Department, Nikko Co., Ltd. Address: 1013-1 Eigashima, Okubo-cho, Akashi, Hyogo 674-8585, Japan Telephone: +81-78-947-3131 Hours: Monday to Friday, 8:00 AM – 5:00 PM JST (excluding national holidays and year-end/New Year holidays) Inquiry URL: https://www.nikko-net.com/en/contact/
