SHIMOMURA KIHAN CO., LTD. (hereinafter referred to as “the Company”) recognizes that the protection of personal information that it obtains in the course of its business activities is an important social mission, and that it has a serious duty to safeguard said personal information. In order to gain the trust of society at large, including those who entrust us with their information, we have established and published the following Privacy Policy to ensure that personal information is handled appropriately. In addition, we shall promptly respond to complaints and consultations regarding the handling of personal information, and review and improve, as appropriate, our handling of personal information and appropriate measures for its safe management.

1. Acquisition and Purposes of Use of Personal Information

When acquiring personal information from customers, the Company shall notify or publicly announce in advance the purposes for which the information will be used, and shall acquire the information in a lawful and fair manner. In addition, the Company shall specify the purposes for which the personal information of customers is to be used and shall use it appropriately only to the extent necessary to achieve these purposes. The Company shall not use personal information for any purpose other than the publicly announced purposes of use, except in cases where the Company has obtained the prior consent of the person concerned or where required by law.

2. Joint Use of Personal Information

The Company shall share the personal information of customers with other companies in the Shimomura Group. For this purpose, the Company shall disclose in advance the items of personal information to be shared, the names of the joint users, and the purposes of use, and shall assume responsibility for the joint use of the said personal information.

3. Provision of Personal Information to Third Parties

The Company shall not provide customers’ personal information to any third party without obtaining prior consent from the customer in question, except when required by law or when necessary to fulfill the terms of a contract with the customer.

4. Accuracy and Security Management of Personal Information

The Company shall take organizational, personnel, physical, and technical safety measures to prevent the loss, destruction, falsification, and leakage, etc. of customers’ personal information, and shall take necessary corrective measures. In addition, when handling customers’ personal information in foreign countries, the Company shall take necessary and appropriate measures for the safe management of personal information, based on its knowledge of the systems for the protection of personal information in such foreign countries. Furthermore, in the event that the handling of personal information is outsourced to an external contractor, the Company shall conclude a contract with the contractor regarding the handling of personal information and supervise the contractor appropriately.

5.Requests for Disclosure of Personal Information

In the event that a customer requests the disclosure, correction, suspension of use, deletion, suspension of provision to third parties, or disclosure of records of provision to third parties with respect to personal information that the customer has entrusted to the Company, the Company shall respond appropriately in light of laws, regulations, and socially accepted norms.

Handling of Customers’ Personal Information

The purpose of use of customers’ personal information is as follows. In compliance with our Privacy Policy, we shall carefully handle the personal information of customers in the following manner.

1. Purposes of Use of Customers’ Personal Information

(1) Purposes of Use of Customers, Personal Information
The Company shall use the personal information it obtains or retains for the following purposes.

1. (1) Provision of information on the Company’s products and services
2. (2) Provision of support services concerning the Company’s products and services (e.g., repair of the Company’s products, etc.)
3. (3) Planning, research and development to improve the Company’s products and services
4. (4) Implementation of sales promotion activities for the Company’s products and services, such as campaigns, etc.
5. (5) Responding to inquiries from customers
6. (6) Other operations related to the above items

(2) Purpose of Use of Personal Information of Applicants for Employment
The Company shall use the personal information it obtains or retains for the following purposes.

1. (1) Contacting and sending documents and other information related to the selection process
2. (2) Basic data for recruitment activities (interviews, written applications, etc.)

2. Joint Use of Personal Information

1) Items of Personal Information to be Shared

(1) Name
(2) Address
(3) Telephone number
(4) Date of birth
(5) E-mail address
(6) Other items necessary for the purpose of use

2) Scope of Joint Users
Shimomura Group companies, including the following companies.
Shimomura Industrial Co., Ltd.

3) Purposes of Use
As set out above in "1. Purposes of Use of Customers’ Personal Information."

4) Company Responsible for Joint Use

The Company Shall be responsible for the joint use of the personal information of customers.
Address: 4803-4 Koike, Tsubame City, Niigata Prefecture, Japan
Representative: Tatsuhiro Shimomura

3. Provision of Personal Information to Third Parties

The Company may provide the personal information of customers to related parties to the extent necessary to achieve the above purposes of use. When providing personal information to third parties, the Company shall take the necessary measures to maintain confidentiality.

1) Items of Personal Data Provided to Third Parties

As set out above in “1) Items of Personal Information to be Shared” of “2. Joint Use of Personal Information.”

2) Methods Used to Provide Personal Information to Third Parties

The Company provides personal data to third parties by electromagnetic means, electronic media, or paper printouts.

3) Cessation of Provision to Third Parties

The Company shall cease the provision of personal data to third parties if the customer requests that the provision of personal data to third parties be stopped. However, there may be cases in which this may hinder the Company’s ability to provide services, fulfill contracts, or perform administrative tasks.

4. Accuracy and Security of Personal Information

Measures that the Company takes to ensure the accuracy and security of personal information are as described in “4. Accuracy and Security of Personal Information” of SHIMOMURA KIHAN’s Privacy Policy. The following is a more detailed explanation of these measures.

1) Formulation of Basic Policy

In order to ensure the proper handling of personal data, in its Privacy Policy, the Company has established and disclosed its basic policy regarding compliance with laws and regulations related to the protection of personal information, as well as a point of contact for questions and complaints.

2) Establishment of Rules for Handling Personal Data

The Company has established rules for the handling of personal data, including such things as methods, persons responsible and in charge of handling personal data, and their duties.

3) Organizational Safety Control Measures

In addition to appointing a person responsible for the handling of personal data, the Company clarifies the employees who handle personal data and the scope of personal data handled by such employees, and has established a system for reporting to the person responsible in the event that a fact or indication of a violation of personal data protection-related laws or company regulations is detected. The Company has established internal rules for the handling of personal data, carries out periodic self-inspections, and conducts appropriate audits of the status of these rules.

4) Personnel Safety Control Measures

In order to improve the level of information protection, the Company provides regular training to its employees on points to keep in mind regarding the handling of personal data and safety management.

5) Physical Safety Control Measures

The Company takes measures to prevent theft or loss of such things as equipment, electronic media, and documents that handle personal data, and implements measures to ensure that personal data is not easily revealed when such equipment, electronic media, etc. are carried, including within business locations.

6) Technical Safety Control Measures

The Company exercises control over access to limit the scope of persons in charge of the handling of personal data, databases of personal information, and other matters. Measures are taken to protect information systems that handle personal data from unauthorized external access and other scenarios.

5 Requests for Disclosure, etc. of Personal Information

The Company shall respond to requests for the disclosure, etc., of retained personal data of customers within a reasonable period and scope as follows. In order to prevent the leakage of information and ensure the accuracy of information, Company shall request the submission of various certificates from the person in question and each representative.

(1) Persons who are Entitled to make a Request for Disclosure, etc.

1. (1) The customer in question
2. (2) A representative authorized by the customer in question (voluntary representative)
3. (3)Legal representative of a minor or guardian of an adult

2) How to Make a Request

To make a request, please fill out the Company’s request form below in writing and send it by mail to the contact details provided. The required documents to be submitted are as follows.

(1) Company’s request form

(2) A copy of one kind of identification document for the person in question (one of the following)

1. [1] Driver’s license
2. [2] Passport
3. [3] Health insurance card
4. [4] Certificate of seal registration (within 3 months of creation)

(3) Documents required when a voluntary representative makes a request

1. [1] A letter of attorney from the person in question (sealed with a registered seal)
2. [2] One copy of the person’s seal registration certificate (within three months of creation)
3. [3] An identification document for the voluntary representative (one copy of any of the documents [1] to [4] listed above in (2) for the voluntary representative)

(4) Documents required when a legal representative makes a request

1. [1] A copy of one kind of identification document for the person in question (one copy of any of the documents [1] to [4] listed above in (2))
2. (2) An identification document for the legal representative (one copy of any of the documents [1] to [4] listed above in (2) for the voluntary representative)
3. [3] A certificate that confirms the relationship of the legal representative with the person in question (a copy of the family register, a certified copy of the certificate of residence, etc.)

3) Contact for Inquiries

Please refer to the “Inquiries” section below.

(4) Handling Fee

Please be advised that a designated handling fee shall be charged for each request for disclosure of personal information.

(5) Request Forms

Request Form for Disclosure of Personal Information

6 Revision of this Privacy Policy

This Privacy Policy may be revised from time to time in response to such things as amendments or changes in related laws and regulations, or changes in business needs.

Revised March 31, 2023