Handling of Personal Information

2. Personal Information Protection Manager and Contact Information

• ITFOR Inc.
• General Affairs Division, Human Resources Department
• Manager: Masamichi Ejiri
• Address: Ichibancho Tokyu Bldg. 21 Ichibancho, Chiyoda-ku, Tokyo 102-0082
• Phone: +81-3-5275-7841
• E-mail: privacy@itfor.co.jp

3. Purpose of Use of Personal Information Obtained by Methods Other Than Direct Written Acquisition

• Personal information of investors and analysts
  • For invitations to IR briefings and related events.
• Personal information related to contracted services
  • For the fulfillment of contracts.

4. Purpose of Use of Retained Personal Information

1. Personal information of customers
   1. Business communications.
   2. Fulfillment of contracts.
   3. Provision of information and promotional materials related to products/services, analysis and statistics of promotional effectiveness, and subsequent improvements.
   4. Planning and proposals related to products/services.
   5. Invitations to seminars, exhibitions, and other events.
   6. Information on our sales activities.
   7. Responses to inquiries or requests.
2. Personal information of business partners
   1. Business communications.
   2. Fulfillment of contracts.
   3. Responses to inquiries or requests.
3. Personal information of visitors to our premises (excluding open areas)
   1. To ensure the security of our company.
4. Personal information of participants or applicants to seminars/events hosted or attended by our company
   1. Invitations to future similar seminars/events.
   2. Analysis and statistics of seminar/event outcomes and subsequent improvements.
5. Personal information of email newsletter subscribers
   1. Distribution of email newsletters, analysis and statistics of their effectiveness, and subsequent improvements.
6. Personal information of individuals who contact our company
   1. Confirmation and responses to the content of inquiries.
7. Personal information of job applicants
   1. Dissemination of recruitment information and dispatch of materials.
   2. Notifications related to selection processes and dispatch of documents.
   3. Communication with prospective employees.
   4. Responses to inquiries or requests.
8. Personal information of our employees
   1. For personnel and labor management purposes.
9. Personal information of shareholders
   1. Exercise of rights and fulfillment of obligations based on laws and regulations.
   2. Provision of various information related to shareholder status.
   3. Management of shareholder data in accordance with prescribed standards based on various laws and regulations.
   4. Responses to inquiries or requests.

5. Delegation of Handling of Retained Personal Information

To achieve the purposes of use mentioned above, we may delegate certain business operations, including the handling of personal information.

6. Provision of Retained Personal Information to Third Parties

We do not provide personal information to third parties without the consent of the individual, except in the following cases as permitted by law:

• When required by law.
• When it is necessary to protect human life, body, or property, and obtaining consent is difficult.
• When particularly necessary to improve public health or promote the sound growth of children, and obtaining consent is difficult.
• When cooperation is required with a national or local government agency or its designee in executing affairs prescribed by law, and obtaining consent may impede those affairs.
• When disclosed or provided to third parties, such as subcontractors, within the necessary scope of business operations.
• When the third party is an academic research institution, etc., and it is necessary for them to handle the personal data for academic research purposes (including cases where part of the purpose is academic research, except where there is a risk of unjustly infringing on the rights and interests of individuals).

7. Measures Taken for the Safe Management of Retained Personal Data

Our main measures for the safe management of retained personal data include:

• Formulation of Basic Policy
  • Establishing a basic policy for proper handling of personal data, ensuring compliance with laws and guidelines.
• Development of Rules for Handling Personal Data
  • Establishing handling methods, responsible persons, and duties for each stage, including acquisition, use, storage, provision, deletion, and disposal.
• Organizational Security Measures
  • Appointing a person responsible for handling personal data and clarifying the scope of data handled by employees.
  • Establishing a reporting system for violations or signs thereof.
• Personnel Security Measures
  • Conducting regular training for employees on handling personal data.
  • Including confidentiality provisions in employment regulations.
• Physical Security Measures
  • Managing entry and exit of employees in areas handling personal data and restricting devices brought in.
  • Preventing unauthorized access to personal data.
  • Implementing measures to prevent theft or loss of devices, electronic media, and documents handling personal data.
• Technical Security Measures
  • Implementing access controls to limit access to personal data.
  • Installing mechanisms to protect personal data systems from unauthorized access and malware.
• Understanding External Environments
  • If handling personal data in foreign countries, ensuring understanding of local laws and taking necessary safety measures.

8. Contact for Complaints and Inquiries Regarding Personal Information Handling

Please direct opinions, questions, or complaints regarding the handling of personal information to the following:

• ITFOR Inc. General Affairs Division
• Address: Ichibancho Tokyu Bldg. 21 Ichibancho, Chiyoda-ku, Tokyo 102-0082
• Phone: +81-3-5275-7841
• E-mail: privacy@itfor.co.jp

9. Procedures for Requests for Disclosure, etc.

1. Contact for Requests for Disclosure, etc. (Notification of Purpose of Use, Disclosure, Correction, Addition, or Deletion of Content, Suspension of Use, Erasure, and Suspension of Provision to Third Parties)
   1. Please direct your request to the contact listed in Section 8 above.
2. Method for Requesting Disclosure, etc.

   1. Please send the designated 'Personal Information Disclosure Request Form' to the contact address listed in Section 8 above.
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3. Purpose of Use of Personal Information Obtained for Disclosure Requests, etc.

   1. Personal information obtained for a disclosure request, etc., will not be used for purposes other than responding to the request.