PRIVACY POLICY

About Personal Information Handling

1. The utilization purpose of personal information at the Company

The utilization purpose of personal information in the Company's possession, in the case of carrying out business affairs, directly obtaining information through means other than written documents, through indirect means of obtaining personal information, or regarding information of those in the Company's employ, are as follows. (1) Utilization purpose ・To exercise our rights and fulfill obligations according to the law and contracts related to our business ・To ensure pertinent and smooth execution of the Company's business ・To make various proposals regarding the services provided by the Company and send them via methods such as direct mail ・To propose technical information in the course of business transactions, make direct contact or send an announcement to facilitate the relevant and smooth performance of such transactions ・To monitor use of information systems and entrance/leave of the people to/from the property in order to maintain the security guarantee of the Company. ・To carry out the Company's employment screening process ・To deal with the comments and inquiries ・To contact the person who sent the inquiries ・Other than above mentioned, when the utilization purpose is specified indivisually for a particular cases to fulfil the purpose When directly obtaining personal information in writing, the utilization purpose will be explicitly stated indivisually in each cases. However, the utilization purpose may not be disclosed, in following circumstances. ・Cases where the disclosure of the utilization purpose is made to the concerned party or announced publically may result in damage to the life, health, property or rights/privileges of the concerned party or any third party ・Cases where the disclosure of the utilization purpose is made to the concerned party or announced publically may result in damage to the rights or legitimate gains of the Company ・Cases where it is necessary to comply with the laws and ordinances executed by national and local government bodies, and where notification to the concerned person or public announcement regarding the utilization purpose would result in the obstruction of the execution of these affairs ・Cases where it is clear what the utilization purpose is recognized (2) The utilization purpose of personal information entrusted to us are as follows ・To ensure the proper implementation and smooth operation of commissioned services

2. The provision of personal information by the Company to third parties

(1) In the case that a comissioned service and registry of the contracted technical staff is submitted ・Information provided: name, age, sex, emergency contact information, closest station to residence, years of experience ・Sent by: email or documentation ・Provided by: those commisioning software development projects ・Contract with provider: contract of agreement to safeguarding personal information (2) Exceptional cases ・Except in cases where one is exempted from the Personal Information Protection Law or other laws, personal information shall not be provided to third parties without the consent of the concerned party. In cases where personal information is entrusted to shipping companies to carry out orders, to financial institutions in order to carry out settlement or other such companies, the necessary personal information provided to these companies to carry out their duties exists outside the sphere of our third party information provision agreement.

3. The entrustment of personal information with the Company

There are cases where the Company may entrust personal information to other businesses to successfully achieve its utilization purposes. In those cases, a contract will be signed with those selected and entrusted with personal information. Information entrusted to the Company shall not be recommissioned without the consent of entrusting parties.

4. Procedures for claims concerning personal information disclosure

Personal information subjected to disclosure includes personal information systematically organized and collected, and which the Company is endowed with the authority to respond to all requests concerning claims by concerned parties concerning the disclosure, correction, addition, omission, discontinuation, deletion, and stoppage of provision to third parties of such information. At the Company, we respond to all claims made by concerned parties (such as clients) regarding matters like disclosure (disclosure, notification of purpose of use, correction, addition, omission, discontinuation, stoppage of third party provision, and deletion) of personal information subject to disclosure. However, personal information entrusted to us under contract from outsourcing agreements with outside firms cannot be provided in response to disclosure requests due to a lack of management rights. Please direct any inquiries to the businesses in possession of personal information. Handling charges for claims relating to personal information disclosure as well as procedures for claims. (1) Procedures for requests of disclosure Please contact us by phone, regular mail or email. We will provide further procedural details upon receipt of the request. Submission of identity verification document will be requested in order to confirm the identity of the inquiring party as that of the concerned party matches. (2) Handling charges Specific fees for each request is charged for disclosure and notification of target personal information. Depending on the claim, appropriate handling fee for the excess workload will be charged. In such cases, you will be provided with the estimation in advance.

5. Items of special mention

(1) Utilization purpose of requests for personal information disclosure Requests for personal information disclosure are handled only to the extent necessary to complete them. (2) Reasons for the non-disclosure of personal information In the following cases, disclosure will not be granted. When such non-disclosure is decided, the main reason will be noted and reported to the claimant. ・Cases where the identity of the concerned party cannot be confirmed due to mismatch of the address in our records and the address recorded on the invoice or in identity confirmation documents ・Cases where inadequate information is provided in fixed invoice documentation ・Cases where the requested person is not objected to the personal information disclosure ・Cases where there is a risk of causing injury or damage to the life, body, assets or other rights of the concerned party or a third party ・Cases where there is a danger of seriously impeding the business operations of this Company ・Cases where such action would violate any other laws or ordinances

6. Contact method for inquiries and grievances related to the handling of personal information

Contact for inquiries and grievances related to the handling of personal information Please contact us through the following methods with regard to inquiries or grievances related to personal information handling: Personal Information Inquiries and Grievances Inquiries Supervisor, Rock Store House Co., Ltd. Telephone:+81-3-3588-6789 (Weekdays, 9:30-17:00) Email:info@rsh.co.jp The personal information obtained from the inquiry email addressed to our contact wil be used only when responding back to the inquiry.

7. The name of the "authorised personal data protection organisation" to which the company is subject and the contact details for resolving complaints

The Company is a covered entity of the following authorised personal data protection organisations. Complaints and consultations regarding the handling of personal data by the company can also be addressed to the same organisation. Name: Japan Association for the Promotion of Information Economy and Society Contact point: Certified Personal Information Protection Organization Secretariat Address: Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo Telephone enquiries: +81-3-5860-7565 / 0120-700-779 *This is not a contact for enquiries about our services.

8. Safety Management Measures

With respect to the handling of personal information, etc., we operate a personal information protection management system that meets the requirements of the Privacy Mark, and we have implemented the following safety control measures for the safe management of such information. (1) Organizational safety control measures We have established internal rules for the safe management of personal information, and ensure that all employees comply with them. Under the supervision of a personal information protection manager, the roles and responsibilities of employees who handle personal information are clearly defined, and necessary and appropriate supervision is provided to employees. Internal audits will be conducted by the personal information protection supervisor to check, maintain, and improve the management of personal information, and if any problems are found, measures will be promptly taken to correct them. (2) Personnel safety control measures All employees shall receive regular training on the personal information protection management system to ensure that they are fully aware of the importance of personal information and to raise their awareness of the need to handle personal information properly. (3) Physical safety control measures The Company shall take measures to prevent theft or loss of personal information by controlling access to the office where personal information is handled, restricting access to the system and documents, and locking the system when storing personal information. (4) Technical safety control measures The Company shall take measures to control access to personal information handled using information systems, prevent unauthorized access, etc., and strive to prevent leakage, loss, destruction, etc., of personal information.

9. Person in charge of personal information (Personal Information Protection Manager)

(1) Position Personal Information Protection Manager (2) Contact E-mail address: privacy@rsh.co.jp

7F, BPR place kamiyatyou Bld., 1-11-9, Azabudai, Minato-ku, Tokyo, 106-0041, Japan
Rock Store House Co., Ltd.
代表取締役 Nobuhiko Iwakura