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Basic Policy

Ryoyo Electro Corporation (hereinafter, the “Company”) and its group companies (hereinafter, the “Group”) recognize the importance of protecting privacy. In all the countries and regions where the Group does business, the Group observes the laws, regulations and other norms and guidelines, etc., pertaining to the handling of personal information acquired in the course of its business operations that belongs to customers, trading partners, shareholders, employees (officers, regular employees, dispatched employees, part-time employees), and employment applicants, etc., (hereinafter, collectively referred to as “you” or “your”). The Group strives to practice continual review and improvement in the areas of providing education to employees, developing the requisite safety measures and corporate structures, and properly managing personal information in accordance with the Ryoyo Group Code of Conduct and ISO Management System Activities Policy.

Moritaka Nakamura

Representative Director, President and Chief Executive Officer

Ryoyo Electro Corporation

Last revision on September 1, 2023

1. Acquisition of Personal Information

We will acquire your personal information to the extent appropriate and through lawful and fair means, upon notifying you of the purpose and manner of use in advance.

2. Types of Personal Information to be Acquired

The types of the personal information acquired from you shall be as follows:

  • Personal information acquired through business activities in general, such as business card information.
  • Personal information acquired through sales activities and provision of services in general.
  • Personal information acquired through planning, development, design and manufacturing of products and services, etc.
  • Personal information required for payment or settlement when we provide products or services.
  • Personal information acquired through trading of secondhand items.
  • Personal information of shareholders.
  • Personal information of employees (including their family members).
  • Personal information of employment applicants acquired through employment activities.
  • Personal information acquired from images of security cameras.

3. Purpose of Use of Personal Information Acquired

The Group will use the personal information acquired within the scope of the following purposes. If the Group uses the personal information for any purpose other than the following purposes, the Group will specify the purpose of use and obtain consent from the owner of the personal information in each case. The Group will notify the owner of the personal information of, or publicly disclose, any change in the purpose of use.

(i) Purpose of use of the personal information of customers and business partners

    • Providing information about products and services, etc.
    • Planning, developing, designing and manufacturing products and services, etc.
    • Processing payments when selling products or providing services, etc.
    • Delivering products and services and providing related maintenance and other after-sales services.
    • Responding to inquiries and complaints and providing consultation services about products and services.
    • Providing information about or operating exhibitions, seminars, training, prize competitions, contests and other events hosted, co-hosted, supported or sponsored by the Group.
    • Responding to inquiries and requests by you and providing consultation services, etc., to you.
    • Performing questionnaires or other marketing activities for improvement of services and operating websites.
    • Trading secondhand items.
    • Leasing real properties.

(ii) Purpose of use of the personal information of shareholders

    • Undertaking administrative procedures for the exercise of rights and performance of obligations of shareholders under the Companies Act, etc.
    • Providing shareholder special benefit services and delivering IR information.

(iii) Purpose of use of the personal information of employees (including former employees)

    • Employment management.
    • Payment of salaries, etc.
    • Settlement of expenses for travel, business trips, etc.
    • Provision of health and welfare benefits.
    • Health management, etc.
    • Ensuring security and safety related to crime prevention and management of office access.
    • Ensuring security and safety related to disaster prevention and confirmation of personal safety.
    • Supporting sustainability-related efforts such as sporting events and conducting social contribution activities.
    • Undertaking administrative procedures for former employees and communication as necessary related to social gatherings, etc.

(iv) Purpose of use of personal information of employment applicants

    • Performing employment activities, selection of employment applicants, and the procedures for employment of prospective employees.

Notwithstanding, the Group may use your personal information beyond the scope of the purposes of use indicated in the foregoing items in the event that:

    • Such use is required under the relevant laws and regulations;
    • Such use is necessary for the protection of the life, body or property of an individual and it is difficult to obtain consent from the owner of the personal information;
    • Such use is specifically necessary for improving public health or promoting the sound growth of children and it is difficult to obtain consent from the owner of the personal information;
    • Such use is necessary for cooperating with a government agency or a local government or an entity entrusted by such agency or government in executing the affairs prescribed by laws and regulations and obtaining consent from the owner of the personal information is likely to interfere with the execution of the affairs.

4. Disclosure and Provision of Personal Information to Third Parties

The Group will not disclose or provide your personal information to any third party without your consent, except in the event that any of the conditions listed below applies. Also, your personal information, including sensitive information, will not be disclosed or provided to a third party under any circumstances, unless prescribed by laws and regulations, or with your consent. Note that provision of personal information in the course of joint use or outsourcing is not deemed to constitute disclosure or provision to third parties.

(i)    You have given consent yourself.

(ii)   Disclosure or provision is required within the scope allowed by laws or regulations.

(iii)  Disclosure or provision is necessary to protect human life, health, or property, and it is difficult to obtain your consent.

(iv)  Disclosure or provision is necessary to cooperate with the official affairs of national or local governments, etc., and it is difficult to obtain your consent.

(v)   Information is disclosed or provided as statistical data (in a form that is not personally identifiable).

(vi)  Information is provided in conjunction with the succession of business due to a merger, company split, transfer of business, or other reason.

5. Joint Use

The Group may use your personal information within the Group to the minimum extent necessary in conjunction with the uses outlined below.

(i) Use within the Group

    • Scope of joint users
      Group companies in and outside Japan:
      https://www.ryoyo.co.jp/en/corporate/network/
    • Purpose of use by joint users
      Purposes listed above in “3. Purpose of Use of Personal Information Acquired”
    • Items of personal information of customers and business partners to be jointly used
      Name of placement of employment (company name, etc.), affiliation, job title, name, address, telephone number, facsimile number and e-mail address and other contact information; results of questionnaires performed for the improvement of services.
    • Items of personal information of employees to be jointly used
      Name of placement of employment (company name, etc.), affiliation, job title, name, gender, age (date of birth), face shot, telephone number, e-mail address and other contact information.

(ii) Name, address, and representative of the party responsible for management and operation of your personal information for joint use within the Group

Moritaka NakamuraRepresentative Director, President and Chief Executive OfficerRyoyo Electro Corporation1-12-22 Tsukiji, Chuo-ku, Tokyo 104-8408

(iii) Outsourcing of operations to outside business operators

in order to accomplish the purposes of use as specified to you, the Group may outsource some related operations to outside business operators and may provide your personal information to them to the minimum extent necessary to perform the operations. In such cases, the Group will conduct appropriate management of outside business operators, including establishing agreements with operators concerning their handling of your personal information.

(iv) Inquiries to credit card companies and other financial institutions

If you have purchased products or services or used the paid membership services or in any other similar cases, the Group may refer the card number of your credit card or other payment card and your name, etc., to the relevant credit card company or other financial institution for the purpose of payment settlement, etc.

6. Transferring Information Internationally

In the event that the Group jointly uses your personal information within the Group in order to accomplish a specified purpose of use within the scope of that purpose of use, the personal information may be transferred internationally from the country where a group company is located to another country where a group company is located.

In the event that the Group transfers your personal information internationally, including to joint users within the Group or outsourced business operators, the personal information will be provided on the basis of your consent, except in the event that either of the conditions listed below applies:

(i) The third party to which the transfer is being made is located in a country prescribed by laws and regulations as a country with a personal information protection system equivalent to that of Japan; or

(ii) The third party to which the transfer is being made has in place a system necessary to continuously take measures equivalent to the measures business operators handling personal information in Japan would be expected to take.

Note that in the case of (ii) above, each group company will take necessary and appropriate measures to ensure that the third party takes the corresponding measures on an ongoing basis. If you wish to confirm the details of these measures, please make a request in accordance with “11. Requests Concerning Handling of Personal Information.”

7. Collection of Information from Your Device

On the Group’s webpages, the Group or third parties authorized by the Group may use technologies such as cookies and web beacons to collect browsing history and other information from your device (such as a PC, smartphone, or tablet).

(i)    About Cookies and Web Beacons

A “cookie” is a means of exchanging information between the browser of a website visitor and a web server. The use of cookies allows the website to identify your browser. Web beacons are small image files embedded in a website. The use of web beacons enables the website to recognize information, such as whether and how often you have visited the website. Cookies neither identify you individually nor cause any damage to your computer.

If you do not want information collected using cookies, you can configure your internet browser settings to disable the cookies function. Please note that disabling cookies may prevent you from using some functions such as contact/inquiry forms. Please contact the software provider for instructions on how to configure your browser settings.

(ii)   Information Collection by the Group

The Group may collect browsing history and other information when you visit websites operated by the Group. The Group (including companies entrusted by the Group for research, analysis, etc.) employs the collected information to make the website more convenient for users, and to provide better services to users by analyzing overall access trends and patterns. The information collected will be treated as confidential, the same as with your personal information.

(iii)  Information Collection by Third Parties

On websites operated by the Group, third parties authorized by the Group may collect browsing history and other information from your device. Details of information transmission from your device to third parties for each website are as follows. Please note that information may also be shared with third parties from websites not listed below.

・List of collection tools of information per website >

8. Management of Personal Information, etc.

In collecting your personal information, the Group will implement necessary and appropriate safety management and security measures in line with current technological standards in order to prevent unauthorized access to personal information or loss, falsification, leakage, damage, etc.

(i)    Formulation of our basic policy

In order to ensure the proper handling of personal data across our entire organization, we have included information security as a fundamental policy in the Ryoyo Group Code of Conduct, explicitly to defend against cyber security attacks, protect personal information, and prevent the leakage of confidential information.

(ii)   Information security management system (ISMS) use

The Group uses an ISMS with a framework compliant with ISO 27001 standards to implement full management and security measures, while also implementing plan-do-check-act (PDCA) cycles to ensure appropriate operation of the ISMS.

(iii)  Safety management measures

The Group carries out periodic education and training for employees, employee entry/exit management, information terminal management, communication encryption, access control, periodic vulnerability management of information systems, etc.

9. Period of Retention of Your Personal Information

The Group will retain personal information acquired from you by the Group for a period necessary for fulfilling the purpose of use or a period required by law, and will erase such personal information promptly when it is no longer needed.

10. Handling in Cases where Provision of Personal Information Is Not Desired

If you do not desire to provide your personal information, you may refuse to provide your personal information at your own discretion. In this case, please be aware that some services of the Group may not be available to you.

11. Requests Concerning Handling of Personal Information

If the Group receives requests, submitted in the manner specified, for the disclosure, correction, deletion, addition, discontinuance of use, or erasure of customers’ personal information that is stored in databases held by the Group or for the provision of information concerning personal information protection measures from the customers themselves through the means indicated in “12. Contact for Disclosure Requests and Other Inquiries” or through the contact form in the “CONTACT” section, the requests will be handled as appropriate in the manner described below. This will be done in accordance with laws and regulations concerning personal information protection, and within a reasonable timeframe and scope, after confirming whether the request was submitted by the customer themself or an authorized representative. However, this may not apply in cases where the Group has no obligation to respond to such requests.

(i)    Requests for disclosure

Items of personal information, purposes of use, or records on the provision of personal information to third parties will be disclosed as requested by customers. While no fees will be charged when requests for disclosure are made with the acceptance of response by email, please be aware that if printed documentation is desired, a fee (¥500 in postage) will be requested.

(ii)   Requests for correction, deletion, or addition

Correction, deletion, or addition of personal information will be performed to the extent appropriate and feasible after due review of the request.

(iii)  Requests for discontinuance of use or erasure

Items of personal information specified by the customer will cease to be used or will be deleted to the extent appropriate and feasible in accordance with the submitted request. However, please be aware that such requests may prevent customers from being provided with services that they had heretofore been able to use.

(iv)  Requests for provision of information concerning personal information protection measures

Information regarding the following items will be provided in accordance with customers’ requests:

    • Details of the safety management measures taken by the Group in collecting customers’ personal information; and
    • Details of measures taken by the Group when providing customers’ personal information to third parties outside of Japan.

The Group may be unable to fulfill customers’ requests if compliance with such requests would seriously impact the Group’s business operations, violate relevant laws and regulations, or disrupt the safety management of personal information.

12. Contact for Disclosure Requests and Other Inquiries

For inquiries regarding the Group’s disclosure, correction/addition, deletion/erasure, or suspension of use or suspension of provision to third parties of personal information collected from customers, or to request notifications on the purposes of use of personal information, please contact us here.

13. Revisions

In the event that revising this policy would be in the best interests of customers or could reasonably be considered necessary or appropriate, the Group may make revisions at its own discretion. If certain procedures are required by Japan’s Act on the Protection of Personal Information or other laws and regulations in making revisions, revisions will be made in accordance with relevant laws and regulations.

Note that in the event the Group makes revisions to this policy, details of the revisions and the time when they go into effect will be announced by posting this policy on the Company’s website. Use of the Group’s services after revision of the policy will be deemed to indicate consent to the revised policy.

14. Appropriate Handling of Specific Personal Information

The Group’s Basic Policy Concerning Appropriate Handling of Specific Personal Information can be accessed below.

Basic Policy Concerning Appropriate Handling of Specific Personal Information >

CONTACT

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