PRIVACY POLICY

Personal information protection policy

Kumahira Co., Ltd. (hereinafter referred to as "the Company") recognizes the importance of information that can identify specific individuals (hereinafter referred to as "personal information") handled in developing, manufacturing, and selling security products and services that provide "safety" and "security" to people. In order to ensure the protection of personal information at the Company, the Company will establish the following personal information protection policies, establish rules and organizational structures for the protection of personal information, and establish and operate a personal information protection management system.

1. Acquisition, use, provision and delegation of appropriate personal information

When acquiring, using, providing, and entrusting personal information, we shall comply with the regulations stipulated by us and take measures to ensure that personal information is not handled for any purpose other than the purpose of use.

2. Compliance with laws and other standards concerning the handling of personal information

We will comply with all laws, regulations, and other rules governing the handling of personal information, as well as the guidelines and other rules set forth by the government, and will conform our regulations and organizational structure to these laws, regulations, guidelines, and other rules.

3. Prevention and correction of leakage, loss or damage of personal information

We will take appropriate safety measures to prevent leakage, loss, or damage of personal information handled, and take corrective measures as necessary.

4. Response to complaints and consultations

We will respond promptly to complaints and inquiries about the protection of personal information.

5. Continuous improvement of personal data protection management system

We will continuously improve our personal information protection management system to maintain the effectiveness of the system.

Established August 1, 2020
Revised December 1, 2022
Kumahira Co., Ltd.
Akinobu Kumahira, President and CEO

For inquiries about the protection of personal information

1-42, Ujina-higashi 2-chome, Minami-ku, Hiroshima-city, Hiroshima
Corporate Management Division, Kumahira Co., Ltd.
TEL: 082-251-2111 FAX: 082-252-7024
E-mail:privacy@kumahira-safe.co.jp

Handling of personal information

In accordance with the “Act on the Protection of Personal Information” and our “Personal Information Protection Policy”, we will handle and protect personal information handled in the course of business as follows.

1. Purpose of use of personal information

We use personal information for the following purposes.
(1)Personal information about employees

1. For work related to personnel management such as transfer, evaluation, commendation, disciplinary action, etc.
2. For work related to the treatment of salary, bonus, retirement allowance, etc.
3. For operations based on laws and regulations such as taxes, social insurance, and labor insurance etc.
4. For work related to occupational safety and health such as health management
5. For work related to welfare
6. For the purpose of duties pertaining to education and training
7. For recruiting operations
8. For the purpose of information transmission such as business communication and emergency communication
9. For internal system use (ID, password, e-mail address, etc.)
10. For personnel and labor management related to or incidental to the above

(2)Personal information on customers, suppliers, and other business partners

1. To respond to inquiries, requests for materials, and other requests related to transactions, etc.
2. For the purpose of providing products and services we handle, as well as giving notices and information on related services
3. For the purpose of linking our products and services handled by us with products and services handled by affiliated service providers
   (see SPLATS Partner page for more information)
4. For the performance of any agreement entered into with us
5. To request customer satisfaction surveys etc. , and to develop better products and services
6. For other purposes for which prior consent has been obtained

※In order to enable Bluetooth function, some products and services handled by the Company or affiliated service providers must be permitted to use the location information services on some information terminals.
(3)Personal information on shareholders and shareholding members of Kumahira Holdings

1. For the purpose of exercising rights and fulfilling obligations under the Companies Act

(4)Personal information concerning the recruitment applicants

1. For recruitment selection and internal employee management

(5)Personal information about the subjects of security cameras installed in our facilities

1. For the prevention of crime and the maintenance of safety in the facility

(6)Personal information about retirees

1. For the payment of retirement pensions
2. For necessary communication such as information on OB meetings and company status

(7)Personal information about readers of publications

1. For publication delivery

(8)Personal information about the participants in the event

1. For information on the next event and sending relevant information

2. Use of data related to personal information

Some products and services handled by us or our affiliated service providers collect personal information (Cookie, etc.) in order to improve the convenience of our customers.

3. Measures taken for safety management

When handling collected personal information, we will appropriately implement organizational, human, physical, and technical security management measures.
(1) Organizational security control measures

1. We have established an organizational structure for the protection of personal information and have established internal rules for the management of personal information.
2. We regularly audit the status of personal information protection and make continuous improvements.

(2) Human security control measures

1. We provide education on the handling of personal information to all employees.
2. All employees are required to sign confidentiality agreement.

(3) Physical security control measures

1. We take security measures to ensure that the areas where personal information is handled and the and equipment and fixtures where personal information is stored are accessible to only related parties.
2. When disposing of personal information and equipment that used to handle personal information, personal information is processed and disposed of in a manner that makes it impossible to restore personal information.

(4) Technical security control measure

1. Appropriate access rights are set on devices and media used to manage personal information, and measures are taken to ensure that only relevant parties can access such information.
2. For the security measure of malware threats, we install the latest version of antivirus software and perform regular checks.

4. Provision to third parties

We will not provide your personal information to any third party without obtaining the consent of the principal except in the following cases:

1. In accordance with laws and regulations
2. When it is necessary to protect a person's life, body, or property and it is difficult to obtain the consent of the person
3. When it is especially necessary to improve public health or to promote the sound growth of children and it is difficult to obtain the consent of the individual concerned
4. When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the consent of the individual is likely to impede the execution of such affairs.

5. Entrustment of personal information

When we outsource the handling of personal information, we select a subcontractor that maintains a certain level of personal information protection and supervise it to ensure proper handling.

6. Procedures for disclosure of personal information

We will respond to requests from the Principal or his/her agent for notification, disclosure, correction, addition or deletion, suspension of use, deletion or discontinuation of provision to a third party, and disclosure of records of provision to a third party (hereinafter referred to as "Disclosure") of Retained Personal Data as follows.
(1)Procedures for offering disclosure, etc.
Requests for disclosure, etc. shall be made by attaching the necessary documents for identification to the prescribed application form, enclosing a postage stamp equivalent to the prescribed fee, and mailing it to the address to which the following application form is sent. The application may not be accepted even if you call or visit the Company directly.

1. Application for disclosure of personal data
2. Application for correction, etc. of retained personal data

< Documents for identity confirmation >

1. One copy of official documents such as driver's license or passport

Incidentally, if the person who makes the “Request for Disclosure” is the legal representative or the agent authorized by the principal, please enclose the following documents in addition to the documents mentioned in the preceding paragraph.
< In the case of a legal representative >

1. One copy of legal representative return form
2. One copy of the document confirming the statutory authority of representation
   (A copy of the family register. In the case of a person who has parental authority, a copy of the insurance certificate containing the dependents may be accepted.)
3. One copy of document confirming that the person is the legal representative of a minor or an adult ward
   (Copy of official documents such as a driver's license or passport of a legal representative)

< In the case of a proxy by delegation >

1. One copy of power of attorney
2. One copy of certificate of the person's seal impression
3. One copy of the document confirming that he/she is an agent.
   (Copy of official documents, such as an agent's driver's license or passport)

(2)Fees for "Request for Disclosure" and the method of collection thereof
It will cost the person who makes the “Request for Disclosure” 1000 yen per notification of the purpose of use and request for disclosure. Please enclose the same amount of postage stamps in the request form. If the fee is insufficient or not enclosed, or if the payment is not made within the prescribed period, we will respond as if there was no request for disclosure.
(3)How we will respond to the “Request for Disclosure”
Respond to the contact address on the applicant's application in the manner specified by the applicant. However, we may change the method of response if it is difficult to disclose by the specified method due to the large amount of cost required for disclosure by the specified method.

7. Manager of Protection of Personal Information

Head of Corporate Management Division of Kumahira Co., Ltd.

8. Contact for complaints, consultations, inquiries, and requests for disclosure of personal information

1-42, Ujina-higashi 2-chome, Minami-ku, Hiroshima-city, Hiroshima
Corporate Management Division, Kumahira Co., Ltd.
TEL: 082-251-2111 FAX: 082-252-7024
E-mail: privacy@kumahira-safe.co.jp