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About Personal Information Protection

Enacted on April 1, 2005
Revised on April 1, 2026
Astemo Business Solutions, Ltd.
President & CEO
Manabu Ishii
4-7-1 Onna, Atsugi-shi, Kanagawa-ken,
243-8510 Japan

1.Background of the Personal Information Protection Policy of Astemo Business Solutions, Ltd.

As a company that provides solutions to address a wide range of customer challenges across all business settings, Astemo Business Solutions, Ltd. ("Astemo-BS" or “Our Company”) handles a variety of information, including information entrusted to us by our customers. For this reason, Astemo-BS has established and fully implemented an information management system that respects the value of such information.
With this background, Astemo-BS endeavors to create rules and establish a management system to protect personal information protection in Astemo-BS, as well as to set a personal information protection policy and spread it among board members and employees. Moreover, Astemo-BS will take measures to make its personal information protection policy easily accessible to the general public.
Based on the policy stated above, Astemo-BS shall strive to protect appropriately the personal information we own.
Astemo-BS complies with Japan's Act on the Protection of Personal Information, as well as other applicable personal information protection and privacy protection laws and regulations in countries or regions—including but not limited to the EU General Data Protection Regulation (EU GDPR), UK General Data Protection Regulation (UK GDPR), and California Consumer Privacy Act (CCPA) (hereinafter collectively referred to as the “Applicable Laws”)—and strives to handle personal information appropriately.

2.The Personal Information Protection Policy (of Astemo Business Solutions, Ltd.)

  1. Establishment of personal information management rules and continuous improvement of the personal information protection management system

    Astemo-BS will ensure that executives and employees recognize the importance of personal information protection, establish personal information management rules to appropriately use and protect personal information, and steadily implement the personal information protection management system. Furthermore, we will maintain and continuously improve it.

  2. Collection, use, and provision of personal information, and prohibition of use for purposes other than the intended purpose

    While carefully considering the personal information entrusted to us in our Company activities, Astemo-BS will handle such information appropriately by establishing a management system for personal information protection for each type of business, and also by following our rules for collecting, using or providing personal information. In addition, Astemo-BS will not use such information for purposes other than the original intent and will implement appropriate measures for them.

  3. Implementation and correction of safety measures

  4. Compliance with laws and norms

    Astemo-BS will follow the Japanese laws, guidelines and other norms for the handling of personal information. Also, Astemo-BS will conform to its rules with personal information management regarding such laws, guidelines and other norms.

  5. Respect for the rights of individuals regarding personal information

    When a person makes a request to disclose, correct or delete his or her own personal information, seeks to prevent the use or provision of such information, or gives any complaints or requires consultation, Astemo-BS will respond with sincerity, respecting the person's rights related to that personal information.

3.Scope of Application

This "About Personal Information Protection" page establishes Astemo-BS's procedures for handling personal information.

4.Definition of Personal Information and Activity of its Protection

Astemo-BS shall define that personal information means information about an individual that is defined as personal information under the Applicable Laws.
Astemo-BS shall define that personal information means information about an individual that is defined as personal information under the Applicable Laws.

  1. Prompt and appropriate response to the exercise of rights by individuals
  2. Transparency in outsource processing, including clarification of whether outsourcing is to be used and the details of the outsourced operations
  3. Clarification to the individuals of the purposes for which personal information is used
  4. Specifying to the greatest extent possible explicit statements of the sources from which personal information was obtained and the methods of acquisition, etc., upon the individual’s exercise of rights

5.Handling Policy of Personal Information - Collection/Usage Purpose and Provision to Third Party

  1. In relation to Astemo-BS's business activities, Astemo-BS shall obtain and utilize personal information within the scope required only to achieve the following:
    1. Execution of a contract concluded between Astemo-BS and a customer, or the individual.
    2. Contacts for business negotiations and meetings with a customer or the individual.
    3. Delivery of after-sales service on products, and sending information regarding events and new products.
    4. Execution of services entrusted to Astemo-BS by customers.
    5. Response to various inquiries from customers.
    6. Analysis based on questionnaires to improve our services.
    7. Provision of personal information to our group companies when conducting joint operations.
    8. Security and safety management by using security cameras and/or any other equivalent devices.

    For each of the above items, when Astemo-BS requests that a person provides personal information directly in writing (including electronic means such as the web or email), Astemo-BS will clearly state the purpose of collection and use in advance to obtain individual's consent.

  2. Astemo-BS may provide personal information to third parties in the following cases:
    1. Disclosure to Group Companies
      • Astemo-BS may provide the personal information, such as a name, workplace and home addresses, telephone number, fax number, and email address, to Astemo-BS’s group companies when necessary for conducting joint business activities. In such cases, the personal information will be provided via print or electronic media. The person may request Astemo-BS to stop the provision of the personal information to Astemo-BS’s group companies.
    2. Disclosure to Third Parties Outside the Group Companies
      • Astemo-BS may disclose personal information to third parties as required by the Applicable Laws, or to Astemo-BS’s employees, contractors, designated agents (including attorneys and accountants), or third-party service providers.
    3. Disclosure to third parties other than those specified in (a) and (b) above
      • Astemo-BS may disclose personal information for the following purposes when permitted or required by the Applicable Laws:
      • To protect Astemo-BS's rights and assets
      • When necessary to protect human safety in an emergency
      • When a business transfer or change in company ownership occurs, and disclosure is necessary to complete the transaction
      • For other purposes where consent is required by laws and regulations and the person has provided consent
      • Cases in which the handling of personal information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations, and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned
      • Cases in which the handling of personal information is entrusted within the scope necessary for acquisition and achievement of the purpose of use
      • Cases in which personal information is provided as a result of the succession of business in a merger or otherwise

6.Handling of Specific Personal Information

  1. Astemo-BS shall comply with the "Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (the "Number Act")", the "Act on the Protection of Personal Information", and the "Guidelines for the Proper Handling of Specific Personal Information (for Business Operators)" with respect to Specific Personal Information in relation to our business activities primarily involving the provision of shared services mainly within the Astemo Group.
  2. Astemo-BS shall treat the Company's "Personal Information Protection Policy" as the "Basic Policy on the Proper Handling of Specific Personal Information" and ensure the proper handling of Specific Personal Information.
  3. Astemo-BS shall obtain and use Specific Personal Information within the scope necessary to achieve stated purposes for the performance of administrative procedures related to social security, taxation, and disaster response as prescribed in each item of Article 9 of the Number Act, as the scope of use of Specific Personal Information. The principal scope of use of Specific Personal Information handled by our Company is as follows:
    1. Administrative work whereby we are provided with Specific Personal Information by employees and others, and have it recorded in the Certificate of Income and Withholding Tax for employment and retirement income, the Report of Salary Payment, employment insurance filings, the Notification of Acquisition of Insured Status for Health Insurance and Employees’ Pension Insurance, and other required statutory forms, for submission to the Director of the Tax Office, municipal mayors, the Japan Pension Service, and other authorities.
    2. Administrative work whereby we are provided with Specific Personal Information, and have it recorded in various payment statements such as the Statement of Payments of Remuneration/Fees, the Statement of Payments of Dividends, Distributions of Surplus and Fund Interest, the Statement of Payments of Real Estate Usage Fees, and the Statement of Payments of Consideration for the Acquisition of Real Estate, etc., for submission to the Director of the Tax Office.
    3. Performance of services entrusted by administrative agencies or other business operators that involve handling Specific Personal Information.
  4. With respect to Specific Personal Information, Astemo-BS will not provide your Specific Personal Information to any third party except as mandated by applicable laws and regulations. We also do not share Specific Personal Information for joint use. However, if any of the items prescribed in Article 19 of the Number Act (Restriction on the Provision of Specific Personal Information) applies, we may provide Specific Personal Information.
  5. Astemo-BS may commission the handling of Specific Personal Information within the scope of the purposes of use prescribed by laws and regulations.
  6. If you wish to request disclosure, correction, addition, deletion, suspension of use, suspension of provision to third parties, or notification of the purpose of use with respect to Specific Personal Information held by Astemo-BS, or to submit a complaint, the procedures shall be as set forth in Our Company’s “10. Requests for Disclosure, etc. of Personal Information, or Raising Complaints”.

7.Implementation of Safety Management Measures

Astemo-BS has formulated a Personal Information Protection Policy and established internal rules, including the Regulations and Guidelines for Personal Information Management, in accordance with the basic principles set forth in the Policy, in order to operate as an organization that ensures the proper handling of personal information. Astemo-BS has also established a system to confirm and evaluate whether its rules conform to the Applicable Laws. Besides developing such regulations, Astemo-BS is taking concrete safety management measures from four specific aspects (systematic, personal, physical, and technical) in handling personal information.
Astemo-BS retains personal information only for the period necessary to process such information. However, if the Applicable Laws require retention for a longer period, Astemo-BS will retain the personal information for the period specified by such Applicable Laws.

8.International Transfer

Astemo-BS will implement appropriate safeguards in accordance with the Applicable Laws when transferring the individual's personal information outside the country or region where the person resides.

9.About Usage of Cookies and Web beacons

For convenience of users, our website uses cookies*1 and web beacons (clear GIFs)*2 in our website.
You can refuse to receive a cookie, or can change the web browser settings to have a warning message displayed when receiving a cookie. For more details, please refer to the instructions of the web browser in use by that person.
Moreover, you can reject a web beacon by refusing the receipt of a cookie.
However, please note a person may not be able to use part or all of our Company’s services provided in the website when rejecting a cookie.

* For individuals residing in countries or regions where the Applicable Laws require the explicit prior consent for the use of cookies (including but not limited to the European Union), Our company has implemented a mechanism to obtain such explicit consent in advance of any cookie usage.

Glossary

  • *1 Cookies:

    Cookies are small text files that are sent from websites to your device for record-keeping purposes. Cookies may be stored as files on your computer’s disk. Cookies are necessary to enable your smooth use of websites and record actions taken on the website.
    At the same time, cookies enable enhancements to functionality, the collection of analytics data to improve performance, the display of personalized advertisements from our site or ad-tech partners by tracking users across the internet, and sharing on social media.
    However, (while cookies identify the user’s device, typically the web browser), unless you provide your personal information on the website, we cannot identify you as an individual.

  • *2 Web beacons:

    Technology that functions with a cookie to check how many times a person accesses a particular page. However, we cannot identify the person, unless he or she enters personal information when receiving cookies.

Cookie Settings

10.Requests for Disclosure, etc. of Personal Information, or Raising Complaints

Regarding the personal information Astemo-BS holds about a person: If the person wants to exercise his/her rights (as defined by the Applicable Laws, which may include disclosure, correction, addition, deletion, suspension of use, cessation of provision to third parties, notification of the purpose of use, or disclosure of records of provision to third parties) or submit a complaint, please follow the procedures below.

  1. Exercising rights regarding personal information that a person submitted to an Astemo-BS's sales department:
    Please contact the relevant sales department.
  2. Exercising rights regarding personal information that a person submitted through Our Company’s web site:
    Please contact the department that manages the relevant web site.
  3. Request to disclose personal information in instances aside from the 1. or 2. above, and complaints regarding our handling of personal information:
    Please contact us using the information listed under “Inquiry About Personal Information Protection” in “13. Inquiries on This Page” below.

* Requests for certificates of employment, resignation, etc., are not accepted through this site.
Please contact the HR and labor department of the office you belonged to at the time of retirement.

11.Requests to Individuals

  1. Most of the services we provide can be used without requiring your personal information. Providing your personal information is generally voluntary; however, for certain services, the provision of your personal information is mandatory. In such cases, we will inform you of the requirement.
    Please note that if you do not provide your personal information to us, there are services we may be unable to provide.
  2. Please note that Astemo-BS is not responsible for the security of personal information of any non-Astemo-BS web site whose link is included in the Astemo-BS's web site.
  3. If a person enters his/her own personal information on Astemo-BS's website, he or she is required to agree upon the provisions in the "About Personal Information Protection" page, otherwise the person will not be able to use our services (including our response to his/her inquiries). Also, if the said person is aged at 14 or younger, he/she must enter the personal information with the consent of a parent or a guardian.

12.Special Note

  1. Astemo-BS may revise the "About Personal Information Protection" page to improve the handling of personal information and/or due to the revision of laws or ordinances, or other rules or regulations.
  2. The implementation of this "About Personal Information Protection" page shall be after the issued date (or revised date).
  3. If each Astemo-BS website has its own personal information policy, this policy shall supersede the provisions of any other policies in the Astemo-BS websites.

13.Inquiries on This Page

For inquiries about this page (About Personal Information Protection), please fill out the inquiry form in the linked page below.

Inquiry About Personal Information Protection

Special Provisions for Residents in Japan

For residents in Japan, please see the following in addition to the above

Special Provisions for Residents in Japan Protection