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Policy for the Protection of Personal Information

The SUGIKO Group has established the following basic policy for the protection of personal information based on its recognition that the appropriate handling and protection of the personal information of all parties related to the business activities of the SUGIKO Group, including its customers and business partners, is an important societal responsibility.

Basic Policy

1．Compliance with the Act on the Protection of Personal Information and other Japanese laws and regulations

The SUGIKO Group handles personal information appropriately by complying, in its capacity as a business operator, with Japan’s Act on the Protection of Personal Information as well as related laws and regulations (including government ordinances and guidelines).

2．Acquisition of personal information

The SUGIKO Group acquires personal information appropriately and fairly by identifying the purposes for its use as accurately as possible.

3．Purposes for the use of personal information

The SUGIKO Group uses personal information only within the scope of purposes for use and the scope required to conduct its business activities. If it is necessary to use personal information beyond that scope, the group shall, expect as otherwise provided for by laws and regulations, first obtain the approval of the person(s) concerned. The purposes for the SUGIKO Group’s use of personal information are as follows.

1. The conclusion and fulfillment of contracts for the renting and sale of temporary equipment and the provision of related services (hereinafter referred to as “SUGIKO Group’s business services”), management after such contracts have been signed, and the provision of after-sales services for the equipment and services provided;
2. The communication of information required for the provision of SUGIKO Group’s business services and the carrying in and out of equipment;
3. The transmission of information concerning SUGIKO Group’s business services (by direct mail and/or e-mail);
4. The billing and collection of fees and the protection of accounts receivables in relation to SUGIKO Group’s business services;
5. The conducting of market surveys and other research studies;
6. The awarding of prizes, conducting of campaigns, etc.;
7. The transmission of information on meetings and other events hosted by the SUGIKO Group or held by organizations to which SUGIKO Group belongs as well as other necessary communications;
8. The conducting of corporate social responsibility (CSR) activities;
9. The provision of responses to inquiries and opinions submitted to SUGIKO;
10. The provision of corporate information to persons who wish to or will work for SUGIKO Group and any necessary communication with such persons;
11. The delivery of recruitment information and the like to persons who have retired/resigned from the SUGIKO Group.
12. The provision of management for the use and maintenance of establishments, facilities, and instruments; and

13. Other purposes of use that are clearly specified at the time the personal information is acquired.

4．Provision of personal information to third parties

The SUGIKO Group shall neither disclose nor provide personal information to third parties except when required to do so under a law or regulation or when any of the following circumstances apply.

1. The relevant person’s approval has been acquired;
2. The life, body, property and other rights or interests of the relevant person or third party may otherwise be harmed; and
3. The SUGIKO Group is providing, to the extent necessary, personal information to a party to which it has outsourced part of its business operations.

5．Safety management

The SUGIKO Group takes appropriate system security measures to prevent unauthorized access to personal information as well as the unintentional disclosure, loss or damage of personal information.

6．Outsourcing of personal information handling

If the SUGIKO Group outsources the handling of personal information to an external company in order to conduct its business more smoothly, it shall choose an appropriate company and exercise the appropriate supervision required to ensure that the external company employs comprehensive system security measures to prevent unauthorized access to personal information as well as the unintentional disclosure, loss or damage of personal information.

7．Education

The SUGIKO Group clarifies the roles and responsibilities of its employees involved in the safety management of personal information, ensures that everyone is fully informed of this policy, and continues to provide guidance and education with regard to the protection of personal information.

8．Disclosure and correction of personal information

The SUGIKO Group is committed to meeting requests for the disclosure, correction, addition and/or deletion (hereinafter referred to as “correction”) of the personal information that it holds as faithfully and promptly as possible.

9．Contact

Please contact us at the following address if you wish to submit an inquiry regarding personal information held by the SUGIKO Group.

Contact for consultations on personal information

General Affairs Team SUGIKO Group Holdings
14F, 1-7 Kinko-cho, Kanagawa-ku, Yokohama-shi, Kanagawa 221-0056, Japan
TEL：045-444-0835 FAX：045-444-0836

Established on Dec. 2016
Ryo Sugiyama, President and Representative Director
SUGIKO Group Holdings

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