CORPORATE POLICY

Name, address, and representative of the business operator handling personal information

8-1 takasu, ichikawa-shi,Chiba 279-0023, Japan
Yasunori Hara, President & CEO Appleach, Inc.

Title, affiliation, and contact information for personal information protection management measures

Information Security Manager (Contact information is below under "Personal Information Complaints and Consultation Service")

Purpose of Use of Personal Information

The purposes of using the personal information entrusted by our customers are as follows. In cases of any additional specific purposes, we will disclose them on the respective business website.

1. For the performance of tasks based on customer requests.
2. For the confirmation of customer orders and contracts received.
3. For communication with customers.
4. For delivering products to customers.

Provision of Personal Information to Third Parties

When providing personal information to third parties, we will obtain the consent of the individual concerned except in the following cases:

1. When required by law.
2. When necessary to protect human life, body, or property.
3. When specifically necessary for the improvement of public health or the promotion of the healthy upbringing of children.
4. When cooperation is required for government agencies, local public bodies, or those entrusted by them to perform duties prescribed by law.

In cases where consent cannot be obtained from the individual concerned, we will provide advance notice to the individual and make it readily available for their knowledge, as well as handle it through the "opt-out procedure" to be reported to the Personal Information Protection Commission, allowing the individual to request the cessation of third-party provision.

When providing personal information to third parties located in foreign countries, we will obtain the consent of the individual concerned for such purposes.

Outsourcing of personal information to third parti

When using personal information entrusted to third parties, we will thoroughly ensure management and oversight of the entrusted party, including assessing the appropriateness of entrusting based on the security measures in place with the third party. We will also establish a business outsourcing agreement that outlines the necessary matters, including confidentiality, to maintain appropriate supervision over the third party.

Joint Use of Personal Information

We will jointly use the personal information provided by you as follows:

1. Items of personal information to be jointly used:
   Personal information obtained for the purposes described in the "Regarding the Use of Personal Information" section may be jointly used as necessary with affiliated companies of our company.
2. Range of parties who will jointly use:
   Appleach, Inc.
   Field, Inc.
3. Purposes of use by the parties:
   Same as the "Regarding the Use of Personal Information" section.
4. Name or designation, address, and name of the representative responsible for the management of this personal information:
   Address:8-1 takasu, ichikawa-shi,Chiba
   Representative Director of Appleach, Inc.: Yasunori Hara
5. Method of acquisition:
   Various methods and channels such as telephone, fax, email, and the internet.

Measures taken to ensure the security of personal information

We will implement the following security measures for the safe management of personal information, taking into consideration the magnitude of potential infringement on the rights and interests of individuals in the event of a data breach and assessing risks arising from factors such as the scale and nature of our business, the handling of personal information, and the nature of the media used to record personal information:

1. Establishment of Basic Policies:
   • We will publish a personal information protection policy that includes compliance with personal information protection laws and continuous improvement.
2. Development of Disciplinary Regulations for Handling Personal Information:
   • We will establish internal regulations for the handling of personal information at each stage, including acquisition/input, transfer/transmission, use/processing, storage/backup, and deletion/disposal, specifying handling methods, responsible individuals, personnel, and duties.
3. Organizational Security Measures:
   • We will appoint individuals responsible for the handling of personal information and clarify the scope of personal data handled by employees. We will also establish a reporting system to responsible parties in cases where violations of laws or handling regulations are identified.
   • Regular self-assessment and audits by other departments regarding the provisions for handling personal information.
   • We will undergo external audits by third-party review organizations to maintain ISMS (Information Security Management System) certification.

   

4. Human Resource Security Measures:
   • Regular training on personal information protection.
   • Inclusion of confidentiality provisions in employment rules and agreements.
5. Physical Security Measures:
   • Implementation of access control and restrictions on the introduction of devices.
   • Measures to prevent unauthorized access to personal information by individuals without authorization.
   • Implementation of security measures such as locking and encryption to prevent data loss or leakage for devices, electronic media, and documents used to handle personal information.
6. Technical Security Measures:
   • Implementation of access control for personal information databases and systems.
   • Introduction of mechanisms to protect against unauthorized access from external sources or malicious software.
7. Awareness of External Environments:
   • Identification of the country where personal information is stored and implementation of security measures after understanding the personal information protection system in that country.
   • Disclosure of the specific countries where personal information is stored on a case-by-case basis.
   • Reference to the Personal Information Protection Commission's website for information on personal information protection systems and regulations in foreign countries.
   Conduct research on systems related to the protection of personal information in foreign countries.