Handling of Personal Information and Specific Personal Information

Handling of Personal Information and Specific Personal Information by BellSystem24 Holdings, Inc.

Collection and Use of Personal Information

BellSystem24 Holdings, Inc. ("the Company") uses personal information within the scope necessary for the purposes of use described below. In addition, when personal information is collected from an individual directly and in writing (including when information is input into a Company website), or when it becomes necessary to access the personal information of an individual, each time the Company will collect or access the information after specifying the purpose(s) of use and obtaining the individual's consent. Also note that calls with customers may be recorded in written, audio or electronic forms to confirm the details of the call or to improve customer satisfaction through the evaluation of customer service quality and training.

Purposes of Use of Personal Information

1. Personal information about customers
   • Contact information, such as name, address, telephone number and email address
     • To respond to the details of an inquiry or complaint
     • To propose products or services, to engage in business talks, to fulfill contractual obligations, and to otherwise make administrative contact necessary for business
     • To provide information about products and services or provide notification of events, seminars, exhibitions and other events by way of direct mail, email, telephone or otherwise
     • To sell and ship products and provide services
   • Image data such as faces and appearances
     • To watch for suspicious persons and control facility access through the installation of security cameras and the like
   • Voice data such as customer service records
     • To confirm the details of a voice call, to evaluate the quality of customer service, and to conduct training
2. Information about clients
   • Contact information, such as name, address, telephone number and email address
     • To propose products or services, to engage in business talks, to fulfill contractual obligations, and to otherwise make administrative contact necessary for business
     • To provide information about products and services or provide notification of events, seminars, exhibitions and other events by way of direct mail, email, telephone or otherwise
     • For managing transaction partner information
3. Information related to recruitment and applications
   • Contact information, such as name, address, telephone number and email address / Attribute information such as gender and age
     • To contact applicants and provide information to them
     • To recruit employees, screen applicants and carry out procedures for new employees to join the company, etc.
     • To improve customer service provided by the Company and utilize for research and development into new services
4. Information about employees
   • Contact information, such as name, address, telephone number and email address / Attribute information such as gender and age
     • To perform personnel management for employees, etc., including procedures related to employment, welfare, resignation and retirement
     • To fulfill obligations set forth in the Worker Dispatch Act and other laws or regulations for temporary staff accepted by the Company
     • To improve customer service provided by the Company and utilize for research and development into new services
5. Information about shareholders
   • Information, such as name, address, telephone number and email address
     • To exercise rights, perform obligations and prepare records under the Companies Act and various other laws and regulations
     • To manage shareholders
6. Provision to third parties within the scope required to achieve the purposes of use stated above
   (Provided, however, provision is limited to cases where the act is permitted under applicable laws and regulations including the Act on the Protection of Personal Information.)

Collection and Use of Specific Personal Information

The Company uses specific personal information within the scope necessary for the purposes of use described below. When specific personal information is collected from an individual directly and in writing, the purpose(s) of use are specified each time. When specific personal information is directly collected by other means or when specific personal information is indirectly collected from a person other than the individual to which it relates, the information is also only used within the scope necessary to satisfy the purposes of use described below.

Purposes of Use of Specific Personal Information

1. Clerical work related to individual numbers concerning individuals other than officers and employees
   • To conduct clerical work to prepare records of payment for compensation or fees, etc.
   • To conduct clerical work to prepare records of payment related to transaction of real estate, etc.
   • To conduct clerical work to prepare records of payment related to dividends, distribution of surplus funds or interest on funds
2. Clerical work related to individual numbers concerning officers and employees (including their dependents)
   • To conduct clerical work to prepare withholding income tax slips
   • To conduct clerical work to prepare statutory documents pertaining to financial instrument transactions as part of a workers' asset formation system
   • To conduct clerical work related to resident tax
   • To conduct clerical work related to social insurance
   • To conduct clerical work related to national pension or corporate pension schemes
   • To conduct clerical work related to labor insurance
   • To conduct clerical work to prepare statutory documents pertaining to financial instrument transactions related to a stockholding association

Safe Management of Personal Information and Specific Personal Information

The Company manages the personal information and specific personal information that we have obtained or are about to obtain by undertaking stringent security measures to prevent leakage, loss or damage as follows.

(Formulation of basic policy)
The Company formulates basic policies for matters such as the observance of laws and regulations related to the handling of personal information and specific personal information, guidelines set by the Japanese government and other standards, and contact points for inquiries and complaints to ensure the proper handling of personal data.

(Establishment of rules on the handling of personal data)
The Company has formulated rules on the handling of personal information, setting out handling methods, the persons responsible/in charge, their responsibilities, etc., at every stage of the process, from collection, use, storage and provision to deletion and destruction.

(Systematic security measures)
The Company has established regulations and the like related to safety control whose preparation included the appointment of people responsible for the handling of personal data, the clarification of the employees who handle personal data and the scope of the personal data handled by those employees. Further, the Company has established system to report facts or indications that a violation of laws, regulations or handling rules has or will occur to the people responsible when these facts or indications are identified.
The Company carries out self-inspections on a regular basis to assess the handling of personal data and are also audited by other business units and external parties.

(Human security measures)
The Company regularly provides training to employees on matters to be considered when handling personal data. Moreover, our work rules include information about the confidentiality of personal data.

(Physical security measures)
In areas where personal data is handled, the Company takes measures to prevent unauthorized people from viewing personal data, such as employee physical access control, restrictions on equipment being brought into facilities, and access controls.
The Company takes steps to prevent the theft, loss, etc. of equipment, electronic media, documents, etc. that contain personal data. Moreover, when carrying such equipment, electronic media, etc. inside offices and between offices and other locations, measures are taken to ensure that personal data cannot be easily accessed.

(Technological security measures)
The Company enforces access control to limit the employees that are authorized to use information systems through which personal information databases and the like are handled.
The Company introduced frameworks to protect information systems that handle personal data against illegal access from outside or malware.

(Assessment of external environment)
The Company may transfer personal data to Group companies located overseas to outsource portions of internal management operations and entrusted operations. Regarding the handling of personal data by companies to which the data is transferred, the Company periodically confirms their implementation of measures that are at the same level as the measures required for business operators in Japan that are authorized to handle personal information.

■ Socialist Republic of Vietnam
Company name: BELLSYSTEM24 VIETNAM
Please confirm the information on systems related to the protection of personal information in the Socialist Republic of Vietnam on the following page that has been prepared by the Personal Information Protection Commission Japan.
https://www.ppc.go.jp/files/pdf/vietnam_report.pdf

■ Kingdom of Thailand
Company name: True Touch
Please confirm the information on systems related to the protection of personal information in the Kingdom of Thailand on the following page that has been prepared by the Personal Information Protection Commission Japan.
https://www.ppc.go.jp/files/pdf/thailand_report.pdf

Third Party Provision

The Company manages personal information by undertaking stringent security measures to prevent the information from being leaked, lost or damaged. Except when any of the following apply, the Company will not disclose or provide personal information to any third parties.

1. When an individual has provided consent
2. When required by laws or regulations
3. Where the provision is required for protecting human life, body or property and it is difficult to obtain the approval of the individual
4. Where it is especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the approval of the individual
5. Where it 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 it is difficult to obtain the approval of the individual
6. Where personal information is provided in connection with the succession of business for reasons of merger or otherwise and the personal information in question is used within the scope of the purpose of use before the succession
7. When personal information is entrusted to a third party within the scope of the purpose of use
8. Specific joint use of personal information within the following scope
   1. Personal information items for joint use and the purposes of their use: The items and purposes correspond to the purposes of personal information use stated above.
   2. Scope of joint users: companies belonging to a group led by the Company
      https://www.bell24.co.jp/ja/company/group/）
   3. Person responsible for personal information management: highest officer in charge of the protection of personal information

The Company submits no specific personal information except in cases where its submission is prescribed in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.

Handling of Anonymously Processed Information

1. Creation of anonymously processed information
   When creating anonymously processed information (information obtained by processing personal information so that it cannot identify a specific individual by taking action prescribed by law, where the personal information in question is rendered irrecoverable), the Company will comply with the following.
   • Appropriately process the information in accordance with the standards set forth in law
   • Take safety management measures to prevent the leaking of the information deleted in accordance with the standards set forth in law and information related to the processing methods
   • Publicly announce the items of information included in anonymously processed information
   • Not engage in any conduct to identify an individual whose personal information was used as the source of creation
2. Provision of anonymously processed information
   When providing anonymously processed information to a third party, the Company will publicly announce the items of information on individuals contained in the anonymously processed information it seeks to provide and the method of provision, and clearly specify to the third party recipient that the information provided is anonymously processed information.
   *Please check here for information about the items of information contained in the anonymously processed information prepared by the Company, the items of information contained in anonymously processed information provided to third parties, and the method of provision.
3. Use of anonymously processed information
   When using anonymously processed information it has prepared itself or received from a third party, the Company will not cross-check the anonymously processed information against other information, or identify individuals related to the personal information used in the anonymously processed information in question.

Handling of Pseudonymously Processed Information

1. Preparation of pseudonymously processed information
   The Company complies with the following rules when preparing pseudonymously processed information (information about individuals obtained by processing personal information to prevent the identification of a specific individual unless actions prescribed in laws and regulations are taken to compare such information with other information).
   • Appropriately process the information in accordance with the standards set forth in law
   • Take safety management measures to prevent the leaking of the information deleted in accordance with the standards set forth in law and information related to the processing methods
   • Publicly announce the items of information included in pseudonymously processed information
   • Not engage in any conduct to identify an individual whose personal information was used as the source of creation
2. Provision of pseudonymously processed information
   The Company provides no pseudonymously processed information to third parties except in cases where the provision of such information is based on laws and regulations.
   *Please check here for the information included in pseudonymously processed information prepared by the Company.
3. Use of pseudonymously processed information
   The Company does not engage in handling beyond the scope necessary to achieve the initial purposes of use in cases where it uses pseudonymously processed information prepared by itself. Further, the Company avoids comparing the pseudonymously processed information with other information, and identifying an individual whose personal information was used to prepare the pseudonymously processed information.
4. Deletion of pseudonymously processed information
   The Company deletes the relevant personal data, information about its deletion and the like without delay when the use of the personal data that is pseudonymously processed information, the information about its deletion and the like becomes unnecessary.
5. Purposes for the use of pseudonymously processed information
   The Company uses pseudonymously processed information for internal analysis aimed at applying the information to service enhancement, research and development, and the research and development of recruitment and new services.

Matters Concerning Personal Information and Specific Personal Information Subject to Disclosure

Personal information subject to disclosure is personal information systematically arranged in such a way that specific personal information can be easily searched, and for which the Company has the authority to respond to all requests from the individual to disclose, correct, add or delete the information, to discontinue its use, to erase, and to discontinue its provision to a third party (JISQ15001 3.4.4.1).

1. Name of Business Operator:BELLSYSTEM24 Holdings, Inc.
2. Personal Information Protection Manager: General Manager of the Human Resources Development Department (please refer to the "Personal Information Inquiry Desk" below for contact details).
3. Purposes of Use of All Personal Information and Specific Personal Information Subject to Disclosure:
   The purposes of use correspond to the purposes of personal information use by the Company and the purposes of specific personal information use by the Company stated above.
4. Contact details for complaints or consultations regarding the handling of personal information, specific personal information, anonymously processed information and pseudonymously processed information:

   Contact details for general inquiries regarding personal information protection policies:
   BellSystem24 Holdings Inc. Personal Information Inquiries Desk
   Telephone: 03-6893-9778
   Reception Hours: Weekdays from 9:00 a.m. to 6:00 p.m
   *Excluding Saturdays, Sundays, public holidays, the period from August 13 to August 15, and the period from December 30 to January 3.

5. Requests for the Disclosure, etc. of Personal Information and Specific Personal Information Subject to Disclosure:
   When an individual or the proxy of an individual to which personal information or specific personal information held by the Company pertains (1) requests the disclosure of their personal information or specific personal information or notification of its purpose of use, (2) requests that the personal information or specific personal information in question to be corrected, added to or deleted, or (3) requests the discontinuation of use, erasure or discontinuation of provision to third parties of personal information or specific personal information by which the individual concerned can be identified (with requests (1) through (3) collectively referred to as "requests for disclosure, etc." hereafter), the Company shall respond accordingly.

Security

On the Company's website, personal information provided through inquiries, applications and other interactions is protected by a data encryption technology known as Secure Sockets Layer (SSL), in order to safeguard the personal information of customers. When using a browser that does not support SSL, it may not be possible to access the Company's website or enter information.

Cookie Policy

Protecting the Information of Customers Aged 15 and Younger

The Company makes the utmost efforts to protect the information of customers aged 15 and younger. Please ensure that the personal information of customers aged 15 and younger is only provided based on the consent of their parent or guardian.

Revisions

To safeguard personal information and specific personal information, or to comply with laws, regulations, national government guidelines and other norms, etc. concerning the handling of personal information and specific personal information, the "Handling of Personal Information and Specific Personal Information by BellSystem24 Holdings, Inc." is subject to change without notice. Your understanding is appreciated.

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