Precautions on Using the Service and Handling Personal Information on Investor Relations (IR) Briefing Information Distribution Service

• The issued ID cannot be used by anyone other than the registered person.
• If there are any changes to your registered information, please promptly complete the change procedures (notification of a job change, transfer, etc.) on the relevant network.
• Your registration will be cancelled under any of the following circumstances:
  1. If duplicate registrations are made by one person.
  2. If the Company determines that your registration information contains false information or information suspected to be false.
  3. If it is determined that your ID has been improperly used.
  4. If the Company determines that you are an anti-social force or are suspected of being an anti-social force.
  5. If it is determined that you do not belong to an institutional investor or a securities firm.
  6. If the Company determines that your use of the content infringes a copyright or other intellectual property rights.
• The copyright and intellectual property rights to this content, including information on the networks, belong to the Company or the information provider.
• Any unauthorized posting, reproduction, or distribution of information on the networks (information on companies holding briefings, schedules, venues, presenters, etc.) is a violation of our copyright and other intellectual property rights and is strictly prohibited.

1. Acquisition of personal information and purposes of use

IR Japan, Inc. (hereinafter, the “Company”) acquires and uses personal information to an appropriate extent, in accordance with the following purpose of use. If it becomes necessary to use personal information for purposes other than those listed below, the Company will obtain the consent of the individual to whom the information pertains, except in cases where the individual has given prior consent or where exceptions are permitted under the Act on the Protection of Personal Information or other laws and regulations.

Our purpose is to provide the “Analyst Network” and other networks as services for potential investors that offer analysts and institutional investors useful information, including information on the Company’s services, corporate IR briefings, summaries of financial results, and general meetings of shareholders, etc.

2. Matters concerning provision of information to third parties

The Company will not provide personal information to any third party without prior consent of the individual, except in the following cases.

• When required by laws and regulations.
• When the provision of information is necessary for the protection of the life, body, or property of an individual, and it is difficult to obtain the consent of the individual.
• When the provision of information is particularly necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the consent of the individual.
• When it is necessary to cooperate with a national organization, a local government, or an individual or entity entrusted by either a national organization or local government to execute the work prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of such work.
• When personal information is provided in connection with the succession of business due to a merger or other reasons.

3. Matters concerning outsourcing

The Company may outsource all or part of the handling of personal information within the scope of achieving the purpose of use. When outsourcing, we will select a party that meets sufficient personal information protection standards, conclude a contract for personal information protection, and exercise necessary and appropriate supervision over the outsourced party.

4. Matters concerning disclosure of personal information

Upon a request from the individual, the Company will respond to notification/disclosure of the purpose of use, revision/addition of the content, deletion of items of the content, disuse/elimination of information, or cessation of provision to third parties of personal information subject to disclosure held by the Company. Please contact the “Contact point” provided below and we will explain the procedures for requesting disclosure, etc.

5. Matters concerning optional aspects

Items marked with an asterisk (*) are required fields. Please note that if you do not fill in a required field, your application cannot be processed. Items not marked with an * will not affect your application process if they are not completed.

6. Name of organization

IR Japan, Inc.

26th floor, Kasumigaseki Building, 2-5, Kasumigaseki 3-chome, Chiyoda-ku, Tokyo 100-6026, JAPAN
Yuichiro Kitamura, Representative Director and President

7. Administrator for protection of personal information

8. Contact point

If there are any complaints or consultations regarding the handling of personal information, please contact us at the telephone number or email address shown below.

1. Definitions

In this personal data protection policy (hereinafter, the “Policy”), the following terms shall have the meanings set forth below, provided that the meanings in Article 4 of the General Data Protection Regulation shall apply for terms not defined in the Policy.

• Personal Data” means any information relating to an identified or identifiable natural person (hereinafter, the “Data Subject”).
• Processing” means any operation or set of operations performed on Personal Data or on sets of Personal Data, by automated means or not by automated means.
• Controller” means the natural or legal person, public authority, agency, or other body that alone or jointly with others determines the purposes and means of the processing of Personal Data.

2. Purpose of use

Provider’s Personal Data that the Company obtains will be used for the purposes defined in the Company’s “Handling Personal Information” and will be treated in a lawfully, fairly, and transparently, and only to the extent that is adequate, relevant, and necessary in relation to the purposes for which they are processed. If the Company handles Provider’s Personal Data for purposes other than the foregoing, it will notify Provider of the new purpose of use and other matters required by law in advance and obtain consent.

3. Withdrawal of consent

Provider has the right to withdraw the consent to the provision of Personal Data at any time. This withdrawal of consent shall not affect the lawfulness of processing or the transfer of data before the withdrawal.

4. Data protection

To prevent leakage, theft, destruction, improper access, improper alteration, etc., of Personal Data, the Company comprehensively evaluates and determines the risk of Personal Data infringement with consideration of the type of Personal Data, the level of sensitivity, and the degree of impact, including economic and mental damage, on the Provider, if Personal Data is infringed illegally. The Company implements necessary and appropriate human, organizational, and technical security control measures in accordance with the infringement risks of Personal Data. Furthermore, the Company inspects these security control measures, sets corrective processes as necessary, and strives to constantly protect Personal Data.

5. Appropriate management of information

The Company strives to keep Personal Data up-to-date at all times and will correct any inaccurate Personal Data without delay.

6. Storage limitation

Provider’s Personal Data will not be stored in an identifiable form for longer than is necessary for the purpose of processing.

7. Transfer of personal data to third countries

Personal Data will be transferred to Japan and stored on the Company’s server in Japan. While Japan has not received a data protection adequacy decision from the European Commission, the Company will appropriately manage the Personal Data of Provider.

8. Rights of access, correction, deletion, and limitation of data processing

Provider can request from the Company access to their own Personal Data, correction, and deletion of inaccurate Personal Data, and limitation of data processing during accuracy assessment of Personal Data. The contact point for inquiries regarding the handling of Personal Data is the same personal information protection contact point shown in “Handling Personal Information.” If Provider objects to the Company’s handling of Personal Data, Provider has the right to file a complaint to supervisory authorities in the European Economic Area. Although the Company is obliged to respond to requests from Provider regarding such rights within one month, this term can be extended to a maximum of two months under certain circumstances.

9. Data portability

The Company guarantees that Provider has the right to receive their Personal Data in a structured, commonly used, and machine-readable format and has the right to transmit them to another controller.