This Privacy Policy has been established based on the recognition that Qpolaris Corporation and its group companies (collectively, the “Qpolaris Group”) have a social responsibility to promote the proper handling of personal information. The Qpolaris Group is committed to ensuring that all officers and employees comply with this Privacy Policy and to exerting all possible efforts to protect personal information.

1. Basic stance

In the course of handling the personal information of customers, business partners, shareholders, job applicants and all other individuals (collectively, “Customers”), the Qpolaris Group will comply with all laws and governmental regulations concerning the proper handling of personal information and all other applicable rules and guidelines.

2. Purpose of using personal information

The Qpolaris Group will use the personal information received from Customers solely within the scope of permissible use described as follows.

• • Introduction of products and services
• • Response to inquiries and questions about products and services
• • Communication, response and administration necessary for the conclusion and execution of agreements
• • Operations related to the delivery of products and provision of services
• • Operations for the settlement of payment for products and services
• • Confirmation of the usage conditions of products and services and the provision of feedback/support for products and services
• • Invitation to events, exhibitions, etc. and communications in relation to their operation
• • Signing up for e-mail distribution services or other services available on the Qpolaris Group’s websites, distribution, confirmation and other communications in relation to those services
• • Response to the access to and use of the Qpolaris Group’s facilities by Customers
• • Planning of and response to human exchange activities, including the acceptance of secondment
• • Shareholder administration and notifications to shareholders pursuant to the Companies Act of Japan
• • Provision of recruitment information to job applicants; screening and selection of prospective employees
• • Creation of data through de-identification of personal information, which cannot be restored to original personal information (“anonymously processed information”)
• • Processing of personal information into data through which a specific individual cannot be identified unless the information is collated with other information (“pseudonymously processed information”)
• • Investigations, examinations, surveys and reports about compliance
• • Other purposes of use as announced on Qpolaris Group’s websites and others where its products and services are introduced

3. Purposes of using pseudonymously processed information

The Qpolaris Group may use pseudonymously processed information for any of the purposes listed below.

• • Development of the Qpolaris Group’s products and services, improvement of their quality, research for new services, and various marketing surveys and analysis to facilitate the foregoing
• • Creation of statistical data for business analysis and utilization of analytical findings
• • Provision of other information that the Qpolaris Group may find beneficial for Customers

4. Shared use of personal data

The Qpolaris Group may share personal data received from Customers (excluding the specified personal information) for use in accordance with the following conditions.

※Shared use within the Qpolaris Group

• • Types of personal data that may be shared:

  Customers’ attribute information, including the name, address, telephone number, age, gender and e-mail address as well as other personal data provided by Customers, including the details of inquiries made by them

• • Scope of those who may share personal data

  Qpolaris Group companies within and outside Japan

• • Purposes of shared use

  The purposes described in Section 2 (Purposes of using personal information)

• • Administrator for shared use

  Qpolaris Co., Ltd.

5. Provision of personal data to third parties

The Qpolaris Group will never disclose or provide any of Customers’ personal information without the person’s consent, to any third parties other than the parities included by the Qpolaris Group in the scope of those who may share personal data, the Qpolaris Group’s outsourcing partners and those taking over a business from the Qpolaris Group, except when such disclosure is required under the law or justified on any other grounds.

※Specified personal information of Customers will not be provided to any third party, regardless of whether the person’s consent is obtained or not, except when such information is provided to an outsourcing partner of the Qpolaris Group or provided under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures of Japan (the “Number Use Act”) or any other applicable laws and regulations.

6. Administration of outsourcing partners

The Qpolaris Group will conclude a non-disclosure agreement with the outsourcing partners to whom the Qpolaris Group will disclose Customers’ personal information pursuant to the preceding paragraph and direct and supervise the outsourcing partner to ensure the proper handling and protection of the personal data.

7. Transfer of personal data outside Japan

For the transfer of Customers’ personal data outside Japan, the Qpolaris Group will implement necessary measures in line with the relevant laws and regulations.

8. Disclosure, correction, etc. or cessation of use, etc. of retained personal information

If Customers desire disclosure, correction, etc. (meaning correction, addition or deletion) or cessation of use, etc. (meaning deletion, cessation of use or cessation of provision to third parties) with regard to their own personal data retained by the Qpolaris Group, they will be required to contact the Human Resources Department of Qpolaris Corporation. After verifying the identity of the person, the Qpolaris Group will take necessary action as soon as reasonably possible. However, the foregoing does not apply when acting as requested by the person may be detrimental to any right of a third party, or when the Qpolaris Group determines that its proper business operations may be significantly disrupted, or when a violation of law may arise.

9. Items related to data security management

The Qpolaris Group will appropriately manage data security when handling personal data, thereby preventing illegal access to the data from outside the Qpolaris Group as well as data loss, destruction, falsification, leakage and other incidents. To this end, the Qpolaris Group will implement data security management measures in an appropriate and rational manner. In the event of an incident, the Qpolaris Group will promptly take corrective measures. If you have any questions about the Qpolaris Group’s data security management, please make an inquiry to the contact point described in Section 11 below.

10. Controller of Personal Information Protection

• • Qpolaris Co., Ltd.
• • 270-0222 414, Kimakase, Noda City, Chiba, Japan

Our data protection officer can be contacted at business@qpolaris.com or using our postal address and adding “The data protection officer”.

11. Inquiries

Any inquiries or questions regarding personal information can be directed to the contact point with Contact Us Form.

For other comments and opinions regarding the handling of personal information, please refer to the public announcement.

Please note that this Privacy Policy may be revised from time to time without notice.

Revised on March 1, 2023