Privacy Policy

• Purposes of Use of Personal Information Retained by the Group
• Inquiry Window for Handling of Disclosure of Personal Information
• Joint Use of Personal Information
• Handling of Anonymously Processed Information of the Group
• Handling of Pseudonymized Information of the Group

The Group companies (hereinafter referred to as "the Group") have been in business by placing priority on information security in order to protect the information that can identify specific individuals, such as customers involved in the business, business partners, and employees, as well as the various types of information assets arising from the BPO business from different threats and to fulfill the social responsibilities as corporations. Given the importance of the protection of personal information, in particular, all persons engaged in the business shall recognize their responsibilities; abide by the laws, other rules, and guidelines on personal information protection; and shall implement the appropriate safety control measures to handle personal information.

1. Purposes of Use and Acquisition of Personal Information

1.1 When acquiring personal information directly or indirectly

• The Group shall acquire personal information through lawful and fair means only with the consent of the person concerned.
• The Group shall not acquire any confidential information that is likely to damage the interest of a person without the clear consent of the person concerned or as required by laws and regulations.
• The Group shall clarify the purposes of use, announce the availability of the consultation window for personal information, and acquire personal information to the extent necessary to achieve the purposes.

1.2 When a business is entrusted to us.

• The Group shall use the received personal information only to the extent reasonably necessary for the operation of the businesses.
• The Group shall, after implementing sufficient safety control measures, acquire personal information through lawful and fair means to the extent necessary for the operation of the business.
• The Group will comply with the contract terms on the confidentiality of personal information, matters on reconsignment, returning and destruction of personal information upon termination of a contract, and burden sharing in the event of an accident.
• In order to operate and manage the customer service operation and enhance services, the Group may record the telephone calls received at the toll-free call center to the extent necessary to attain the purposes of use.
• When providing anonymously processed information to a third party, the Group shall announce publicly the items of information to be provided, as well as the method of provision, and shall notify the receiving party of the fact that the information is anonymously processed information.

2. Security Control Measures for Personal Data

When implementing security control measures, the Group will establish a department that is exclusively focused on information security and shall disclose its Information Security policy and its privacy policy. In addition, the Group shall use the framework for the information security management system (ISMS) to comply with the laws, regulations, and guidelines governing the protection of personal information and shall appropriately implement the technical and organizational protection measures as detailed below:

2.1 Ensuring accuracy

The Group shall maintain the acquired and received personal data in an accurate and up-to-date state.

2.2 Security control measures

• The Group shall implement the necessary and appropriate measures to prevent leakage, loss, or damage of personal data and will safely manage such data.
• The Group shall develop the organizational structure and handling regulations and guidelines, promote awareness by the employees of the same, and provide employees with education and training with regard to the same.
• The Group shall implement physically and technically sufficient safety control measures.
• The Group shall periodically evaluate, review, and improve the safety control measures.
• If any problem arises, the Group shall fulfill its obligation to report and to give notice to the person concerned and shall promptly implement the appropriate corrective measures.

2.3 Supervision of subcontractors

• In the event the Group intends to outsource any business, including the processing of personal information (including the subcontracting to any of the overseas group companies or other group companies), the Group shall exercise the necessary and appropriate supervision over the subcontractor so that the entrusted personal data will be safely controlled.
• The Group shall conclude a confidentiality agreement and confirm compliance with the contract terms.

3. Appropriate Acquisition of Personal Information

The Group shall acquire personal information appropriately and shall not acquire information deceitfully nor through other fraudulent means. Also, the Group shall not collect personal information from a customer under 16 years of age without due cause and without obtaining the consent of their legal representative (such as a person with parental authority).

4. Provision to a Third Party

• The Group shall not provide personal data to a third party without obtaining consent from the person concerned unless specified under the Personal Information Protection Act of Japan.
• With regard to a business in which personal data is provided to a third party in a foreign country, the Group shall provide the personal data after confirming that whether or not the provision falls under (1) a consent of the person concerned, (2) provision to a business operator who has prepared a system conforming to the standard, or (3) provision to a country having the same level of protection of personal information as Japan (the EU and the United Kingdom).
• In the event personal data is to be provided to a third party in a foreign country, the Group shall periodically check the status of implementation of equivalent measures implemented by the third party and the existence of and the details of a system in the foreign country that may affect the performance of equivalent measures by appropriate and reasonable methods and shall evaluate, review, and improve all safety control measures on a regular basis.

5. Compliance with Laws and Regulations

• The Group shall comply with the laws, regulations, and other norms governing the handling of personal information, continuously review the privacy policy, and strive to improve the same.
• With regard to the provision of personal data to a third party who is an overseas business operator, the Group shall implement the necessary and appropriate measures to safely control the personal data after gaining a proper understanding of the system of personal information protection by the applicable overseas country.

Shinichi Tamagami
CEO
Prestige International Inc.

Purposes of Use of Personal Information Retained by the Group

The Group shall use personal information for the purposes described below. In addition, with regard to the purposes of use of the personal information handled uniquely by the Group, each of the Group companies shall disclose their purposes of use. In addition, even when acquiring personal information as a result of a merger or other reasons, the Group shall not handle the information in excess of the scope of the purposes of use that have been preliminarily established in relation to the business succession without obtaining consent from the person concerned, except when prior consent has been given or unless specified otherwise by laws and regulations.

1. Group-Wide Purposes of Use of Personal Information

The Group shall not, without obtaining consent from the person concerned, handle personal information that exceeds the group-wide purposes of use. However, the Group may handle the personal information without obtaining separate consent if obtaining such consent may interfere with the performance of business, including causing a delay, and the case falls under any of the following:

• When the business succession of the Group, including the provision of personal information, is the result of a merger, company split, business transfer, or other reasons
• When it is necessary to cooperate with a national government organization or local government, or a party consigned by such, to execute legally prescribed affairs.

1.1 Retained personal information and purposes of use

Scope of Use (Names of Group Companies)	Retained Personal Information	Purposes of Use
Commonly applicable to Group Companies	Personal Information of customers (who have direct contractual relationships with any of the Group Companies)	Identification and personal verification of customers. For the sale of products, invoicing, sale of tickets, and the various procedures for the campaigns that the customers have joined in the Aranmare Project Division and other projects that the Company hosts or sponsors. Responding to, confirming, and maintaining records of inquiries, consultations, and complaints from customers and providing the appropriate support. Developing products and promoting improvement of other services. Promoting improvement of the customers' experience in relation to the digital services (such as websites, and mobile apps) provided by the company. Advertisements and the provision of information on products, services, and campaigns through letters, email, and other means. When the Group provides the information to a third party in order to mediate the provision of the service of the subcontractor and of the Group or the entrusted business service and in order to respond to inquiries, complete settlements, make inquiries to the customers, and provide any related after-sales services. To detect users in violation of the terms of service, to give notice to such users, and to examine, detect, and prevent fraudulent activities (such as fraud and unauthorized access) that abuse the services, as well as to respond to such fraudulent activities in order to safely provide products and services to customers. When personal data is provided to an academic research institution for the purpose of academic research that is not intended for a purpose that may unreasonably impair the rights and interests of individuals.
	Personal information of customers other than the above	To secure physical security (access control) of those visiting the Company. To respond to inquiries and opinions about the services as detailed below (1) through (4): (1) To specify users. (2) To respond to, confirm, and record inquiries and consultations. (3) To record the shipment of printed materials, such as the requested corporate information. (4) To offer information on projects, products, and services.
	Personal information of business partners (in the case of a corporation, officers and persons in charge); Personal information of customers and users of business partners with whom the Group has concluded a consignment agreement	Communications necessary for business operations, performance of contracts, and business discussions. Management of business partner information. Performance of contracts with the consigner. Fact checking, investigations, and corrective actions at the time of using the whistleblower protection system of a business partner.
	Personal information of shareholders (or of all officers, if the shareholder is a corporation)	Exercise of rights and performance of obligations under the Companies Act. Creation and management of shareholder data based on the prescribed standards set in accordance with applicable laws and regulations. Implementation of measures designed to optimize the relationship between shareholders and the company.
	Personal information of newly hired employee and job applicants	Communication with and provision of information to newly hired employees and job applicants. After obtaining consent from the individual, continue to retain and use the information for subsequent opportunities on recruitment if the individual’s application is turned down. Employment screening.
	Personal information of employees	Business notification to employees. Payment of remuneration (such as wages, bonuses, and allowances), performance of personnel and labor management, and offering of welfare benefits for employees. Employee health management.
	Personal information of members of the fan club and those who participated in the events	Communication and provision of related information in the Aranmare Project and other projects that the company hosts or sponsors. Sale of related products and tickets or event announcements for the Aranmare Project and other projects that the company hosts or sponsors.
	Personal information of children, parents, and families at Orangery (day nursery)	Provision of child care services, and administrative management of such services (including listing information on websites and brochures). When it is necessary to provide meals that are safe and in line with the growth and development of children. When it is necessary for liaison and coordination with public agencies and medical institutions and to seek opinions from a contract physician. When it is necessary for other advertising activities.

About cookies

1. (*1) Cookies are part of the technology to record and manage the information of customers using the websites of the Group with a computer or application software. Some parts of the Group's websites use cookies for customer convenience.
2. (*2) The websites of the Group use Google Analytics, one of the services provided by Google LLC, in order to understand the status of visits to the websites of the Company by customers.

Cookie Settings

About Google Analytics

When Google Analytics is used on the Group's website, Google LLC will, based on the cookies issued by the Group, collect, record, and analyze the history of visits to the websites of the Company by customers. The Group receives from Google LLC the results of their analyses and understands the status of visits to websites by customers. The information on the customers that has been collected, recorded, and analyzed by Google Analytics cannot be used to identify specific individuals. Also, such information will be managed by Google LLC in accordance with their privacy policy.

1. (*3) Customers may prevent Google Analytics, which the Company uses, from collecting information by disabling Google Analytics in the browser add-on settings. Customers may also disable Google Analytics by changing their browser's add-on settings after downloading and installing the Google Analytics Opt-out Browser Add-on found on the Google's download page for add-ons. However, if customers disable Google Analytics, it will disable Google Analytics on all websites that they visit, but it may be re-enabled by changing the browser add-on settings when necessary. Please refer to the Google Analytics' website for details on the terms of service for Google Analytics and refer to Google's website for details on Google's privacy policy.

Google Analytics Terms of Service

Google Privacy Policy

Google Analytics Opt-out Browser Add-on

2. Purposes of Use of Personal Information Unique to the Group

*Any companies within the Group that are not listed below shall be within the scope of the Group-Wide Purposes of Use on Personal Information.

Scope of Use (Names of Group Companies)	Retained Personal Information	Purposes of Use
Prestige Human Solution Inc.	Personal information of dispatched workers and those taking the training course	Recruitment activities of dispatched workers (for conducting reviews on recruitment and for recruitment documents), employment of the physically challenged, responding to questionnaires, and formulating new services and improving quality based on the responses to questionnaires. *Detailed information is available at https://www.prestige-hs.com/policy/
Premier Assist Inc.	Personal information to provide emergency services; Personal information of the owners of commercial land	Provision of road services (to verify identification of customers, respond to inquiries, send receipts, etc.). Provision of emergency services to a room, emergency services for building facilities, and services of inspection, examination, housing life, and repair of home appliances (to confirm the details of a request, to verify identification of customers, to respond to inquiries, or to send receipts). Responding to problems of commercial land.
	Personal information of service users; Personal information of those who made inquiries and cooperated with questionnaires	Provision of home-visit medical services to users, health consultations over the phone, creation of receipts, and the shipment of documents, prescription drugs, and products of therapeutic nutritional formulas.
Premier Life Inc.	Personal information of contractors	Provision of services to residents and management companies (in relation to guarantee contract, rent collection agencies, inquiries, etc.).
Prestige Core Solution inc.	Personal information of service users	Provision of Electric Vehicle Charging Service(to verify identification of customers, respond to inquiries, send Invoice, etc.).
Premier Bright Connect Inc.	Drivers name, Drivers License, Your company name, Your terminal ID, Your car number, Departure time, Arrival time, Driving distance.	To distinguish high-risk driver and low-risk driver through analyzing score traffic accident for high quality.

Inquiry Window for Handling of Disclosure of Personal Information

In the event of a request for disclosure, change, suspension of use, deletion, or suspension of provision to a third party (hereinafter collectively referred to as a “Request for Disclosure of Personal Information”) from the person concerned or a proxy, the Group shall, after confirming that the requester is the person concerned or the proxy, respond to the request with the method of disclosure as instructed by the person or proxy, such as responding in writing, providing the retained personal data in the form of an electromagnetic record in which the person concerned is identified, or other methods that the personal information protection committee has determined. With regard to the requests received, the Group shall work to respond or correct, add, delete, suspend the use of, or erase the information within a reasonable time and scope.
Please note that if suspension of use or deletion is performed for any part or all of the information, the Group may not continue to provide its services to meet the preferences of the customer.

Please check the conditions stated below because the Group may be unable to respond to those Requests for Disclosure of Personal Information:

1. (ⅰ) When the Company is unable to verify identification, such as when the address stated on the request form and the address stated on the eligibility verification document of the person concerned or of the proxy are not identical.
2. (ⅱ) When the Company is unable to confirm the right of proxy in the case of an application by proxy.
3. (ⅲ) When the prescribed request form contains a deficiency.
4. (ⅳ) If the request for disclosure of retained personal data is made, when the information requested for disclosure does not fall under the category of retained personal data.
5. (ⅴ) When responding to the request is likely to seriously interfere with a proper operation of the Group's business.
6. (ⅵ) Other cases as provided by laws and regulations and when it results in a violation of laws and regulations.
7. (ⅶ) When the information requested for disclosure is the personal information of the customer or user of a business partner with whom the Group has concluded a consignment agreement.

However, when the suspension of use requires large expenses or when it becomes difficult to suspend the use of information for technical reasons or because of the social impact, the Company may, when possible, implement the alternative measures necessary to protect the rights and interests of the person concerned. Also, when the Company decides not to disclose the information as provided by laws and regulations, the Company shall announce the same and the reason for such decisions. Please note that even when the decision is made not to make the disclosure, the Company will not refund the disclosure fee.

1. How to request the disclosure of personal information

<How to request>

When making a request for disclosure, please contact the inquiry window for personal information, a contact point of the Group, by telephone or by post. To submit a request for disclosure, please fill out the prescribed request form that will be sent from the reception window and then return the form by post along with the documents required for identity verification and the prescribed fees.

* A Request for Disclosure of Personal Information can be made for one (1) company or one (1) person with one (1) sheet of the request form. When multiple company names or personal names are entered on the form, the Company will handle the request as a request only on the first-entered company or person.

<Items of information to be disclosed upon request>

Name, address, telephone number, email, and other items that are considered to be part of personal data.

1.1 Documents required for Identity Verification

If the requester is the person concerned:

Please enclose the document specified below for identity verification.
(A photocopy of an official document, such as a driver's license and passport)

* Please note that the Company will not disclose nor send the disclosure document if the current address and the address stated on the verification document are not identical.

If the request is made by a legal representative:

Please fill out the prescribed request form to describe the relationship with the person concerned and enclose it with the following documents to certify the relationship to the person concerned, in addition to the document for identity verification.

• Declaration form for legal representative One (1) copy
• Document to certify the authority of statutory representation One (1) copy
  (A copy of family register, or, in case of a person with parental authority, a photocopy of the insurance card on which the name of a dependent is specified is accepted.)
• Document to certify that the person is a statutory representative of a minor or an adult ward One (1) copy
  (A photocopy of an official document of the statutory representative, such as a driver's license and passport)

If the request is made by a person entrusted by the person concerned:

Please fill out the prescribed request form to describe the relationship with the person concerned and enclose it with the following documents to certify the relationship to the person concerned, in addition to the document for identity verification.

• Letter of Proxy One (1) copy
• Certificate of seal registration certificate of the party concerned One (1) copy

1.2 Fees

• Among the Requests for Disclosure of Personal Information, the Company shall charge posting fees for the requests for disclosure by mail.
• After the reception desk reports the fees, if no payment is made within the prescribed period (one week from the date of notification or two weeks if the Group is unable to contact the requester) or when the Group is unable to confirm payment, the request will be deemed to have never been made.
• The Group will not charge fees for a request for disclosure associated with the leakage of personal information arisen from a reason attributable to the Group. However, if the facts are unspecified at the time of request, the Group will promptly refund the fees that have been collected only for the case attributable to the Group.

2. How Group Responds to Requests for Disclosure of Personal Information

Upon receipt of a request for disclosure of retained personal data, the Group shall respond by either sending a document to the requester's address stated on the request form or by sending an email message to the address stated on the request form with an electromagnetic record attached thereto in accordance with the requester's preference. (However, when it is difficult to complete such disclosure in the form of electronic media (such as USB memory, CDR, and DVD), or through email, the Group shall notify the requester of the same and respond in writing. Also, when responding via an electronic medium, the Group will use only the medium that the person concerned has sent).
In addition, with regard to the request for correction of the retained personal data (excluding the requests for disclosure), the Group will respond in written form by sending a document to the requester's address provided on the request form.

3. Purposes of Use of Personal Information that is acquired in relation to a Request for Disclosure of Personal Information

The Group shall handle the information only to the extent necessary for the Request for Disclosure of Personal Information.

4. Inquiries on Personal Information

The Group has established the Personal Information Help Desk in order to respond appropriately to complaints, consultations, and disclosure issues related to personal information. When the Group receives inquiries, a response shall be made only when the inquiry is about the personal information retained by the Group; the Group shall not respond to inquiries regarding the personal information of customers and users of business partners with whom the Company has concluded a consignment agreement.

Joint Use of Personal Information

The Group may jointly use the personal information of customers for the automotive business, property business, global business, customer business, financial guarantee business, IT business, social business, and other businesses operated by the Group as described below:
(*Please refer to the List of Group Companies for more details of the Group.)

<Activities>

• To make contact regarding matters on transactions
• To provide products and services that the Group handles
• To perform contracts concluded with the Group
• To offer notifications on the products and services that the Group handles, to introduce services related thereto, and to request product monitoring and participation in inquiries
• To introduce fairs and events that are to be held (hosted, jointly-hosted, or sponsored) by the Group
• To analyze the acquired information on the purchase history, visiting history, and activities history conducted for the purpose of developing and advertising new products and services
• To respond to inquiries, document requests, and other requests
• For other purposes on which the customers have given consent in advance

<Items of Personal Information for Joint Use>

Name, company name, department, position, address, phone number, fax number, email address, product purchase history, and other information.

<Person Responsible for the Management of Personal Information to be Jointly Used>

Prestige International Inc.
(*Please refer to our Company Profilepage for more information on the address and the names of representatives)

Handling of Anonymously Processed Information of the Group

• When creating anonymously processed information, the Group shall, in accordance with the applicable laws and regulations, implement the measures necessary to ensure that the specific individuals cannot be identified and that the personal data used to create the anonymously processed information cannot be reproduced. Also, when using the anonymously processed information, the Group shall not check such information against other information with the intent to identify the person related to the original personal data.
• When creating anonymously processed information, the Group shall announce to the public the items pertaining to the individuals that are contained in such anonymously processed information in accordance with the applicable laws and regulations.
• When the Group provides the anonymously processed information that was created to a third party, the Group shall announce to the public the items concerning the individuals contained in the anonymously processed information to be provided to a third party, as well as the provision method, and shall expressly state to the third party that the information to be provided is anonymously processed information in accordance with the applicable laws and regulations.

Handling of Pseudonymized Information of the Group

• When creating pseudonymized information, the Group shall process personal information in accordance with the applicable laws and regulations.
• When handling pseudonymized information, the Group shall not check the pseudonymized information against other information with the intent to identify the person related to the personal information that has been used to create the pseudonymized information.
• In addition to cases based on laws and regulations, the Group will not provide pseudonymized information (excluding the information that falls into the category of personal information) to a third party unless specified otherwise.

March 1, 2024