1.Definition of Personal Information

“Personal Information” means information that can help identify specific individuals as defined by the “Act on Protection of Personal Information”, including but not limited to the name, age, telephone number, email address, address and employer of an individual as well as information on products or services purchased by an individual, information on inquiries made by an individual and ID numbers.

2.Basic Policy on Personal Information Protection and Management

1. PROMASAFETY USA LLC will collect, obtain, use and provide Personal Information in an appropriate manner.
2. PROMASAFETY USA LLC will make best efforts to ensure personal data to be precise and up-to-date.
3. PROMASAFETY USA LLC will take necessary and appropriate measures to manage personal data including protecting personal data against unauthorized access, loss, leak and damage.
4. PROMASAFETY USA LLC will comply with laws, regulations and the guidelines for them as well as internal rules on Personal Information.
5. When contracting the handling of personal data to a third party, PROMASAFETY USA LLC will only entrust to a contractor who meets the requirements based on PROMASAFETY USA LLC’s internal rules. PROMASAFETY USA LLC will manage such contractors in an appropriate manner.
6. PROMASAFETY USA LLC will continue to try improving protection of Personal Information.

3.Name of Business Operator handling Personal Information

PROMASAFETY USA LLC

4.Purpose of Use of Personal Information

PROMASAFETY USA LLC will ensure that, in the process of providing its products and services, it will obtain Personal Information necessary to carry out its business through the PROMASAFETY USA LLC business entities (as described in 4(1) below) for the purposes of use (as described in 4(2) below), and that it will handle Personal Information within the scope of the purposes.
For details of the purposes of use of Personal Information by each PROMASAFETY USA LLC business entity, please go to the website of the respective business entity.
The purposes of use of Personal Information obtained from shareholders are as described in 4(3) below.

1. PROMASAFETY USA LLC’s Businesses
   1. Planning, development, manufacturing, sales, installation and maintenance of machines and equipment.
   2. Information communication and information processing services.
   3. Collecting, analyzing and providing information on themes related to people, culture, life style and health. Managing and operating sports and cultural facilities.
   4. Planning and producing advertisement and acting as an advertising agent. Manpower services, for-fee job placement services, leasing business, non-life insurance agency business, credit card business, freight services, security services, construction business and real estate management services.
   5. Sales of foods, beverages and general merchandises.
2. Purposes of Use of Personal Information
   1. Providing customers with products and services that PROMASAFETY USA LLC and its subsidiaries and partners offer (“Products”) and maintenance of them.
   2. Planning, development, manufacturing, sales and installation of Products.
   3. Providing and distributing information such as information on Products.
   4. Managing contractual relationship related to providing Products and other business activities
   5. Advertising and holding campaigns, exhibits and other events to promote Products.
   6. Providing and distributing brochures, CD-ROMs, materials and samples of Products.
   7. Conducting surveys on Products and analysis of the results.
   8. Ensuring the security of PROMASAFETY USA LLC’s business bases.
   9. Providing information, contacting and notifying applicants seeking employment with PROMASAFETY USA LLC and PROMASAFETY USA LLC Group companies. Carrying out selection processes.
3. Purposes of Use of Personal Information obtained from Shareholders
   1. Exercising rights and fulfilling obligations provided by and required by laws and regulations.
   2. Facilitating understanding of the business of PROMASAFETY USA LLC. Carrying out measures and initiatives that facilitate a good relationship between PROMASAFETY USA LLC and its shareholders.
   3. Collection, preparation and statistical processing of data in accordance with the prescribed standards required by laws and regulations.

5.Joint Use

PROMASAFETY USA LLC uses personal information (names, date of birth, place of employment, image, development data etc.) which PROMASAFETY USA LLC obtained when products are purchased, developed or services are provided etc. within the purposes described in 4 above, jointly with PROMASAFETY USA LLC Group Companies, joint research partners, dealers and agents. PROMASAFETY USA LLC is responsible for the management of such Personal Information.

6.Providing Personal Information to Third Parties

PROMASAFETY USA LLC will not disclose or provide personal data to third parties without consent of the Persons in Question, except in the following cases. However, even in the cases of (5), (6) and (7) below, PROMASAFETY USA LLC will obtain consent of the Persons in Question before personal data is provided to third parties in foreign countries.

1. When required by laws and regulations.
2. When necessary to protect life, well being or property of the Persons in Question, and when it is difficult to obtain the consent of them.
3. When necessary particularly for improving public health or promoting healthy growth of children, and when it is difficult to obtain the consent of the Persons in Question.
4. When necessary to provide cooperation to national agencies, municipalities, or entities which are entrusted by such governmental organizations in the performance of their tasks required by laws and regulations, and when obtaining consent from the Persons in Question can hinder the proper execution of such tasks.
5. When contracting out a part of or the entire operations to a contractor for facilitating smooth operations.
   In this case, PROMASAFETY USA LLC will conclude an agreement with the contractor on the handling and protecting of Personal Information and manage such information in an appropriate manner.
6. When the consent of Persons in Question has been obtained in advance.
7. When Personal Information is jointly used as described in 5 above.
8. When a business is transferred and succeeded.

7.Information needed for Requesting Disclosure, etc.

PROMASAFETY USA LLC will promptly respond to requests, within a reasonable scope, for disclosure of stored personal data, revision, addition or deletion of the contents, suspension of use or deletion of such data (“Request for Disclosure, etc.”). The procedures for such requests are as follows.

1. Where to send requests for disclosure, etc.
   Please mail your request to PROMASAFETY USA LLC Corporation. Please mark the envelop with “Request for Disclosure, etc.” to info@promasafety.com
2. Documents (forms) to be submitted with “Request for Disclosure, etc.”
   When sending a “Request for Disclosure, etc.”, please download the request form as described in (a) below and fill in all the spaces provided. Please enclose the ID documents described in (b) below and a return envelop with the address of the Person in Question (the same address as on the ID) and mail them to the address provided in 7(1) above.
   
   When notifying the purpose of use or requesting disclosure, please return an addressed and stamped return envelop as described in (c) below.
   1. Request form prescribed by PROMASAFETY USA LLC
   2. ID document
      One of the following documents and a seal registration certificate (when a seal is affixed on the request form)
      • Copy of driver’s license
      • Copy of passport
      • Copy of alien registration card
      • Copy of residence card
      • Copy of special permanent resident certificate

Or, a copy of each of the following documents:

• Copy of either health insurance card or pension book;
  and
• Copy of family register or resident register

[When a request is made by an agent:]

• An agent with power of attorney: Power of attorney (affixed with a registered seal) and each of the following documents:
  • Seal registration certificate for the seal affixed on power of attorney
  • Documents to prove the agent’s identity
    (the same ID documents as required for the Person in Question above)

1. When a request is made by a legal representative: One copy of each of the following:

For a minor

• Copy of family resister of the Person in Question or copy of health insurance card with the names of dependents.

For an adult ward

• Documents to prove registration as prescribed in Section 10 of the Act on Guardianship Registration, etc.
• Document to prove the right for legal representation for a minor or an adult ward.
• ID documents of the legal representative.
  (the same ID documents as required for the Person in Question above)

1. Addressed and stamped return envelope
   • Please write down the address of the Person in Question on the envelope.
     (the address on the ID documents for the Person in Question or his/her agent)
   • When notifying the purpose of use or requesting disclosure, please affix a stamp that covers the cost of certified registered mail.
2. Reply to Request for Disclosure, etc.
   • A reply will made in writing and sent using the return envelop.

8. When Request for Disclosure, etc. cannot be granted:

A Request for Disclosure, etc. will not be granted when laws and regulations present the grounds and when there are flaws in the information presented in accordance with 7 above.