Safety management of personal information

We conduct necessary and appropriate supervision of our employees so that personal information can be safely managed against risks such as loss, destruction, tampering and leakage of personal information. In addition, when we entruve all or a part of the handling of personal information, we will carry out the necessary and appropriate supervision so that the security of personal information can be managed at the destination. The outline of our safety management measures is as follows.

1. Definition of personal information

In this privacy policy, personal information means personal information defined by Article 2, paragraph 1 of the personal information protection act.

2. Purpose of use of personal information

We use personal information for the following purposes.

To provide our services, goods, etc. (hereinafter referred to as "our services, etc.")

To respond to the guidance and inquiries regarding our services, etc

For the guidance of our service

To respond to the act of violating our agreement, policy, etc

To notify the change of the certificate of incorporation, etc

To improve our services, develop new services, products, etc

To grasp and analyze the acquired history, behavior history and purchase history, and to improve and improve our service and to develop and advertise new products and services according to interests and preferences

For employment management and in-house procedures

In order to respond to shareholders' management, company law and other legal procedures (personal information of shareholders and holders of share options)

To create statistical data processed in a form that cannot be identified in relation to our services

Information provision from our company

In addition, for purposes associated with the purpose of use

3. Change of personal information use purpose

The company may change the scope of the use of personal information within the scope of reasonableness, and notify or publicize the individual who is the subject of personal information (hereinafter referred to as the "person").

4. Restrictions on personal information

Except as permitted by personal information protection act or other laws and regulations, we do not deal with personal information beyond the scope necessary for achieving the purpose of use without obtaining the consent of the individual. However, this is not the case.

Laws and regulations

When it is necessary for the protection of a person's life, body or property, and when it is difficult to obtain the consent of the person

When it is especially necessary for the improvement of public health or the promotion of sound training of children, when it is difficult to obtain the consent of the principal

In cases where a national institution or local public entity or a person who has been entrusted with the said Act requires cooperation in order to carry out the affairs specified by laws and regulations, there is a risk of hindering the execution of said affairs by obtaining the consent of the principal

In cases where personal data is provided to academic research institutes, etc., the relevant academic institutes, etc.need to handle said personal data for academic research purposes (excluding cases where a part of the purpose of handling said personal data is the purpose of academic research, and there is a possibility that the right interests of individuals may be violently infringed)

5. Appropriate acquisition of personal information

5.1

Our company acquires personal information appropriately and does not acquire by false or other illegal means.

5.2

Except for the following cases, we do not obtain personal information (meaning defined in Article 2, paragraph 3 of the personal information protection act) without prior consent of the individual.

Cases falling under any of items (I) to (IV) inclusive

In cases where it is necessary to acquire the necessary personal information from the academic research institutes, etc., it is necessary to obtain the necessary personal information for the purpose of academic research (excluding the case where the part of the purpose of obtaining the necessary personal information is for academic purposes, and the case where there is a possibility that the right interests of the individual may be violently infringement) (limited to cases where the company and the academic research institutes carry out academic research jointly).

The personal information necessary for the purpose is disclosed by the persons specified in the items of Article 57, paragraph (1) of the individual, the national organization, the local government, the personal information protection act, and other persons specified by the Personal Information Protection Commission regulations

In the case where the personal information is clearly specified in the external form, the personal information is acquired or photographed

When the person receives the provision of personal information to be taken into consideration in the manner which is not to be provided by a third party pursuant to the provision of paragraph

6. Safety management of personal information

We conduct necessary and appropriate supervision of our employees so that personal information can be safely managed against risks such as loss, destruction, tampering and leakage of personal information. In addition, when we entruve all or a part of the handling of personal information, we will carry out the necessary and appropriate supervision so that the security of personal information can be managed at the destination. The outline of our safety management measures is as follows.

The company complies with the personal information protection act, the relevant laws and regulations, and the applicable guidelines, and accepts questions, consultations and complaints about the handling of personal data at the window shown in paragraph 15.

The company specifies the handling method, the responsible person, the person in charge, and the duty for each stage such as acquisition, use, preservation, provision, deletion, and disposal.

The person responsible for the handling of personal data is established, and the person confirms that the personal data is handled according to the maintenance handling method. In addition, we will establish a report communication system for employees to understand the fact that they violate laws and regulations, internal rules, etc. In addition, the responsible person periodically checks the handling situation of the personal data.

The necessary training will be carried out for employees regarding the handling of personal data. In addition, the provisions concerning the confidentiality of personal data are listed in the rules of employment.

We will conduct measures that cannot be easily accessed by employees or individuals who can handle personal data. In addition, in order to prevent theft or loss of equipment, electronic media, and documents handling personal data, documents containing electronic data or personal data recorded with personal data are stored in a cabinet, a bookable cabinet, etc. In addition, if the information system handling personal data is operated only by equipment, the equipment is fixed by security wire or the like. In addition to this, we take measures necessary to prevent theft or loss of equipment, electronic media and documents, etc. handling personal data, and carry out measures to prevent personal data from being easily detected when carrying such equipment, electronic media, etc., including movement within a business establishment.

Identify equipment that can handle personal data and employees handling the device and prevent unnecessary access to personal data. We introduce a mechanism to protect personal data handling devices from external or illegal software.

When the personal data is deleted or the personal data is recorded, and the electronic medium, etc. is discarded, the responsible person confirms it.

7. Third party offer

7.1

We do not provide personal information to the third party without the consent of the individual in advance except for the case falling under any of the items of paragraph (4). However, the following shall not apply to the third party specified in the above.

In the case where the personal information is provided in accordance with the fact that the company entrusts all or part of the handling of personal information within the scope necessary for the achievement of the purpose of use;

In cases where personal information is provided as a result of a merger or any other reason

Joint use of the personal information protection act

7.2

Notwithstanding the provisions of paragraph (1), the company shall, except in cases where it falls under any of the items of paragraph (4), provide personal information to a third party (excluding the country designated by the personal information protection commission rules pursuant to Article 28 of the personal information protection act) in a foreign country (excluding those designated by the personal information protection commission rules in accordance with Article 28 of the personal information protection act), and obtain the consent of the individual to admit the provision to the third party in advance in the foreign country and take measures based on the personal information protection act.

7.3

When we provide personal information to third parties, we make and preserve records according to Article 29 of the personal information protection act.

7.4

When we receive personal information from a third party, we shall make necessary confirmation in accordance with Article 30 of the personal information protection act, and prepare and preserve the record for the confirmation.

7.5

Notwithstanding the provisions of paragraph (1), we may provide the information of the user to the partner company based on the terms of use of the service and other special provisions.

8. Individual information

When we obtain personal information from the third party and use it as personal data, our company responds to the consent of the individual in acquiring the personal related information as personal data beforehand, and utilizes it in the scope of the purpose of use in paragraph 2

In the case where the third party is supposed to use personal related information as personal data, the company shall confirm that the third party has obtained the consent of the person in advance for acquiring such personal related information as personal data.

9. Disclosure of personal information

When we are requested to disclose possession personal data or third party records based on the provisions of the personal information protection act, we shall disclose without delay to the person in the confirmation of the fact that it is a request from the person himself. However, this is not the case in which the company does not assume the obligation of disclosure by personal information protection law or other laws and regulations.

10. Correction, etc. of personal information

In accordance with the reason that personal information is not true, the person himself is requested to correct, add or delete the contents of the personal information protection act (hereinafter referred to as "correction, etc.") based on the provisions of the personal information protection act, and to confirm that it is a request from the person himself, perform the necessary investigation without delay at the time necessary for the achievement of the purpose of use, and to revise the contents of the personal information on the basis of the result, and make the correction of the contents of the personal information on the basis of the result thereof, and so that the personal information may be corrected, added or deleted based on the personal information protection act in accordance with the provisions of the personal information protection act (hereinafter referred to as "correction, etc.") our company If it is found that it is a request from the person himself, it is necessary to carry out the investigation without delay in the range necessary for the achievement of the purpose of use, and to correct the content of the personal information on the basis of the result, and notify the person to that effect (the decision is made to the person when the decision has not been made, for example, of the Amendment). However, this is not the case in which the company is not obliged to comply with the personal information protection act or other laws and regulations.

11. Suspension of use of personal information

In the case where the person is requested to suspend or suspend the use of the personal information pursuant to the provisions of the personal information protection act (hereinafter referred to as "suspension of use, etc.") pursuant to the provisions of the personal information protection act (hereinafter referred to as "suspension of use, etc.") pursuant to the reason that the personal information of the person has been treated beyond the scope of the intended purpose of use, or false or other wrongful means, the said person shall be suspended from the provision of the personal information protection act pursuant to the provisions of the personal information protection act (hereinafter referred to as "suspension of suspension") If you find that there is a reason for the request, you shall suspend the use of personal information or suspend suspension of your personal information without delay, confirming that you are a request from your own. However, this is not the case in which the company is not obliged to suspend use or suspension of services by the personal information protection act and other laws and regulations. The reason for this is that, due to the fact that the personal information specified by the Personal Information Protection Commission pursuant to the provisions of the Personal Information Protection Commission, which is likely to harm the rights and interests of the individual, which is likely to harm the rights and interests of the individual in the circumstances pertaining to the security of personal data prescribed in the personal information protection act pertaining to the personal data protection method pertaining to the retained personal data identified by the person, and the fact that the person is not required to use the personal information of his / her own person, the fact that the person's right or legitimate interests may be damaged due to the handling of the retained personal data identified by the individual In the case where it is found that there is a reason for the request in the case where it is found that there is a reason for the request in accordance with the provisions of the personal information protection act, when it is found that the request is made by the person himself, he / she stops the use of personal information or suspends suspension, and notifies the person to that effect. However, this is not the case in which the company is not obliged to suspend use or suspension of services by the personal information protection act and other laws and regulations.

12. Handling of anonymous processing information

12.1

When we make an anonymous processing information (meaning only those specified in Article 2, paragraph (6) of the personal information protection act, and constitute an anonymous processing information database, etc. prescribed in Article 16, paragraph (6) of the same act. The same shall apply hereinafter), personal information shall be processed according to the standards specified by the personal information protection commission.

12.2

When we make anonymous processing information, our company shall take measures for safety management in accordance with the standards specified by the personal information protection committee.

12.3

When we create anonymous processing information, we publish the item of information about the individual contained in the anonymous processing information pursuant to the rules of the personal information protection committee.

12.4

When we provide anonymity processing information (including the one made by our company and the ones provided by a third party; and the same shall apply unless otherwise provided), the company shall, in accordance with the rules of the Personal Information Protection Commission, publicize the items and the method of the information about the individual contained in the anonymity processing information provided to the third party beforehand and express the fact that the information pertaining to such provision is anonymous processing information to the third party.

12.5

In dealing with anonymous processing information, we shall not use (1) to collate anonymous processing information with other information, and (2) to obtain information on the method of processing made pursuant to the provision of Article 43, paragraph (1) of the personal identification code or the personal information protection act deleted from the personal information, or (2) only the anonymous processing information received from the third party.

12.6

We shall endeavor to take necessary measures to ensure the proper handling of anonymous processing information and to disclose the contents of the measures for the safety management of the anonymous processing information.

13. Using cookies and cookies

Our service may utilize cookies and similar technologies. These technologies will help us understand the status of our services. Users who wish to disable cookies can disable cookies by changing their web browser settings. However, when you disable cookies, some functions of our service may not be available.

14. External services

Our service uses the following services for the following purposes. For each company's privacy policy, please confirm the website of each business operator.

1) grasp of user's visit situation

Google Analytics access analysis service "Google Anna" and "Google Anna quality" feature.

The function to use is as follows.

Google Anna quality marketing

HP display network impression Report

Report on Google Anna's user attribute and interest category

2) marketing automation

We use the marketing automation tool Wix form provided by wix.com.

A "Wix form" cookie is used to track and collect access data such as the date and time you have viewed your website. We identify the customer's identity and interest by identifying the customer's email address, registration information, and cookies acquired by our application form, business card exchange, and others.

Cookie invalidation and opt out

It is possible for users to change the settings of Internet browsers to disable all cookies. Cookies can be saved at any time by specifying a specific domain and rejecting cookies. Also, for each use service, it is possible to stop the acquisition of data by taking the procedure called opt out. If you want to opt out individually, please proceed from the privacy policy of each site.

Go to the external site.

Privacy policy https://policies.google.com/privacy )

Google Anna tricks opt Addon https://tools.google.com/dlpage/gaoptout )

15. The name and address of the business operator handling personal information and the name of the representative

Coel Corporation

Takahashi JOBO

A simple landing place in komagata Bridge

16. CONTACT

Inquiries, comments, questions, complaints, and other inquiries regarding personal information handling shall be made by telephone or email to the following window.

tel:03-0000-0000

E-mail：info@koel.tokyo

17. Continuous improvement

We will review the operational status of the handling of personal information appropriately, endeavor to make continuous improvements, and may change this privacy policy if necessary.

March 12, 2026