Handling of Personal Information

KYUDEN Holdings recognizes the importance of the rights and interests of individuals, so in order to handle personal information^*1 appropriately, it has established the following Basic Policy on the Protection of Personal Information, and will ensure that all executive officers and employees of KYUDEN Holdings are thoroughly aware of this policy to provide appropriate protection of personal information.

1. We will strictly observe laws and guidelines regarding personal information, other social norms, and our rules and regulations regarding the protection and management of personal information, as well as other regulations.
2. Based on Kyuden group basic policy on information security, we will manage personal information in an appropriate manner, and will implement security measures to manage the risk of unauthorized access to, leakage of, loss of, or damage to personal information.
3. We will handle personal information in the following ways. (1)  Specification, notification, and disclosure of the purpose of use
   We will concretely specify, as much as possible, the purpose of use of your personal information.
   When obtaining your personal information, we will either disclose the purpose of use in advance, or notify you as soon as possible after it has been collected. (2)  Acquisition and handling
   We will acquire your personal information through proper means and use it within the scope of the specified purpose of use.
   However, if we receive an individual's personal identification number^*2 ("My Number") , we will verify the individual's identity. Additionally, when this information is no longer necessary, your personal identification number will be promptly discarded or deleted. (3)  Providing information to third parties
   Except for the following cases, your personal data^*3 will not be provided to third parties.
   Excluding cases stipulated by law, your personal identification number will not be provided to third parties.
   • When you have provided consent.
   • When there is a need to protect the life, wellbeing, or property of a human being, and it is difficult to obtain your consent.
   • When cooperation with governmental organizations or local public entities, or persons entrusted by them in carrying out duties specified by the pertinent laws and regulations is deemed necessary, and obtaining your consent is likely to interfere with the performance of such duties.
   • When providing your personal information in accordance with business succession procedures.
   • When providing your personal information to contractors within the scope deemed necessary for achieving the purpose of use.
   • When sharing your personal information with a third party is deemed acceptable on the basis of other laws and regulations.
   (4)   Handling of notifications and requests for disclosure
   We will, in principle, respond without delay when we receive a request from you regarding retained personal data^*4 for notification of the purpose of use, and requests for disclosure, correction, addition, deletion, suspension of use, erasure, and suspension of provision to third parties of the data.
4. We periodically review our measures for protecting personal information and make every effort to improve them accordingly.
5. In cases where major complaints or similar issues occur, top management will take the initiative to resolve them directly, identify the root causes, and immediately implement corrective measures to prevent recurrence, as well as promptly provide the public with accurate information. In addition, we will also establish a system to deal with complaints regarding our handling of personal information in a rapid and appropriate manner.

*1: As defined by the Act on the Protection of Personal Information (Act No. 57, enacted in 2003). *2: Refers to an individual's personal identification number (known in Japan as "My Number") stipulated in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No.27, enacted in 2013). *3: Refers to personal information constituting a personal information database, etc. that is systematically organized to allow personal information to be searched. *4: Personal data which handling entities have the authority to disclose, add to, delete, revise, suspend the usage of, etc.