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The Japanese text is the original and the English text is for reference purposes.In the case of inconsistencies between the English version and the Japanese version, the Japanese version shall prevail.

1. Handling of personal information

Compliance
VECTOR INC. and its Group companies (the “VECTOR Group”) handle personal information (meaning personal information prescribed in the Act on the Protection of Personal Information (Act No. 57 of 2003; “Personal Information Protection Act”) in accordance with the Personal Information Protection Act and related laws, and this Privacy Policy.

Purpose of Use
The VECTOR Group shall acquire personal information by fair and appropriate means, and use it within the scope indicated under “Purpose of Use” in the “Table.” When acquiring personal information other than that indicated under “Personal Information Type” in the “Table” below, the Group will use it after notifying the individual or announcing the purpose of use.

Outsourcee management
The VECTOR Group may outsource some business operations in relation to personal information. The Group’s policy is to have sufficient supervision over the outsourcee upon such outsourcing, including conclusion of an outsourcing agreement, etc.

Third party provision
The VECTOR Group will not disclose or provide personal information to a third party without the consent of the principal; except for in the case where there is a reason for exclusion stipulated in the laws and regulations.

Joint use
The VECTOR Group will perform “joint use” in the “Table” and also may jointly use the personal information in carrying out events jointly held with other corporations, etc. or on some other occasions. In such instance, the Group will clarify and notify or announce in advance the purpose, personal data items, and the scope of users and persons responsible for management.

2. Personal information to be collected and purpose of use

The VECTOR Group will use the personal information in the following types, within the scope of “Purpose of Use” in the “Table” below.

Table

Personal Information Types Purpose of Use Acquisition Method Joint Use
Personal information on coordinator at client, mass media, affiliates and other business partners Provision of information and contacts relating to the business Direct acquisition from the principal Joint use items
• Contact information of coordinator such as name, work address, telephone No., or email address

Scope of joint use
• VECTOR INC., its consolidated subsidiary and its affiliates under the equity method

Purpose of use of joint user
• Provision of information and contacts relating to the business

Party responsible for management of personal data
• VECTOR INC. (see here for representative person and address)
Sending publications and periodicals
Personal information of those who use the services (including various campaigns, seminars, questionnaires, etc.) or purchase VECTOR Group goods Provision of goods or services(including use and login management, etc. for analysis of attribute information, etc., to propose and provide appropriate services), provision of accompanying information and contacts, campaign information notification, advertisement distribution (including use for analysis of customer attribute information, purchase history, etc., to distribute appropriate advertisements), response to unauthorized or improper use of services, improvement of service content, research and development on new products and services, notification of changes in Terms of Use, Privacy Policy, etc. Direct acquisition from principal, acquisition through provision by third parties (online marketplace business operators, etc.) Joint use items
• Name, address, gender, age, date of birth, contact information, purchase history of customers

Scope of joint use
• VECTOR INC., its consolidated subsidiary and its affiliates under the equity method

Purpose of use of joint user
Provision of goods or services, provision of accompanying information and contacts, campaign information notification, advertisement distribution, response to unauthorized or improper use of services, improvement of service content, research and development on new products and services, notification of changes in Terms of Use, Privacy Policy, etc.

Party responsible for management of personal data
• VECTOR INC.
Personal information of those who desire to join the VECTOR Group Work and contact in connection with implementation of screening activities Direct acquisition from the principal, acquisition through provision by third parties (staffing agency, referral by employee, etc.) Joint use items
• Information submitted by applicant including name, contact information, career, personal record, etc.

Scope of joint use
• VECTOR INC., its consolidated subsidiary and its affiliates under the equity method

Purpose of use of joint user
• Work and contact in connection with implementation of screening activities

Party responsible for management of personal data
• VECTOR INC.
Personal information of those who make inquiries, etc. of the VECTOR Group Response to inquiries, requests or complaints, etc. Direct acquisition from the principal (via telephone, email, facsimile, letter, etc.) Joint use items
• Provided information including name, contact information, etc.

Scope of joint use
• VECTOR INC., its consolidated subsidiary and its affiliates under the equity method

Purpose of use of joint user
• Response to inquiries, requests or complaints, etc.

Party responsible for management of personal data
• VECTOR INC.
Personal information on shareholders Exercise of rights and performance of obligations under the Companies Act and other laws and regulations, management of shareholder information, provision of various benefits in relation to status of shareholders, provision of information on various events and questionnaires, etc. Acquisition from securities firms, trust banks, etc. Joint use items
• Name, contact information, number of shares held, acquisition date of shares,

Scope of joint uses
• VECTOR INC., its consolidated subsidiary and its affiliates under the equity method

Purpose of use of joint user
• In-Group management of shareholder information, response to inquiries and requests, provision of information on various events and questionnaires, etc.

Party responsible for management of personal data
• VECTOR INC.

3. Security management measures

The VECTOR Group takes necessary measures for prevention of leak, loss or damage of collected information or for any other proper management of collected information. Each company in the VECTOR Group will carry out development of internal systems, continuous improvement of its personal information protection management system, and overall educational activities.

4. Window for disclosure, correction, suspension of use and other handling of personal information

For personal information collected by the VECTOR Group, it is possible to make requests, etc. for disclosure, correction or suspension of use, etc. in accordance with the Personal Information Protection Act. In such instance, sometimes submission of documents for identification will be necessary, and a handling fee will be charged for disclosure. Any other inquiries about handling of personal information shall be made below:

Inquiries:
Please make requests for disclosure, etc. in a form prescribed by the VECTOR Group. Requests for disclosure and other inquiries about personal information shall be made below:

Operating hours: 9am to 6pm Monday to Friday (except public holidays and New Year holidays
Inquiries to: VECTOR INC. (Personal Information Inquiry Counter)
privacy@vectorinc.co.jp

5. Review and revision of this Privacy Policy

This Privacy Policy shall be reviewed and revised when necessary. If there is a change in handling of personal information already acquired as a result of revision of this Privacy Policy, the Group will follow the procedures prescribed in the Personal Information Protection Act.

Establishment: January 31, 2005
Latest Revision: August 8, 2022

Keiji Nishie, Representative Director, VECTOR INC.