ALEXON Co., Ltd. (hereinafter referred to as "the Company") has established the following policy to ensure the proper handling of personal information as an organization, in accordance with the "Act on the Protection of Personal Information" (hereinafter referred to as the "Personal Information Protection Act").

1. Definitions

In this policy, the terms 'personal information,' 'personal data,' 'retained personal data,' and 'records of third-party provision' are defined as per the Personal Information Protection Act.

2. Acquisition of Personal Information

The Company acquires personal information by safe and appropriate means and does not obtain personal information through false or other fraudulent methods.

3. Safety Management of Personal Data

The Company will ensure that all employees who handle personal data are fully trained on its safety management. Additionally, we will strive to maintain personal data in an accurate and up-to-date manner and will work to implement safe and appropriate management measures to prevent unauthorized access, loss, leakage, destruction, damage, and alteration of personal data.

(Establishment of Basic Policy)
1. In order to ensure the proper handling of personal data, the Company has established a basic policy (this policy) regarding compliance with relevant laws and guidelines, as well as a contact point for inquiries and complaints.

(Regulation of Personal Data Handling)
2. For each stage of acquisition, use, storage, provision, deletion, and disposal, we will formulate and implement regulations regarding the handling methods, responsible parties, and their duties related to personal data.

(Organizational Safety Management Measures)
3. The Company will appoint a responsible person for the handling of personal data and clarify the scope of personal data handled by employees engaged in such activities. The responsible person will confirm that personal data is handled in accordance with established procedures.

(Human Safety Management Measures)
4. Regular training will be conducted for employees regarding matters to be noted in handling personal data.
5. Provisions regarding confidentiality of personal data will be included in the employment regulations.

(Physical Safety Management Measures)
6. Measures will be implemented to prevent unauthorized access to personal data by employees other than those authorized to handle it.
7. Measures will be taken to prevent theft or loss of equipment, electronic media, and documents that handle personal data.

(Technical Safety Management Measures)
8. Access control will be implemented to limit the scope of personnel and personal data databases handled.
9. Mechanisms will be introduced to protect information systems that handle personal data from unauthorized access and malicious software from external sources.

4. Purpose of Use of Personal Information

Personal information may be used for the following purposes. If the need arises to use personal information for purposes other than those stated, we will notify you of such intentions and obtain your consent, except as required by law. Additionally, any changes to the purpose of use will be made within a reasonable range that is considered relevant to the previous purpose.

• To ship products and provide services.
• To provide support for the use of products and services.
• To serve as a reference for future product development and sales strategies.
• To analyze the usage status of products and services and establish an appropriate support system.
• To provide information related to new products, services, events, and campaigns.
• For the billing and collection of various fees.
• To conduct surveys and reflect the findings in the Company’s various services.
• For communication regarding transactions, meetings, and responses to various inquiries.
• For managing contractual relationships with business partners and necessary business communications and negotiations.
• For managing personnel-related matters of employees.
• For recruitment activities.
• To investigate the number of users and traffic on the Company’s website.
• To monitor for fraudulent activities on the Company’s website.
• For confirmation work related to accounting audits.
• To subcontract business within the necessary scope to achieve the purposes of use stated above.

5. Provision of Personal Data to Third Parties

The Company will not disclose or provide acquired personal data to third parties, except in the following cases. The same handling will apply when the Company acquires personal information from business partners.

• When prior approval or consent is obtained from the individual.
• When required by law.
• When it is necessary to protect the rights or property of the Company, the individual, or a third party, and obtaining the individual's consent is difficult.
• In the case of a merger or company split, where business or rights and obligations are transferred between the Company and other companies.

6. Outsourcing of Personal Data Handling

The Company may outsource the handling of personal data to facilitate smooth business operations and provide better services. In such cases, the Company will require that the outsourced party handles personal data appropriately and will conduct necessary supervision, including regular reviews of their compliance.

7. Disclosure of Retained Personal Data

1. The Company will promptly inform the individual of the retained personal data and records of third-party provision upon request. However, disclosure of all or part of the retained personal data may not be possible in the following circumstances:

・If there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party.
・If disclosure would violate other laws and regulations.
・If there is a significant risk of hindering the proper conduct of the Company's business.

2. If the Company decides not to disclose all or part of the retained personal data and records of third-party provision in accordance with the provisions of paragraph 1, or if it is determined that such retained personal data and records do not exist, or if disclosure in the manner requested by the individual is difficult according to the provisions of the same paragraph, the Company will promptly notify the individual of this decision and the reasons for it.

8. Correction, Addition, or Deletion of Retained Personal Data

• If the Company becomes aware of an error in retained personal data upon request from the individual, and a request for correction, addition, or deletion (hereinafter referred to as "corrections, etc.") is made, the Company will promptly conduct the necessary investigation and, unless other laws and regulations provide special procedures, will make corrections to the content of the retained personal data based on the findings.
• When the Company makes corrections, etc., to all or part of the retained personal data in response to the request mentioned in the previous paragraph, or when the Company decides not to make such corrections, the Company will promptly notify the individual of this decision and the reasons for it.

9. Suspension of Use of Retained Personal Data, etc., and Stopping Provision to Third Parties

• Upon request from the individual, if it is determined that retained personal data has been handled in violation of Article 18 or Article 19 of the Personal Information Protection Act, or has been acquired in violation of Article 20, and if it is found that there is a valid reason for the request to suspend or delete the use of such retained personal data (hereinafter referred to as "suspension of use, etc."), the Company will promptly suspend the use of the retained personal data to the necessary extent to correct the violation. However, this does not apply in cases where significant costs would be incurred to suspend the use, or when it is difficult to suspend the use, and necessary alternative measures are taken to protect the individual’s rights and interests.
• If the Company receives a request from the individual to stop providing retained personal data to third parties due to a violation of Article 27, paragraph 1, or Article 28 of the Personal Information Protection Act, and it is found that there is a valid reason for this request, the Company will promptly stop providing the retained personal data. However, this does not apply in cases where significant costs would be incurred to stop the provision or when it is difficult to stop the provision, and necessary alternative measures are taken to protect the individual’s rights and interests.
• If the Company receives a request from the individual to suspend the use of retained personal data, or to stop providing it to third parties, on the grounds that the Company no longer needs to use such personal data, that a situation as described in Article 26, paragraph 1, of the Personal Information Protection Act has occurred, or that there is a risk of harming the individual’s rights or legitimate interests due to the handling of the retained personal data, and it is found that there is a valid reason for this request, the Company will promptly suspend the use of the personal data or stop its provision to third parties to the necessary extent to prevent infringement of the individual's rights and interests. However, this does not apply in cases where significant costs would be incurred to suspend the use or provision or when it is difficult to do so, and necessary alternative measures are taken to protect the individual's rights and interests.
• When the Company has suspended the use of all or part of the retained personal data upon request, or when a decision has been made not to suspend the use, or when the Company has stopped providing all or part of the retained personal data to third parties, or when a decision has been made not to stop such provision, the Company will promptly notify the individual of this decision and the reasons for it.

10. Procedures for Disclosure of Retained Personal Data, etc.

If you wish to request disclosure, etc., as outlined in the previous three sections, please fill out the designated Personal Information Disclosure Request Form provided by the Company and send it along with the required documents specified in the form to the contact point listed in Section 12. The personal information provided by the individual will be used solely for the purpose of responding to the request and will be stored securely.
株式会社アレクソン個人情報開示等請求書(ALEXON Personal Information Disclosure Request Form).pdf
Please note that the request form and attached documents will not be returned.

11. Compliance with Laws and Regulations Related to Personal Information and Continuous Improvement

If you wish to request disclosure, etc., as outlined in the previous three sections, please fill out the designated Personal Information Disclosure Request Form The Company will comply with laws, regulations, and guidelines related to personal information, and will review and improve the initiatives mentioned in the previous sections as necessary to further strengthen the protection of customers' personal information.

12. Inquiries Regarding Personal Information

Requests for disclosure, correction, suspension of use, complaints, and consultations related to personal information protection are accepted at the following contact point:

Address
1-8-6 Azuchicho, Chuo Ward, Osaka City, Osaka 541-0052, Japan
ALEXON Co., Ltd.
Management Department
Personal Information Protection Consultation Desk

Established Date: March 1, 2010
Revised Date: April 1, 2022
ALEXON Co., Ltd.
President and CEO: Atsushi Mise