TSUGAMI CORPORATION (hereinafter “the Company”) recognizes the importance of protecting personal information, and considers it the Company’s social responsibility and duty to do so.
With that in mind, the Company has set out the following Privacy Policy and will make every effort to raise awareness amongst its employees, to ensure that all information is protected.

1．Legal compliance

The Company will comply with all applicable legislation in relation to the handling of personal information.

2．Purpose of using personal information

As a rule, the Company will only use personal information for the purpose of providing customers with information on the Company’s products and services, for the purpose of promotional, IR or recruitment activities, or for related purposes. If using personal information for any other purposes, the Company will clearly state the relevant purpose on a case-by-case basis, and will only use information for the purpose indicated when the information was provided.

3．Handling personal information and security management

The Company will adequately manage personal information, and take preventive steps and security measures to guard against unauthorized access, loss, damage, falsification or leaks in relation to personal information. The Company will also make every effort to raise awareness amongst employees, to ensure that they handle personal information in an appropriate manner.

4．Providing and disclosing information to third parties

The Company will only disclose personal information to a third party in the following circumstances.

• (1) If the relevant individual has given their consent
• (2) If the Company deems it appropriate for one of its affiliates to respond to or take action based on the contents of an inquiry from the relevant individual
• (3) If necessary to disclose personal information to a subcontractor or partner company with which the Company has signed a confidentiality agreement in advance, for purposes already indicated to the relevant individual
• (4) If necessary to disclose personal information to a financial institution or other such organization for the purpose of completing a payment (e.g. when purchasing a product or paying for a service)
• (5) If disclosing personal information in such a way that it is impossible to identify the relevant individual (e.g. statistical data)
• (6) If disclosure of personal information to a third party is permitted by law or in accordance with standards or guidelines.

5．Revisions to the Privacy Policy

The Company will revise this Privacy Policy in line with changes to applicable legislation, and will make every effort to continually improve initiatives to protect personal information.