Junkosha Inc. (“Junkosha” hereinafter) appropriately handles personal information concerning stakeholders in compliance with the Act on the Protection of Personal Information, the UK/EU General Data Protection Regulation (“GDPR” hereinafter), the California Consumer Privacy Act (“CCPA” hereinafter), and other related laws and regulations. Junkosha properly manages and protects personal data and neither uses personal data for purposes other than its own business purposes nor sells personal information.

Junkosha Inc.
Address: 23F Ochanomizu Sola City, 4-6 Kanda-Surugadai, Chiyoda-ku, Tokyo 101-0062 Japan

1. Informing stakeholders of Company products; providing stakeholders with other information
2. Informing stakeholders of events; contacting stakeholders for other reasons; conducting surveys
3. Sales analysis, marketing research, improving services
4. Responding to inquiries from stakeholders concerning products
5. Confirming the identity of visitors during plant tours and facilitating their guidance
6. Screening prospective associates; human resource management after hiring
7. Preparing various types of human resource data and contacting former associates
8. Responding to inquiries concerning matters incidental or related to items 1) through 7) above

Junkosha handles personal data collected for the purposes of providing services and products to stakeholders, conducting its business, and managing its business and associates within the scope of the stated purposes of use and in accordance with Article 18 of the Act on the Protection of Personal Information of Japan (exceptions to restrictions on the purposes of use).
Where the GDPR applies, Junkosha handles stakeholders’ personal data on the following legal bases stipulated in Article 6 of the GDPR.

1. Junkosha handles customers’ personal information to the extent necessary to carry out product quotations, order acceptance, shipping, invoicing, and payment management.
   The legal basis for this processing is the performance of a contract with the customer or steps taken prior to entering into a contract (Article 6(1)(b) of the GDPR).
2. In marketing activities, such as sharing data with co-organizers and sponsoring companies through our website, at trade fairs, and at seminars, Junkosha handles personal information with the customer’s consent (Article 6(1)(a) of the GDPR).
3. Records such as books and invoices handled pursuant to applicable tax laws are retained on the basis of compliance with a legal obligation (Article 6(1)(c) of the GDPR).
4. During online meetings and business negotiations, Junkosha may make audio and video recordings for the purposes of preparing accurate minutes, improving operational efficiency, sharing the content with those unable to attend, and establishing a common understanding of the meeting content.
   This processing is based on legitimate business interests (Article 6(1)(f) of the GDPR).
   Any consent or approval action displayed in the online meeting system will be treated as a procedure for confirming and acknowledging the validity of such processing.

Data must be provided by stakeholders in order to receive Junkosha services and information or for purposes such as management of Company businesses and associates.
It may be impossible to provide services, in whole or in part, if stakeholders do not provide the required data.

Junkosha handles personal data for customers, shareholders, and associates (including applicants for employment and former associates; collectively, “stakeholders” hereinafter) for the purposes indicated under “3. Purpose of Use of Personal Data” above.
Such personal data includes the following information:

1. Basic Information
   Name, address, contact information (telephone number, fax number, email address), workplace information (company name, section name, position, address, telephone number, email address), school name
2. Trading Partner Information
   Information concerning transactions with customers
3. Information Collected via the Website
   Logs of visits to the Company website (IP address, cookies, etc.), and information on customers who have submitted inquiries or downloaded catalogs

1. Affiliated Companies
   Junkosha may share stakeholder personal data with Junkosha affiliated companies.
   Information on affiliated companies: https://www.junkosha.com/en/corporate
2. Service Providers
   Junkosha may share stakeholder personal data with companies that provide various services for Junkosha, including marketing, responding to orders from stakeholders, payment processing, data analysis, and customer surveys.
3. When Necessary to Comply with Laws or Regulations
   When necessary to comply with laws or regulations, Junkosha may provide stakeholder personal data to authorities or other recipients of disclosure stipulated by applicable laws or regulations.

To achieve the purposes described under “3. Purpose of Use of Personal Data” and “4. Legal Bases for Handling Personal Data,” Junkosha may transfer stakeholder personal data from within the UK/EEA to Junkosha affiliated companies.
Such transfers are carried out lawfully and securely in accordance with the data protection laws and regulations applicable in the relevant jurisdictions (including the GDPR), through the application of adequacy decisions recognized between Japan and the EU and between Japan and the UK, or pursuant to Standard Contractual Clauses (SCCs) concluded within the group.

Junkosha will retain stakeholder personal data for the duration necessary to comply with legal obligations or to provide appropriate services to stakeholders.

1. Rights Concerning Personal Data Held by Junkosha

   will comply with applicable laws and regulations as follows in response to requests from the individuals concerned or their agents regarding personal data in Junkosha’s possession:

   1. Disclosure
      Stakeholders have the right to obtain all important information concerning Junkosha’s actions in the handling of related personal data.
   2. Correction
      Stakeholders have the right to have inaccurate personal data corrected without undue delay and to have incomplete personal data completed.
   3. Deletion
      If consent is withdrawn or certain conditions are satisfied in light of the purpose of use, stakeholders have the right to have their personal data deleted without undue delay.
   4. Cessation of Use
      Subject to certain conditions, stakeholders have the right to restrict the handling of their personal data.
   5. Objection
      Subject to certain conditions, stakeholders have the right to object to the handling of their personal data at any time for reasons related to their own specific circumstances.
   6. Data Portability
      Subject to conditions established by law, stakeholders may have the right to receive their personal data in a structured, generally machine-readable form, or to transfer their personal data to another controller without interference from Junkosha.
   7. Right to Non-Discrimination
      Junkosha will not deny goods or services, charge a different price, or provide a different level or quality of goods or services because of a request concerning the handling of personal information. However, if a stakeholder does not provide personal information, or requests deletion of personal information, Junkosha may be unable to provide the relevant service.
2. Overview of Requests for Disclosure

   For requests concerning personal information held by Junkosha, please contact the contact point listed under “14. Inquiries.”
   The following documents are required to verify your identity.

   Identifying Documents:
   Driver’s license, passport, health insurance card, or other document issued by a public agency that can be used to confirm identity (if no address is indicated on the identification document, attach a document issued by a public agency indicating the address)
   For requests made by an agent, the above documentation for the agent and a letter of attorney are required.

   Junkosha may refuse to comply with a request if the request is clearly groundless, excessive, or repeated.
   In such cases, Junkosha will promptly notify the individual concerned of the refusal and the reasons for it.

3. Filing Objections
   Stakeholders may file objections with supervisory authorities if they object to Junkosha’s handling of personal data or the methods by which Junkosha handles customers’ personal data.

Junkosha has formulated the Information Security Management Regulations and the Information Security Operation Standards separately from this Policy.
Junkosha also implements organizational security measures, including the development and maintenance of information security systems, and takes measures such as access control, identification, and other technological security measures.

Should Junkosha discover any unlawful destruction, loss, alteration, or leakage of personal information, it will issue the necessary notification to the relevant supervisory authorities in accordance with applicable laws and regulations and notify the affected stakeholders.

Junkosha does not engage in automated decision-making, including profiling, based on personal data provided by stakeholders.

Any inquiries concerning personal data of stakeholders should be submitted to the contact point below:

• [ Contact details ]

  Contact Point

  Junkosha Inc.
  Tokyo Business Center, attn.: Privacy

  Address

  23F Ochanomizu Sola City, 4-6 Kanda-Surugadai, Chiyoda-ku,
  Tokyo 101-0062 Japan

  Phone

  +81 3 3518 6520 (main switchboard)

  Email

  privacyadmin@junkosha.com

• [ EU Representative ]

  Name

  DaraRep Tim Bell

  Address

  77 Camden Street Lower, Dublin D02 XE80, Ireland

  Tel

  +353 (0)1 525 9822

  Website

  https://www.datarep.com