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Privacy Policy

1. Appropriate Protection of Personal Information

The Company shall handle the obtained Personal Information appropriately and securely by establishing the organizational structures for the protection and management of Personal Information. It shall also implement security measures to prevent unauthorized access to Personal Information from external parties, unauthorized use of Personal Information, loss, destruction, manipulation, and leakage etc. of Personal Information.

2. Purposes of Use of Personal Information

The Company shall use the obtained Personal Information (excluding Specific Personal Information, which refers to Individual Numbers and other information which contain such numbers) for the following purposes. Special Care‐Required Personal Information shall not be obtained without the consent of the Concerned Individual, excluding the cases prescribed by the laws and ordinances as exceptions to this provision. If purposes of the use of Personal Information are stated clearly and exclusively to the Concerned Individual at the time of its acquisition, Personal Information shall be used specifically for such purposes.

Information concerning the Employees and Executives of Business Partners	Announcement of the services provided by the Company, and related information; Request for questionnaires, surveys, etc. pertaining to the services provided by the Company, and related information; Receiving and handling applications for various seminars; Managing information concerning Business Partners; Business Communication and Performance of Contracts; Handling inquiries, etc.
Information concerning Job Applicants	Communicating and providing information on recruitment, selection, and other recruitment activities
Information concerning the Employees and Executives of the Company	Human Resources and employment management; Administration of Employment Insurance, Social Insurance, and Taxes; Management of Safety and Health; Provision of Welfare Services; Education, Training, and Staff Development; Procedures for Personnel Evaluation, Commendation, Disciplinary Actions, etc.; Procedures for Hiring, Cease of Employment, and Transfer; Management of Payroll, Bonus, Retirement Allowance, Corporate Pension, etc.; Proposing, information sharing, counselling, various procedures related to Labor Dispatchment; Business‐related communication and management of facilities and equipment; Management of Employee Housing and searches for employees’ accommodations; Emergency communication in disasters (including emergency drills); Planning, developing and improving business, as well as conducting research and analysis, and gathering statistics for these objectives; Announcing, proposing and conducting campaigns, events and projects; Handling inquiries, etc.

*Note: Regardless of whether the consent is obtained from the Concerned Individual, Specific Personal Information may only be used within the scope of purposes listed below, which are permitted under the “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures” (hereinafter shall be referred to as “My Number Act”).

• ・Administrative works related to notification etc. of Employment Insurance
• ・Administrative works related to notification etc. of Health Insurance and Pension Plans.
• ・Administrative works related to notification etc. of Category III Insured Persons in National Pension Plans
• ・Creation, submission, etc. of Withholding Records, and other administrative works related to Income Withholding
• ・Administrative works related to the creation of declaration forms, notification forms, and application forms for Workers’ Property Accumulation Savings and Workers’ Property Accumulation Pension Savings
• ・Administrative works related to the creation and submission of payment reports on salaries, fees, contract expenses and rewards
• ・Administrative works related to the creation and submission of payment reports on stocks or shares, etc.
• ・Administrative works related to the creation and submission of payment reports on Real Estate expenses and payment records of equivalent values (“considerations”) for Real Estate transfers
• ・Administrative works related to each of the above

3. Joint Use

The Company may jointly use the obtained Personal Information (excluding Specific Personal Information) in accordance with the following criteria. Provided, however, that the joint use shall not be conducted exceeding the scope necessary to fulfill its purposes.

Personal Information to be Jointly Used

Identity‐related Information such as Home Address, Name, Telephone Number, Age, Gender, Email Address and the contents of the obtained information and inquiries etc.

Scope of Joint Users

AEC’s Group Companies in Japan

Purposes of Joint Use

Purposes for the joint use of Personal Information shall be as specified in Article 2, “Purposes of Use of Personal Information” of this Policy.

Responsible Party in Administration

OUTSOURCING Inc.

4. Management of Personal Information

In compliance to the “Regulations on Personal Information Management”, the Company shall handle the obtained Personal Information properly and rigorously. Upon its use, the Company shall promptly delete and dispose of any Personal Information which is no longer necessary, in accordance with the prescribed procedures of the Company.

5. The Provision of Personal Information to Third Parties

The Company shall not provide obtained Personal Information (excluding Specific Personal Information) to third parties, excluding the company’s entrusted contractors, without consent of the Concerned Individual. However, this provision shall not apply to cases where there are justifiable reasons for such provision (e.g. when disclosure is required under the laws and ordinances).
*Regardless of whether consent is given by the Concerned Individual, Specific Personal Information shall not be provided to third parties, except in the case of outsourcing the handling of such information, or cases when the provision is required under Article 19 of the My Number Act and other laws and ordinances.

6. Administration of the Entrusted Contractors

In the event where the Company entrusts the obtained Personal Information pursuant to the outsourcing mentioned in the previous paragraph, the Company shall enter an agreement on protection of personal information with the entrustees, and exercise proper control and supervision to protect such information.

7. Disclosure, Correction etc., and Suspension of Use etc. of Personal Information

Request for disclosure, correction etc. (correction, addition or deletion) or Suspension of use etc. (suspension of use, deletion or suspension of third‐party provision) concerning the Retained Personal Data shall be made by the Concerned Individual by contacting the “Point of Contact”, provided at the end of this Policy. The Company shall promptly handle the request within the reasonable scope, upon verification of the identity of the Concerned Individual.
Provided, however, that this provision shall not apply if acceptance of such request may infringe on the rights of third parties, impede the proper operation of the Company’s business, or violate the laws and ordinances.

8. Compliance with Laws, Ordinances and Regulations

The Company shall comply with the relevant laws and ordinances related to Personal Information as well as other regulations.

9. Continuous Improvement of the Personal Information Protection System

With the aim to properly maintain protection of Personal Information, the Company shall strive for continuous improvement of its supporting frameworks by setting, operating and regularly monitoring the content of the regulations etc. based on this Policy.

10. Point of Contact

For any inquiries concerning Personal Information, please contact the following:

【Point of Contact】
Method of Contact and Contact Information

E‐mail:	Generalaffairs@aec-japan.co.jp (General Affairs Department)
Telephone:	Operating Hours = 8:00‐12:00, 13:00‐17:00 (Business days of the Company) ・For Business Partners: 098‐897‐6781 (Main) ・For Retired Executives and Employees: 098‐897‐6781 (Main) ・For Job Applicants: 098‐897‐6783 (Direct)
Postal Mail:	American Engineering Corporation General Affairs Department 7-11-47 Oyama, Ginowan-shi, Okinawa, JAPAN, 901‐2223

Please note that revisions may be made to this Policy without prior notice. If revisions are made, the revised version will be notified via the Company website.

Last revised on September 1, 2020