Handling of Personal Information

Public Announcement Pursuant to the Act on the Protection of Personal Information (Translation)

Note: This Handling of Personal Information is based on a Japanese law, and thus is applicable only to OM Digital Solutions Corporation (OMDS) in Japan.

Being profoundly aware of the importance of personal information in the network society and considering the appropriate handling and thorough protection thereof to be its social responsibility, the OMDS shall handle personal information, based on the OM Digital Solutions Coporation Personal Information Protection policy (Translation), as described hereinafter.
The OMDS hereby releases the following information pursuant to the Act on the Protection of Personal Information (hereinafter "the Act").

Date established: Jan. 1, 2021

1.Intended Purpose of Personal Information (Relevant to Article 18 Paragraph 1 and Article 24 Paragraph 1 of the Act)

The OMDS intends to use the personal information it acquires for the purposes set forth below:

(1)Personal Information of Customers

  • Shipment, arrangement and provision of information relating to products and services
  • Sale, repair and inspection of products; provision of post-sale services
  • Notification and operation of seminars, exhibitions, events, contests, campaigns and other functions hosted, co-hosted or sponsored by OMDS or in which an OMDS has a display or is giving a presentation
  • Planning, research, development and marketing of products
  • Access control and access history management of facilities managed by OMDS
  • Business negotiations, meetings and communication with customers
  • Responses to and records of various inquiries, requests for materials and other customer services
  • Investigation, preparation of records and filing of notices, reports and other documents with government offices pursuant to laws, ordinances and other regulations

(2)Personal Information of Business Partners

  • Business negotiations, meetings, communication and other interactions with business partners as well as provision of information thereto
  • Performance of business operations commissioned to OMDS by business partners
  • Access control and access history management of facilities managed by OMDS
  • History management of education provided by OMDS
  • Investigation, preparation of records and filing of notices, reports and other documents with government offices pursuant to laws, ordinances and other regulations

(3)Personal Information of Shareholders

  • Exercise of rights and performance of obligations under the Company Act
  • Operation and preparation of records of shareholders' general meetings
  • Provision of services to shareholders
  • Shareholder and share management pursuant to laws and ordinances, including preparation of data and other materials

(4)Personal Information of Job Applicants

  • Provision of information to job (including internship) applicants and execution of operations related to recruitment activities
  • Recruitment operation management

(5)Personal Information of Employees

OMDS intends to use the personal information of its directors and corporate auditors, employees, their families and relatives, former directors and auditors, former employees, and their families and relatives for the following purposes:

  • Business-related communication and procedures
  • Communication with corporate health insurance societies, corporate pension funds and labor unions as well as among OMDS
  • Investigation, preparation of records and filing of notices, reports and other documents with government offices pursuant to laws, ordinances and other regulations
  • Execution of personnel and labor management operations

2.Provision of Personal Information to Third Parties (Relevant to Article 23 Paragraphs 1, 2 and 3 of the Act)

The OMDS will not disclose the personal information provided by customers to third parties with the exception of the following cases:

  • The relevant customer has consented to the disclosure.
  • The information is disclosed to contractors or other parties to the extent necessary in order to achieve the intended purposes explicitly indicated to the relevant customer.
  • Disclosure is required pursuant to a law, ordinance or regulation.
  • Disclosure is urgently required for the protection of the life or body of a person, assets or other serious interests.

When contracting out an operation pertaining to personal information, OMDS shall enter into an agreement requiring the relevant contractor to manage personal information appropriately and shall supervise as well as provide guidance to the contractor.

3.Sharing of Personal Information (Relevant to Article 23 Paragraph 4 of the Act)

(1)Corporate Health Insurance Societies, Corporate Pension Funds and Labor Unions

Types of personal information shared
Information subject to sharing shall be personnel information on employees, retirees and their family members (e.g., employee number, name, sex, birth date, date the employee joined the relevant company, department, employment status, personnel treatment data necessary for labor-management consultations) in the possession of each party to information sharing as set forth hereinabove as well as other data necessary for the achievement of the intended purposes of information sharing.
Extent of information sharing
Information shall be shared among corporate health insurance societies, corporate pension funds and labor unions.
Intended purpose of information sharing
  • Appropriate management of employees, retirees and their families among the information-sharing parties
  • Various communication, notification and provision of information on events from the information-sharing parties to the relevant person
  • Use as basic data for labor-management consultations (negotiations) on the wages and other labor conditions of the relevant person
  • Smooth implementation of appropriate measures in cooperation with information-sharing parties in the event of disasters or emergencies relating to the OMDS or the relevant person
  • Performance of practical operations relating to welfare programs offered by the information-sharing parties
Entity responsible for information sharing
OM Digital Solutions Corporation

4.Matters Relating to Procedures on Responding to "Requests for Disclosure" and Service Desk for "Complaints" (Relevant to Paragraph 1 Item 4 and Paragraph 2 of Article 24 of the Act; Article 5 of the Order for Enforcement; Article 25 Paragraph 1, Article 26 Paragraph 1 and Article 27 Paragraphs 1 and 2 of the Act; Article 31 of the Act)

A customer may request, pursuant to the Act on the Protection of Personal Information, the disclosure, correction, deletion or other measures regarding the personal information provided thereby. Please see "Personal Information Inquiry" for matters concerning procedures for consenting to "requests for disclosure" and on the service desk for "complaints".

5.Other

OMDS may have separate policies on the handling of personal information related to their businesses, services or other undertakings. In cases where the intended purpose and other details on personal information were separately indicated though a notice to the relevant person or in the form of approval of the Terms of Use or another instrument by the relevant person, said separately indicated purpose and other details shall supersede the foregoing.

OMDS may make changes its Personal Information Protection (Privacy) Policy, matters to be announced to the public pursuant to the Act on the Protection of Personal Information, as well as the procedures for disclosure and other processes without prior notice in order to address changes in laws, ordinances and other regulations.