MKAM Co., Ltd. (hereinafter the "Company") hereby establishes the following Privacy Policy as an organizational response to ensure the appropriate handling of personal data, based on the Act on the Protection of Personal Information (hereinafter the “Privacy Act”).
The meaning of terms used in this Privacy Policy shall be in accordance with the Privacy Act.

1. Compliance with Laws and Ordinances Related to the Protection of Personal Information

The Company shall handle personal data appropriately, in strict compliance with the Privacy Act, other related laws and ordinances, the guidelines of the Personal Information Protection Commission, and other guidelines.

2. Acquisition and Use of Personal Information

When acquiring personal information, the Company shall publicly announce or notify the purpose for which the personal information will be used. When acquiring personal information described in contracts or other documents (including electromagnetic records) obtained directly from the individual, the Company shall specify the purpose of use in advance and acquire the personal information by legitimate and fair means. The Company recognizes the importance of protecting personal information, and shall use the personal information appropriately.

3. Purposes of Use of Personal Information

The Company shall use personal information for the following purposes.

1. Personal information about customers:

• 【Purposes of use】
• To respond to, confirm, and record customer inquiries, consultation, and complaints received through e-mail address on the Company’s website

1. Personal information about business partners (in the case of corporate customers, the officers and employees of those companies):

• 【Purposes of use】
• To send invoices and greeting messages, communicate necessary information related to business operations, execute contracts, and hold business discussions and the like
• To manage business partners’ information
• To respond to inquiries

1. Personal information about applicants for employment/recruitment:

• 【Purposes of use】
• To contact, and provide information to, applicants for employment/recruitment, to consider for employment of the applicants, and to use as reference material for recruitment activities in the following year and beyond

1. Personal information about employees:

• 【Purposes of use】
• To communicate work-related information to employees
• To pay employees’ remuneration (including wages, bonuses, and various allowances), conduct personnel and labor management, and provide employee benefits
• To carry out employee health management

4. Joint Use of Personal Information

When entrusting the handling of personal information to third parties under a service agreement, or when using personal information jointly with third parties, the Company shall take appropriate measures, such as obligating the contractor or joint user to strictly manage the personal data.

5. Provision of Personal Information to Third Parties

The Company shall not provide personal information to any third parties except in the following cases.

• The agreement has been obtained in advance.
• The personal information is entrusted to outside parties within the necessary scope to achieve the purposes of use.
• The Company is required by law to provide the information.
• The disclosure is necessary to protect human life, body or property, and it is difficult to obtain the agreement.
• The disclosure is particularly needed for the improvement of public health/hygiene or to promote sound development of children, and it is difficult to obtain the agreement.
• The disclosure is necessary to cooperate with the national or local government or the like in the implementation of tasks prescribed by law, and obtaining the agreement might impede the execution of the said tasks.
• Any other cases permitted by laws and regulations.

6. Measures for Safety Management

The Company shall appropriately implement safety management measures as needed in order to manage personal data, such as measures for preventing leakage of, loss of, or damage to the personal data. In addition, the Company shall appropriately supervise employees and contractors (including subcontractors) who handle the personal data as needed. The main measures shall be as follows.

1. Formulation of Basic Policy

• The Company shall formulate this Privacy Policy as our basic policy regarding "compliance with related laws, regulations, guidelines, etc." and "point of contact for questions and complaint handling” in order to ensure the proper handling of personal data.

1. Establishment of Rules for Handling Personal Data

• The Company shall establish rules for handling personal data, including handling methods, responsible persons and persons in charge and their duties, for each stage of acquisition, use, storage, provision, deletion, disposal, etc.

1. Organizational safety management measures:

• The Company shall appoint a clerical supervisor responsible for the handling of personal data; clarify the employees who handle the personal data and the scope of the personal data handled by the said employees; and prepare a system for reporting to the clerical supervisor in the case where the fact that there has been a violation of the Privacy Act or Rules on Personal Information Protection is confirmed or such violation is suspected.

1. Personnel-related safety management measures:

• The Company shall provide training on a regular basis to employees on points to consider when handling personal data.
• The Company’s employment regulations include a clause regarding confidentiality of personal data.

1. Physical safety management measures:

• In areas where personal information is handled, the Company shall control entry and exit of employees and implement measures to prevent unauthorized persons from viewing personal data.
• The Company shall implement measures to prevent the theft, loss, etc. of equipment, electronic media, documents, and other such devices used to handle personal data.

1. Technological safety management measures:

• The Company shall implement access controls and limit the scope of persons in charge, the personal information database to be handled, and other such matters.
• The Company shall introduce mechanisms to protect the information systems used to handle personal data from unauthorized external access or improper software.

7. Requests for Disclosure of Personal Information and Other Similar Requests

When the Company receives a request for the disclosure, correction, suspension of use, deletion, etc. of personal information, the Company shall respond promptly to such request, after first confirming the identity of the individual by a prescribed procedure. If you have questions regarding this Privacy Policy or wish to exercise your right to request the disclosure, etc. of your personal information, please contact the Administrative Division described in the numbered item 9 below.

8. Continual Improvements

The Company shall establish, operate, and maintain a management system for the protection of personal information, and regularly review the system to make continual improvements.

9. Consultation Desk

The contact point for requesting disclosure of the personal information held by the Company, or for inquiries, complaints, etc. concerning the Company’s handling of personal information shall be as follows:

Contact:	MKAM Co., Ltd.
Address:	Chiyoda First Building Minamikan, 2-1, Nishi-Kanda 3-chome, Chiyoda-ku, Tokyo
E-mail:	contact_mkamTKJFR@dg.mitsui.com

10. Company Name, Address, and Representative

Name:	MKAM Co., Ltd.
Address:	2-1, Nishi-Kanda 3-chome, Chiyoda-ku, Tokyo
Representative:	Takashi Nakai, Representative Director and President