As a company engaged in IT-related business, we recognize that handling various types of “information” in our operations and strictly managing the security of that “information” is an important social responsibility. In particular, we strongly recognize the importance of personal information and position privacy protection as one of the top priorities in our corporate activities. To make sure we carry this out, we have established the following Basic Policy on Personal Information Protection , and all officers and employees will comply with this policy and strive to properly handle and manage personal information.

Definition of Personal Information

Personal information refers to data related to individuals, such as customers, business partners, employees, and their dependents, that can identify a specific individual by name, age, gender, address, telephone number, email address, or other descriptors. This includes information that can be easily collated with other information and thereby identify a specific individual or personal identification codes (as defined in Article 2, Paragraph 2 of the Act on the Protection of Personal Information).

Collection and Purpose of Use of Personal Information

When acquiring personal information, we will notify or publicly announce the purpose of use, except as stipulated by law, and acquire it by legal and fair means.
Personal information entrusted to us by customers will be used to provide and propose our products and services, provide information about our products and services, and collect information to improve our products and services. Additionally, we will also use it for purposes separately stated in writing, etc., in advance, when personal information is provided.
Personal information entrusted to us by business partners will be used for necessary business communications, contract fulfillment, billing, and related business execution. In addition to these, we will also use it for purposes separately stated in writing, etc., in advance, when personal information is provided.
Personal information entrusted to us by employees and their dependents will be used for tax and social insurance administration purposes. In addition to these, we will also use it for purposes separately stated in writing, etc., in advance, when personal information is provided.
Personal information regarding job applicants will be used for recruitment screening.
We will not handle personal information beyond the above scope (use for purposes other than those specified) and will take measures to prevent use for purposes other than those specified.

Non-Disclosure of Personal Information to Third Parties

Personal information provided by customers, business partners, employees, and their dependents will not be disclosed or provided to third parties except in the following cases:

• When we have obtained consent from the customer, business partner, employee, or their dependents.
• When third-party provision is permitted under the Act on the Protection of Personal Information or other laws and regulations, in addition to the matters specified below:
  ·When we entrust all or part of the handling of personal information to a third party within the scope necessary to achieve the purpose of use.
  ·When it is necessary to protect human life, body, or property, and it is difficult to obtain customer consent.
  ·When it is necessary for a national institution or local public entity, or a person entrusted by them, to cooperate in carrying out affairs prescribed by laws and regulations, and there is a risk of hindering the execution of said affairs by obtaining customer consent.
  ·When disclosure of personal information is requested by a court, public prosecutor’s office, police, or an organization with equivalent authority.
• When disclosing statistical data, etc., in a state where individuals such as customers cannot be identified.

Safety Management of Personal Information

In order to safely manage and operate personal information of customers, business partners, employees, and their dependents, each employee will understand this Basic Policy on Personal Information Protection and strive to improve their information management ethics daily. In addition, we will implement security measures against unauthorized external access to personal information, destruction, falsification, leakage, etc. of personal information, and daily endeavors to constantly pursue improvements in line with technological advances.

Review of this Basic Policy on Personal Information Protection

This Basic Policy on Personal Information Protection and the Personal Information Protection Management System will be reviewed and improved as appropriate.
After changes, they will be posted on our website or through other appropriate methods.

Inquiries about Personal Information

For complaints and inquiries regarding this Basic Policy on Personal Information Protection or personal information of customers, business partners, employees, and their dependents, and requests for disclosure of personal information of customers, business partners, employees, and their dependents held by us, and disclosure, correction, partial addition or deletion, and deletion of all the records provided to third parties, please contact us via the inquiry form.
Regarding the above requests, we will respond within a reasonable period and scope in accordance with relevant laws and regulations after confirming the identification of the requesting person (we will confirm it using official documents from public institutions, such as driver’s licenses and passports, if necessary).

[Contact for Inquiries Regarding Personal Information]
Personal Information Protection Manager
Email：info@tobila.com

[Name of Authorized Personal Information Protection Organization and Contact for Complaint Resolution]
*Only complaints regarding the handling of personal information are accepted.

Japan Information Processing Development Corporation (JIPDEC)
Accredited personal information protection organization secretariat
Roppongi First Building

9-9 Roppongi 1-chome, Minato-ku, Tokyo 106-0032
+81-3-5860-7565