LOGISTEED, Ltd.
Representative Director, President and Chief Operating Officer: Hiroaki Takagi
Date of enactment: February10, 2005
Date of revision: April1, 2022

LOGISTEED, Ltd. (hereinafter, "LOGISTEED") handles a variety of information including in-house technical information as well as information obtained from our customers as a global solution provider offering seamless services to entire global supply chain. Accordingly, LOGISTEED has strived to establish and implement an information management system that respects the value of such information.
In light of this background, LOGISTEED has prescribed rules and established a management system regarding personal information protection; prescribed the personal information protection policy laid out below and informed directors and employees, while taking measures to grant general public an easy access to the information. Moreover, LOGISTEED strives to protect personal information appropriately according to this policy.

(1) Formulation of Personal Information Protection Management Rules and Continuous Improvement of Personal Information Protection Management System

LOGISTEED shall formulate and implement personal information protection management rules in order to raise awareness for the importance of personal information among directors and employees, and to appropriately use and protect personal information. LOGISTEED shall maintain and continue to improve these rules.

(2) Collection, Usage, and Provision of Personal Information and Prohibition of Use beyond Original Purpose

In consideration of the fact that LOGISTEED is entrusted with the customer's information in its business activities, LOGISTEED shall establish a management system for personal information protection specific to each operation, and appropriately handle the collection, usage and provision of personal information according to the established rules. LOGISTEED shall not use personal information for other than the purpose of such information, and shall take measures to prevent such misuse.

(3) Implementation and Corrective Actions of Safety Measures

In order to secure the accuracy and safety of personal information, LOGISTEED shall implement measures such as managing access to personal information, restricting the means for external use of personal information, and preventing unauthorized external access in compliance with the rules for information security, and thereby prevent the leakage, loss, alteration, or destruction of personal information. In case some security issues are identified, LOGISTEED shall immediately take actions to correct them.

(4) Compliance with Laws and Codes

LOGISTEED shall comply with the Japanese laws and codes applicable to the protection of relevant personal information. Moreover, LOGISTEED shall adapt its personal information management rules to comply with these laws and codes.

(5) Respect for the Rights of the Individual Concerning Personal Information

When the individual requests for his or her personal information to be disclosed, corrected, deleted, or seeks to prevent the use or provision of such information, complained or consulted, LOGISTEED shall respond in good faith respecting the rights of the individual pertaining to the personal information.

【Personal Information Protection Administrator】
LOGISTEED, Ltd.
General Manager, Information Security Office

【The office for inquiries concerning Personal Information Protection Policy】
LOGISTEED, Ltd.
Manager, Information Security Office
Telephone: 03-6263-2822
Business Hours: 9:00 - 17:30 (except Saturdays, Sundays and holidays)

1. Definition of Personal Information

Under our Personal Information Protection Policy, LOGISTEED, Ltd. (hereinafter "LOGISTEED") protects and manages personal information with the utmost care and to the best of our ability.
LOGISTEED defines personal information as information about an individual that can identify a specific individual on the basis of a name, date of birth or other description included in the information, or through a number, symbol or other code, image or sound associated with an individual (including that information which on its own cannot identify an individual but can be easily matched with other information to identify a specific individual). Furthermore, personal information includes not only information that can identify an individual but also any and all information that expresses a fact, judgment or assessment concerning the attributes of an individual including an individual's physical characteristics, property, occupation or status.

2. Scope of Application

This document, "About Personal Information Protection," prescribes LOGISTEED's handling of all personal information concerning you, our customers and our suppliers through our business.

3. Purpose of Use of Personal Information

We will use the personal information we obtain from you, customers and suppliers only to the extent necessary to achieve the purpose stated in each item of the following table. When we acquire personal information, we will publicly announce or notify you of the purpose of use unless the purpose of use has already been announced. When any of the following applies, however, we will not publicly announce or notify you of the purpose of use:

1. When there is a risk publicly announcing or notifying you of the purpose of use will harm the life, person, property or other rights and interests of you or a third party,
2. When there is a risk publicly announcing or notifying you of the purpose of use will harm the rights or legitimate interests of an organization concerned,
3. When it is necessary to cooperate with a government agency or a local public body in the execution of affairs prescribed by laws and regulations, and there is a risk publicly announcing or notifying you of the purpose of use will impede the execution of affairs, or
4. When the purpose of use is deemed to be clear from the circumstances of acquisition

Note that when we have you, a customer or supplier provide personal information directly, we will clearly specify, as necessary, matters required for its acquisition including the purpose of use, and will obtain your consent, the consent of the customer or the consent of the supplier accordingly.

NO	Classification	Purpose of Use
1	Logistics business	The execution of contracts concluded with you, a customer or supplier including the execution of outsourced business relating to transportation and delivery, cargo handling, storage, packing, distribution processing, relocation and removal, import/export, rental storage and other logistics services, and provision of business services incidental to these including coordination, reporting and inquiries concerning these
2	Sales business	Business negotiations, meetings and proposals with you, customers and suppliers, and coordination of these Forwarding information about holding events and providing new services for you, customers and suppliers For survey and research analyses of you, customers and suppliers and improvement of services for you, customers and suppliers For providing after-sales services for you, customers and suppliers
3	Supplier information	Concluding worker dispatch contracts, managing dispatched workers at dispatch sources and dispatch destinations, and the education of dispatched workers Business communication with employees of outsourcees as well as work management, safety management and education of these employees Responding to requests for disclosure, provision, submission, etc. from customers and prime contractors, etc. within the scope of business execution under a contract
4	Information of employees and their families	Employment management such as personnel & labor management, salary management, human resource development, welfare, social insurance procedures Employee health management, safety management, work man-hour management, quality control, employee education, advertising & promotion business, information sharing and communication revitalization within the LOGISTEED Group, other management required for the handling of personal information in business operations and various measures incidental to these
5	Recruitment business	Managing work experience under internships, etc. Entry management of applicants through company briefing sessions and recruitment media, etc. Personnel recruitment management including interview guidance for job applicants, recruitment selection, business communication concerning recruitment, and various procedures prior to employment Agency business for recruitment-related services under an outsourcing contract within the LOGISTEED Group
6	Retiree information	Forwarding various post-retirement communications concerning employment management including company pensions and social insurance Management and operation of OB meetings, etc. within the LOGISTEED Group Management of records such as work, salary and health management during employment Responding to various inquiries including social insurance-related procedures
7	Investor information	Administrative work related to shares
8	Security (surveillance) camera video information	Crime prevention management Safety management
9	Image, audio information acquired with a drive recorder	Avoiding problems such as violations and lawsuits through clarification of the cause of mishaps Analysis of the cause of mishaps, drafting measures to prevent their recurrence, and education and guidance For individual guidance on the safety driving operations using image and sound information
10	Information acquired through system services, etc.	Sale, provision, operation of system services developed by the LOGISTEED Group Improvement of services through the above system analysis, enhancement, etc. Research and development of new solution systems, etc.
11	Matters other than the above	Responding to various inquiries to LOGISTEED and other responses

4. Provision and outsourcing of personal information to third parties

1. Except in the following cases, LOGISTEED will not provide your personal information to any third party without obtaining your prior consent:
   1. When required by laws or regulations,
   2. When provision is necessary to protect the life, person or property of an individual or individuals and obtaining your consent is difficult,
   3. When provision is particularly necessary for improving public health or promoting the sound development of children and obtaining your consent is difficult,
   4. When there is a need to cooperate with a government agency, local public body, or an individual or entity entrusted by such government agency or body in the execution of affairs prescribed by law and there is a risk that obtaining your consent may impede the execution of those affairs,
   5. When the handling of personal information is outsourced to a third party within the scope necessary for achieving the purpose of acquisition and use,
   6. When provision of personal information is due to the succession of business owing to a merger or other reason, or
   7. When it is information concerning the officers and shareholders of a corporation or other organization included in the information of the corporation or other organization concerned, and the provision of information has been publicly disclosed or announced by the corporation or other organization concerned in accordance with laws and regulations.
2. LOGISTEED may outsource the handling of personal information within the scope necessary for the purpose of use of the personal information. LOGISTEED will establish company standards concerning the selection of outsourcees and conduct the screening of these. Likewise, LOGISTEED will undertake appropriate supervision and management of outsourcees.
   Furthermore, LOGISTEED will use personal information entrusted by customers within the scope of business prescribed in outsourcing contracts and will clarify in contracts the handling of personal information at the time of termination of an outsourcing contract.

5. Joint Handling of Personal Information

LOGISTEED may jointly use personal information (excluding information including Social Security and Tax Number) only within the scope necessary for achieving the purpose of use.

1. Joint use within the LOGISTEED Group

NO	Classification	Details
1	Purpose of Joint Use	Purpose of use relating to logistics and sales Mutual support in logistics business, the joint promotion of business strategy planning, sales proposals, and business operations, etc., the sharing of customer information, etc. necessary for business operations, the development, operation and management of system services Purpose of use relating to supplier information Management of dispatched workers and outsourcees, etc. by LOGISTEED Group systems, joint promotion of education and guidance, etc. for suppliers, agent business for supplier management services Purpose of use concerning employee (including retiree) and family information, etc. Succession of personnel and labor management business including seconded employees, etc., agent business for employment management services (including shared services), development, operation and use of the integrated LOGISTEED Group system, human resource development and promotional activities as a group strategy, strengthening of group governance, sharing of company information to strengthen the organizational capabilities of the LOGISTEED Group, promotion of other measures necessary for the advancement, etc. of efficiency and strategic issues by group management Purpose of use relating to recruitment business Joint promotion within the LOGISTEED Group of referral, placement and recruitment activities for LOGISTEED Group companies based on employee applicants' wishes, agent for employment-related services (including shared services)
2	Scope of joint users	LOGISTEED Group companies and health insurance associations LOGISTEED Group companies belong to.  Joint users will be limited to the minimum number of users necessary for the execution of business within the scope of the purpose of joint use in 1 above.
3	Items for joint use	Personal information necessary for achieving the purpose of joint use in 1 above Customer information (company name, address, person in charge, job title, phone number, etc.), delivery destination information (name, address, phone number, etc.) Subcontractor employee information (names, ages, qualification licenses, telephone numbers, etc.) Employee (including retiree) and family information of LOGISTEED Group companies (name, department, job title, address, employee number, system registration ID, email address, career information, image/video information, audio information, family information, etc.) Employee applicant information (entry information such as name, address, school name, contact information, etc.) Note that the LOGISTEED Group does not jointly use Social Security and Tax Number with third parties unless its joint use is permitted by law.
4	Joint use information manager	General Manager, Information Security Office, LOGISTEED, Ltd.
5	Contact for inquiries concerning joint use	Information Security Office, LOGISTEED, Ltd. Telephone: 03-6263-2822 Business Hours: 9:00 - 17:30 (except Saturdays, Sundays and holidays)

2. Joint use with partners outside the LOGISTEED Group

NO	Classification	Details
1	Purpose of Joint Use	Under the Smart & Safety Connected Vehicle (SSCV) system provided by LOGISTEED Group, personal information may be used jointly with a partner only when the LOGISTEED Group uses an external system, etc. owned by a non-group partner to build systems and provide services.
2	Scope of joint users	Mobility Technologies Co., Ltd., a non-LOGISTEED Group company partner established under an agreement for the joint development and operation of SSCV. (Note 1) (Note 1) Split and merged businesses such as DeNA Co., Ltd.'s "DRIVE CHART" into JapanTaxi Co., Ltd. and changed its trade name on April 1, 2020.
3	Items for joint use	Personal information necessary for solution systems development, operation and provision of services (video/audio information, etc.)
4	Joint use information manager	General Manager, Information Security Office LOGISTEED, Ltd.
5	Contact for inquiries concerning joint use	General Manager, Information Security, LOGISTEED, Ltd. Tel: 03-6263-2822 Business Hours: 9:00 - 17:30 (except Saturdays, Sundays and holidays)

6. Handling of Specific Personal Information

1. In the handling of Specific Personal Information, the LOGISTEED complies with the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (hereinafter referred to as the "Act on the Use of Numbers"), the Act on the Protection of Personal Information, and the Guidelines for proper handling of Specific Personal Information (for private entities).
2. In addition to a Personal Information Protection Policy, the LOGISTEED has established a Basic Policy for the Proper Handling of Specific Personal Information to ensure the proper handling of Specific Personal Information.
3. LOGISTEED shall acquire and use Specific Personal Information to the extent necessary to achieve its purposes within the scope of use of Specific Personal Information in regard to the execution of administrative procedures concerning social security, tax and disaster measures prescribed in each item of Article 9 of the Act on the Use of Numbers.
   The main scope of use of Specific Personal Information handled by LOGISTEED shall be as follows:
   1. To complete necessary documents such as various legal records including tax withholding slips for salary income/retirement income, salary payment reports, employment insurance notifications, notice of qualification of health insurance/welfare annuity insurance of the insured with Specific Personal Information provided to LOGISTEED by employees, etc., to submit to the tax office chief, municipal mayor or Japan Pension Service, etc.
   2. To complete various payment records such as records of payment of compensation and fees, records of payments of dividends, distribution of surplus and interest on guaranty capital, records of payment of real estate usage fees, etc., and records of payment of consideration for the transfer of real estate, etc. with Specific Personal Information provided to LOGISTEED by employees, etc. to submit to the tax office chief
   3. To execute business for handling Specific Personal Information entrusted to LOGISTEED by an administrative agency or other business operator
4. LOGISTEED will not provide your Specific Personal Information to any third party unless prescribed by laws and regulations, etc. Furthermore, LOGISTEED will not engage in the joint use of such information. However, whenever any of the following items prescribed in Article 19 of the Act on the Use of Numbers (Restrictions on the Provision of Specific Personal Information ) applies, LOGISTEED may provide Specific Personal Information.
5. LOGISTEED may outsource the handling of Specific Personal Information within the scope of the purpose of the use prescribed in laws and regulations, etc.
6. If you request disclosure, correction, addition, deletion, suspension of use, suspension of provision to third parties, or notification of the purpose of use of Specific Personal Information held by LOGISTEED, or if you wish to file a complaint, the procedures shall be as stated in LOGISTEED's "Request for Disclosure of Retained Personal Data, Complaints, Requests for Consultation."

7. Use of cookies and web beacons

We use cookies and web beacons (clear GIFs) in some parts of our website to offer you a more convenient website experience.
You can refuse to accept cookies or have a warning message displayed when you accept cookies by adjusting your web browser settings. For further details, please refer to your web browser instructions. You may also refuse to accept web beacons by refusing to accept cookies.
However, please understand that all or part of the services that we provide on our website may not be available to you if you refuse to accept cookies.

Explanation of terminology

(1) Cookies

"Cookies" refers to information that is mutually exchanged between a web server that controls a website and your web browser. Cookies are sometimes stored as files on your computer disk. The use of cookies enables a web server to record information such as which pages of the website a certain computer has visited. Unless you enter your personal information on the website, however, it is not possible to identify who you are.

(2) Web beacons

"Web beacons" refers to a technology that operates in tandem with cookies and enables a web server to know how many times you accessed certain pages of a website. Unless you enter your personal information when accepting cookies, however, it is not possible to identify who you are.

8. Treatment of complementary rules concerning the handling of personal data transferred from areas within the EU with an adequate level of protection

1. Please check the following details regarding the handling of personal data when we transfer those personal data acquired in Japan if you, our customers or our suppliers reside in any EEA member state, namely European Union (EU), Iceland, Liechtenstein and Norway.
2. The European Commission has certified the adequate level of data protection in Japan. LOGISTEED complies with complementary rules regarding the handling of personal data and manages transferred data appropriately.
3. Individuals (you, customers and suppliers) may make a request to LOGISTEED to access their own personal data and to correct or delete incorrect data. For further information, please make an inquiry at the office for inquiries below.

9. Request for disclosure of retained personal data, complaints, requests for consultation

LOGISTEED has established the following procedures for requesting disclosure, correction, addition, deletion, suspension of use, suspension of provision to third parties, or notification of the purpose of use (hereinafter, "disclosure, etc.") in regard to personal information you provided to LOGISTEED, or for filing a complaint or requesting consultation.

1. To request the disclosure of personal information you have provided to LOGISTEED, see Requests Regarding Disclosure of Information.
2. To file a complaint or request consultation concerning our handling of personal information, please contact the office for inquiries below.

10. Please note the following

1. You may use almost all of the services LOGISTEED offers without providing your personal information. Please understand, however, that there are also some services which are not available unless you provide your personal information.
2. Please note that LOGISTEED cannot be responsible for ensuring the safety of your personal information on a non-LOGISTEED website accessed from links on our website.
3. When entering personal information on the LOGISTEED website, you must agree to the purpose of use and other terms specified on the website. Whether you agree or not is up to you but unless you give your consent, you may not be able to access services we offer (including responding to your inquiries). Please also note that persons of 15 years old or younger may enter personal information only with the consent of a parent or guardian.

11. Special Notes

1. Personal information protection policy of LOGISTEED shall be governed by the laws of Japan.
2. LOGISTEED may revise this document, "Privacy Policy (About Personal Information Protection)" to improve the handling of personal information, and/or in accordance with the revision of laws or ordinances, or other rules and regulations.
3. The implementation of this document, "Privacy Policy (About Personal Information Protection)" shall be on or after the issued date (including update date).
4. If individual LOGISTEED website pages list their own personal information policy, or when they are linked to such policy, the provisions in this "Privacy Policy (About Personal Information Protection)" shall supersede such policies.
5. When you contact us by telephone, conversations may be recorded to ensure accurate response.

12. Inquiries

Please address requests and complaints concerning the disclosure, etc. of personal data and Specific Personal Information held by LOGISTEED and other inquiries concerning LOGISTEED's protection of personal information to the office for inquiries below.

c/o Personal Information Protection Inquiry Office
LOGISTEED, Ltd.
LOGISTEED Bldg., 2-9-2, Kyobashi, Chuo-ku, Tokyo 104-8350, Japan
Telephone: 0120-060-850
Business Hours: 9:00 - 17:30 (except Saturdays, Sundays and holidays)

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13. Privacy Mark

14. Certified Personal Information Protection Organization

The certified personal information protection organization (^*) managing LOGISTEED is as follows:

Name of organization:	Japan Institute for Promotion of Digital Economy and Community Privacy Mark Promotion Center Inquiry for Personal Information Protection
Location	Roppongi First Building, 9-9 Roppongi 1-chome,Minato-ku Tokyo, 106-0032 Japan
Phone	+81-3-5860-7565, 0120-700-779

(^*)The third party organization designated by Personal Information Protection Law, that handles claims or provide information regarding personal information.
(^*)This agency is not the point of contact for inquiries about our products and services.

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