Personal Information Protection Policy/Publication of Personal Information, etc. Nippon Micrometal Corporation Personal Information Protection Policy

April 27, 2023

Recognizing the importance of protecting personal information, Nippon Micrometal Corporation (hereafter “our company”) has adopted a privacy policy as described below with regard to any and all personal information collected and used in the course of business (hereafter “personal information”).

1.Compliance with Laws and Regulation, Conformity with Government Guidelines and Establishment of Company Rules

(1) We will comply with the” Act on the Protection of Personal Information” and related laws and regulations. We will also make every effort to conduct our business in accordance with the guidelines established by the governmental authorities of Japan.
(2) We have established corporate rules for handling Personal Information and strive to protect personal information appropriately.
(3) We will ensure that all employees are familiar with the contents of the above laws, regulations, guidelines, and corporate rules mentioned above. In addition, we will endeavor to review and amend this privacy policy and corporate rules on an ongoing basis.

2.Basic Policy on Collection and Use of Personal Information

(1) When we collect personal information, we will specify as clearly as possible the purpose for which the information will be used. When obtaining personal information directly from the person, we will inform the person of the purpose for which the information will be used or disclose it publicly. If we receive a request for personal information after we have collected it, we will disclose the purpose of use in a reasonable manner (except when exempted by laws and regulations).
(2) We will use personal information only for the purposes described above. We will not change the purpose of use or disclose personal information to third parties without the individual's prior consent. In addition, we will take appropriate measures when an individual requests notification of the purpose of use, disclosure, correction, addition, deletion of content, disclosure of records of provision to third parties, suspension of use, deletion, or suspension of provision to third parties of personal information in our possession (hereafter “request for disclosure, etc.”) (except when exempted by laws and regulations).
(3) We will make efforts to keep personal information as accurate and updated as possible and will take measures to protect the personal information from unauthorized access, loss, destruction, alteration, disclosure, or other accidents.
(4) If we outsource the handling of personal information, we will take appropriate measures, such as contractually defining the management responsibilities of the outsourced company.

Publication Matters Based on the "Act on the Protection of Personal Information"

Pursuant to the "Act on the Protection of Personal Information" (hereafter "Act"), our company discloses the following information.

Name Address Representative's Name
Nippon Micrometal Corporation 158-1, Sayamagahara, ruma-City,
Saitama 358-0032,Japan
President

2.Purpose of use of personal information (Article 17.1 and Article 32.1.2 of the Act)

The purposes for which personal information is collected and maintained by our company are set out below. In cases where the purpose of use of personal information is individually disclosed or publicly announced, the information shall be collected and maintained for that purpose.

Types of Personal Information Purpose of Use
Personal information concerning customers and other business partners
To carry out transactions with companies and government agencies with which our company has business relationships, such as the sale of products and the purchase of raw materials, and equipment.
To make business contacts related to the above
Directories of companies, government agencies, organizations, etc.
(including commercially available directories)
To contact the person on the list
To investigate and confirm the status of organizations, officers and employees of companies, government agencies, organizations, etc., that have a relationship with our company
Personal information related to public relations activities
To send PR magazines, calendars, mail magazines, etc.
To respond to inquiries to our company
Personal information related to recruitment activities
For recruiting applicants
Personal information regarding the use of computer systems
To issue, revise, or abolish IDs for the use of our company's systems and services provided by our group through our systems (hereafter "services").
To contact and notify users of our services
To manage service usage (including security management)
Uses associated with the above

3.Matters regarding the disclosure of personal information to third parties (Article 27 of the Act)

(1)Disclosure to third parties

In principle, our company will not provide personal information to third parties without the consent of the individual, except in the following cases.

Where an opt-out procedure for third party provision has been completed (Article 27.2 of the Act)
In case of outsourcing, business succession or shared use (Article 27.5 of the Act)
In other cases where the consent of the individual is not required by the Act ( Article 27.1 of the Act).
(2)Shared Use (Article 27.5.3 of the Act)

When sharing personal information held by our company, in addition to providing the individual with the necessary information or making it readily accessible to him or her, the following will be done.

Items of Personal Information to be Shared Items of personal information held by our company regarding business contacts, such as company name, affiliation/position, name, work address, telephone number, e-mail address, etc.
Scope of co-users NIPPON STEEL Group companies
Group companies in Japan of NIPPON STEEL Corporation
Group companies in Japan of NIPPON STEEL Chemical & Materials Co,. Ltd.
Purpose of use by shared users To provide appropriate services in the NIPPON STEEL Group companies
Person and the address responsible for the management of personal information General Manager, Administration Department, Nippon Micrometal Corporation

158-1, Sayamagahara, Iruma-City,Saitama 358-0032, Japan
Representative of the business operator handling personal information President
https://www.nmc-net.co.jp/en/company/summary/

4.Procedures for responding to "Requests for Disclosure, etc." *3 of held personal information (Article 32.1, Items 3 and 4, Article 37 and Article 40 of the Act)

*3 For the meaning of "Request for Disclosure, etc.", please refer to the above-mentioned Personal Information Protection Policy 2 (2).

(1)Contact for "Request for Disclosure, etc.”

“Requests for Disclosure, etc." should be directed to the department to which the individual provided the personal information. If you are not sure whom to contact, please send your inquiry to the contact information listed at the end of this document.

(2) How to make a "Request for Disclosure, etc." of held personal information

Unless otherwise specified individually, a prescribed application form will be mailed, faxed, or e-mailed to the individual, depending on the content of the application. Please complete the application form and return it to us with one of the following forms of identification (a copy of your driver's license, passport, or health insurance card).
In the case of an application by a representative, in addition to the above, a document verifying the identity of the representative must be attached.

(3)Complaints

Complaints or other comments regarding personal information held by our company should be directed to the relevant department of the company to which you provided your personal information. If you are not sure whom to contact, please send your comments to the contact information below.

【Contact】

ADDRESS: 158-1, Sayamagahara, Iruma-City,Saitama 358-0032,Japan
Administration Department, Nippon Micrometal Corporation
TEL: +81-4-2934-6101
FAX: +81-4-2934-5454
Contact: https://www.nmc-net.co.jp/en/contact/

5.Measures Taken to Ensure the Security Management of Retained Personal Information

Our company takes the following measures to ensure the security of personal information.

(1) In accordance with the "Guidelines Concerning the Act on the Protection of Personal Information," we have established the “Nippon Micrometal Corporation Personal Information Protection Policy”.
(2) In order to manage the security of personal information, such as preventing the leakage of personal information, we have established the "Basic Rules for Information Management," the "Rules for Management of Personal Information and Specified Personal Information," and the "Rules for Handling Personal Information of Officers and Employees," and we handle personal information in accordance with these rules.
(3) We have established an organizational structure for security control measures, including the appointment of a person responsible for the handling of personal information.
(4) We have established a system to respond appropriately and promptly in the event of a spill or other incident, or if we become aware of indications of such an incident.
(5) Where appropriate, we make sure that employees are informed and trained on how to handle personal information as required.
(6) Physical security controls are in place, such as access-controlled rooms, storage in locked cabinets and storage rooms, password protection, and shredding.
(7) Access to personal information is controlled by limiting the scope of officers and employees who have access to personal information (our company's directors, corporate auditors, executive officers, corporate advisors, specially appointed advisors, counselors, consultant, contract employees, temporary employees, and other similar employees of our company).
(8) Necessary measures, such as the implementation of security software, are taken to prevent unauthorized access from outside and to prevent leaks related to information system specifications.

Basic Policy on the Proper Handling
of Specified Personal Information

Recognizing the importance of protecting specified personal information (personal information that includes personal numbers in its contents), our company has adopted a privacy policy as described below with regard to any and all specified personal information handled in the course of business.

1.Compliance with Relevant Laws, Regulation and Guidelines, and Establishment of Company Rules

(1) We will comply with the” Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures”, “Act on the Protection of Personal Information” and related laws and regulations. We will also make every effort to conduct our business in accordance with the guidelines established by the governmental authorities of Japan
(2) In order to prevent the leakage, loss, or damage of specified personal information and to manage specified personal information appropriately, we will establish corporate rules for the management of specified personal information and strive to manage it appropriately.
(3) We will ensure that all employees are familiar with the contents of the above laws, regulations, guidelines, and corporate rules mentioned above. In addition, we will endeavor to review and amend this privacy policy and corporate rules on an ongoing basis.

2.Basic Policy on Collection and Use of Specified Personal Information

(1) When we collect specified personal information, we will specify as clearly as possible the purpose for which the information will be used. When obtaining specified personal information directly from the person, we will inform the person of the purpose for which the information will be used or disclose it publicly. At the time of acquisition, we will verify the identification of the individual as required by law. If we receive a request for specified personal information after we have collected it, we will disclose the purpose of use in a reasonable manner except when exempted by laws and regulations.
(2) Except as otherwise required by law in exceptional cases, we will use personal information only for the scope of the purposes described above. The purpose of use will not be changed without notice, announcement, or clarification. In addition, we will take appropriate measures when an individual requests for disclosure, etc.
(3) We will make efforts to keep specified personal information as accurate and updated as possible and will take measures to protect the specified personal information from unauthorized access, loss, destruction, alteration, disclosure, or other accidents.
(4) If we outsource the handling of personal information, we will take appropriate measures, such as contractually defining the management responsibilities of the outsourced company.

3.Inquiries on Personal Information

Inquiries or other comments regarding specified personal information handled by our company should be directed to the relevant department of the company to which you provided your personal information. If you are not sure whom to contact, please send your inquiry to the contact information below.

【Contact】

ADDRESS: 158-1, Sayamagahara, Iruma-City,Saitama 358-0032,Japan
Administration Department, Nippon Micrometal Corporation
TEL: +81-4-2934-6101
FAX: +81-4-2934-5454
Contact: https://www.nmc-net.co.jp/en/contact/

Privacy Notice for Business Partners in Accordance with Chinese Law (in Chinese Only)

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