Handling of personal information

Established on August 4, 2015
Revised on January 25, 2022
WDB Holdings Co., Ltd.
President and CEO
Toshimitsu Nakano

Article 1 (Purpose)

This agreement (hereinafter referred to as the "Agreement") is the basic matter for measures to protect and manage personal information regarding the handling of personal information owned by WDB Holdings Co., Ltd. (hereinafter referred to as "the Company").
The purpose of this agreement is to protect the rights of those (hereinafter referred to as "Users") who use various services (hereinafter referred to as "the Service") that we provide while realizing the appropriate and effective use of personal information by establishing the obligations that the Company should comply with.

Article 2 (Definition)

1. In this agreement, personal information refers to information about a living individual that can be used to identify the specific individual by name, telephone number, e-mail address, or other description provided or declared by the user.

2. In this agreement, the term "persons" as used herein refers to the specific individual identified by the personal information.

Article 3 (Purpose of Use)

The Company will only use personal information received from the individual within the scope of the purpose of use as specified by listed in the following paragraphs. Any change in the purpose of use will notify the person of the changed purpose of the use or make it public.

1. To respond to inquiries and provide information

2. To use personal information proceed statistically not to be identified or specified as data for analysis

Article 4 (Acquisition)

1. The Company shall acquire personal information only to the extent necessary to achieve that purpose under the purpose of use based on the preceding article. Personal information shall be acquired by an appropriate method that does not rely on improper means.

2. The provision of personal information when inquiring is the user's discretion. However, if all or part of the required information is missing or if the information is incorrect, the user may not be able to respond to the inquiry from the user.

Article 5 (Safety Management Measures)

The Company shall implement continuous security measures for personal information under its control and take necessary and appropriate measures to prevent leakage, loss, destruction, falsification, unauthorized access, etc.

Article 6 (Provision to Third Parties)

1. The Company will not disclose or provide personal information to third parties without the prior consent of the individual except following cases;

（ⅰ） When it is necessary to protect the life, body or property of a person and it is difficult to obtain the consent of the person.

（ⅱ） When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the individual.

（ⅲ） When it is necessary for a national institution or a local public body or a person entrusted with it to cooperate in carrying out the affairs stipulated by laws and regulations, and it is difficult to obtain the consent of the person.

（ⅳ） When personal information is provided by entrusting all or part of the handling of personal information to the extent necessary to achieve the purpose of use.

（ⅴ） When personal information is provided due to business succession due to merger or other reasons.

2. The Company may outsource all or part of its personal information handling operations to a contractor who has a system that meets the standards for personal information protection set by The Company. The Company shall supervise the security of personal information at the outsourced as necessary and appropriate.

Article 7 (Request for Disclosure, Correction, Suspension of Use, etc.)

1. When a person wishes for disclosure of personal information, correction, addition or deletion of contents, suspension or deletion of use, notification of purpose of use, and suspension of provision to third parties (hereinafter referred to as "disclosure, etc."), please follow the procedures below. The Company will respond without delay after confirming that the request is from the person or agent.

（ⅰ） Contact
If you wish to request disclosure, etc., please contact the address listed in Article 8. After confirming the contents of the request, we will send you a request form for disclosure, etc. designated by the Company. Please fill in the necessary items on the Request Form for Disclosure, etc., enclose the documents to be submitted as described in item 2 of this section, and send it back to the address described in Article 8 by registered mail, simplified registered mail, or specified record mail, or any other method that can prove delivery records. Please write "Request for Disclosure, etc. in progress" in the envelope.

（ⅱ） Documents to be submitted
Please enclose the following documents.

Claimant	Documents to be submitted
A. Request by the person identified by personal data	[If you own photo ID] Please enclose one of the following documents of the copy. Driver's Licenses Basic Resident Register Card Individual Number Card Passport [If you don't own photo ID] Please enclose two of the following documents of the copy. Various Health Insurance Cards Pension Notebooks Resident Cards Seal Registration Certificates
B. Request by statutory representative	In addition to the documents required in (A) above, please enclose a copy of the following documents. [Parental authority] A copy of the family register or an extract of the family register. [Guardian, etc.] Certificate of registered matter
C. Request by voluntary agent	In addition to the documents required in (A) above, please enclose a copy of the following documents. Seal certificate of the seal stamped in the power of attorney column of the disclosure request form

Claimant

Documents to be submitted

A. Request by the person identified by personal data

[If you own photo ID]

Please enclose one of the following documents of the copy.

Driver's Licenses
Basic Resident Register Card
Individual Number Card
Passport

[If you don't own photo ID]

Please enclose two of the following documents of the copy.

Various Health Insurance Cards
Pension Notebooks
Resident Cards
Seal Registration Certificates

B. Request by statutory representative

In addition to the documents required in (A) above, please enclose a copy of the following documents.

[Parental authority]

A copy of the family register or an extract of the family register.

[Guardian, etc.]

Certificate of registered matter

C. Request by voluntary agent

In addition to the documents required in (A) above, please enclose a copy of the following documents.

Seal certificate of the seal stamped in the power of attorney column of the disclosure request form

（ⅲ） Fees, etc.
No fees are collected for requests for disclosure, etc.

（ⅳ） Purpose of use
Personal information acquired by the Company upon request for disclosure, etc. will be used only to the extent necessary for procedures such as disclosure. In addition, the submitted documents will be stored for 5 years after the response to the request for disclosure, etc. is completed, and then properly disposed of.

（ⅴ） Non-disclosure
In the following cases, we will not be able to disclose the personal information requested for disclosure, etc. If we decide not to disclose all or part of personal information, we will notify the person with a reason to that effect.

If you cannot disclose	Reasons for non-disclosure decision
A. If the attached documents are incomplete	He identity or agent confirmation document does not include or has been deleted, such as "address," "name," "date of birth," "issuer name and issue date / issue date." The "address," "name," and "date of birth" entered in the disclosure request form do not match the "address," "name," and "date of birth" stated in the identity verification document. The expiration date of the identity verification document has passed (for various certificates that do not have an expiration date, they must be within 3 months from the effective date). It turned out to be a forged or falsified document (disclosure request form and attached documents will not be returned and will be reported to the authorities and submitted). The proxy right of the agent cannot be confirmed
B. When there is a reason based on laws and regulations	The requested information item is not in the personal information held by the Company. There is a risk of harming the life, body, property or other rights and interests of the person or a third party. There is a risk of significant hindrance to the proper implementation of our business. Disclosure may violate the law.

If you cannot disclose

Reasons for non-disclosure decision

A. If the attached documents are incomplete

He identity or agent confirmation document does not include or has been deleted, such as "address," "name," "date of birth," "issuer name and issue date / issue date."
The "address," "name," and "date of birth" entered in the disclosure request form do not match the "address," "name," and "date of birth" stated in the identity verification document.
The expiration date of the identity verification document has passed (for various certificates that do not have an expiration date, they must be within 3 months from the effective date).
It turned out to be a forged or falsified document (disclosure request form and attached documents will not be returned and will be reported to the authorities and submitted).
The proxy right of the agent cannot be confirmed

B. When there is a reason based on laws and regulations

The requested information item is not in the personal information held by the Company.
There is a risk of harming the life, body, property or other rights and interests of the person or a third party.
There is a risk of significant hindrance to the proper implementation of our business.
Disclosure may violate the law.

2. The Company may not take all or part of the following items if it falls under any of the following items by taking measures such as disclosure requested according to the provisions of paragraph.

（ⅰ） When there is a risk of harming the life, body, property or other rights and interests of the person or a third party

（ⅱ） When there is a risk of significant hindrance to the proper implementation of The Company operations

（ⅲ） When it violates the law

3. If the Company does not take all or part of the measures such as disclosure requested according to the provisions of the preceding paragraph, or if it takes different measures, it will endeavor to explain the reason to the person.

Article 8 (Consultation Desk Regarding Personal Information)

The Company has set up a "Personal Information Protection Counter" and will endeavor to respond appropriately and promptly to complaints and consultations regarding the handling of personal information.

[Personal information consultation desk]
WDB Group Personal Information Protection Manager Deputy Personal Information Protection Counter
E-mail：pmark@wdb.com