This Privacy Policy (this "Policy"") is established by PANDOLOR Inc.(the "Company""), as follows, concerning the protection of personal data within the Company. If the Company has established a separate privacy policy other than this Policy, such other policy shall prevail over this Policy.
The terms used in this Policy shall have the same meanings as those set forth in the Act on the Protection of Personal Information of Japan (the "Act").
 

1. Personal data Items to be Obtained
   The Company shall obtain the following types of personal data:
   Information concerning data subjects to be entered in relation to the use of the Company's services, such as names, occupations (including company names, company addresses and titles, etc.), telephone numbers and email addresses.
    

2. Purposes of Use
   The Company shall obtain and use personal data within the scope of the following purposes (the “Purposes of Use”):
   
   Acceptance of applications for the Company's services（Recruit);
   Confirmation of and communication with the data subjects who use the Company's services;
   Provision of the Company's services;
   Communication of necessary information on the maintenance and management of the Company's services and any other important information;
   Identification of and necessary response to the users who have breached any agreements, such as the Terms of Use, or who attempt to use the services for any wrongful or unjust purpose;
   Notification of and promotional activities pertaining to the Company's services;
   Notification and operational management of, and promotional activities pertaining to, any events hosted by the Company;
   Response to inquiries made to the Company
   Performance of duties commissioned by any other party;
   Planning, research, and development of the Company's services;
   Provision of such personal data to any third party using the methods described in this Policy; and
   Any other purposes incidental to any of the foregoing items.
   Unless permitted by the Act or any other applicable laws and regulations, the Company shall not use any personal data beyond the scope of the Purposes of Use without obtaining the prior consent of the information subject.
    

3. Third-Party Provision
   (1) The Company will not provide any personal data it handles to any third party without obtaining the prior consent of the data subject, except in cases where:
   
   Such provision is made in accordance with the laws and regulations;
   Such provision is necessary to protect human life, body or property, and where it is difficult to obtain the consent of the data subject;
   Such provision is particularly necessary for the enhancement of public health or for the promotion of the sound development of children, and where it is difficult to obtain the consent of the data subject;
   It is necessary for the Company to cooperate with a state organ or local government or any entrustee thereof in performing duties prescribed under the laws and regulations, and where the performance of such duties may be obstructed by obtaining the consent of the data subject;
   Personal data is provided to any third party in relation to the outsourcing to such party of the handling of such personal data within the scope necessary for the Company to achieve the Purposes of Use;
   Personal data is provided in relation to business succession; or
   Personal data is shared due to joint use.
   (2) The Company will not provide any personal data it handles to any third party outside Japan without obtaining the prior consent of the data subject, except in cases where:
   
   Paragraph (1), Items 1 to 4 of this Article 3 applies;
   Such provision is made to any third party located in a foreign country designated under the rules of the Personal Information Protection Commission as a country with a personal data protection system recognized as being at the same level as that in Japan regarding protecting the rights and interests of individuals;
   The implementation of certain measures in line with the intent of Chapter IV, Section 2 of the Act is ensured by an appropriate and reasonable method between the Company and the recipient of such personal data in relation to such recipient's handling of the same; or
   The recipient of such personal data is certified under an international framework for the handling of personal data.
   In cases where Paragraph (2), Item 3 or 4 of this Article 3 applies, the Company will take certain measures required to ensure the recipient's continuous implementation of the necessary measures. Please contact the Company using the “Point of Contact” set forth in Article 9 for details of such assurance measures.
    

4. Outsourcing
   The Company may outsource any duties related to the handling of personal data to any outside party within the scope necessary to achieve the Purposes of Use. When outsourcing any such duties, the Company will evaluate/select the entrustee in accordance with the criteria separately prescribed in advance by the Company and appropriately supervise such entrustee.
    

5. Security Control Measures
   The Company takes any necessary and appropriate measures to prevent the divulgence or loss of, or any damage to, the personal data it handles and for any other safety control of personal data. The safety control measures taken by the Company include the following:
   
   Maintaining internal discipline
   The Company maintains discipline such as by establishing and periodically reviewing the internal rules on the methods and persons in charge of handling personal data and the duties of such persons for each stage of handling, such as the acquisition, use, provision and destruction of personal data.
   Maintaining organizational structure
   The Company places a person in charge of personal data protection who supervises all handling of personal data within the Company, and the Company maintains a system whereby any employee who has detected any divulgence, etc. can promptly report or notify such person in charge to that effect.
   Periodic inspections and audits
   The Company takes certain measures when handling personal data, such as periodic self-inspections, audits by other departments and external audits.
   Employee education
   The Company takes certain measures such as providing periodic training regarding personal data protection and information security to its employees and familiarizing them with matters concerning employee confidentiality by covering such matters in the work rules, etc.
   Preventing unauthorized access
   The Company takes certain measures such as adopting a system which provides for protection against unauthorized access, etc.
   Grasping the external environment
   The Company maintains a system wherein, in the case where the Company is handling personal data abroad, it can get a grasp of the foreign personal data protection systems and respond to the same on a timely basis
   .

6. Requests for Disclosure, etc.
   The Company will respond to any requests for disclosure, etc. (meaning requests for notification of the Purposes of Use, for disclosure, revision, deletion or addition, and for the suspension of use or third-party provision) as follows:
   
   (1) Notification of Purposes of Use or Disclosure
   The data subject may request the Company to provide notification of the Purposes of Use or to disclose his/her personal data or records of third-party provision in accordance with the procedures separately prescribed by the Company, except where:
   
   Such disclosure may damage the life, body, property or any other rights and interests of the data subject or any third party;
   Such disclosure may significantly obstruct the proper performance of the Company's duties;
   Such disclosure violates the laws and regulations; or
   It cannot be confirmed that such request for disclosure had been made by the data subject him/herself.
   Please note that, when making a request for notification of the Purposes of Use or for the disclosure of your personal data or records of the third-party provision thereof, you may be charged a disclosure fee in accordance with the procedures separately prescribed by the Company.
   
   (2) Revision, Deletion or Addition
   The data subject may make a request for the revision or deletion of, or the addition to, his/her personal data in accordance with the procedures separately prescribed by the Company. In that case, the Company will inspect the circumstances without delay, within the scope necessary to achieve the Purposes of Use, and will revise, delete or make additions to such personal data based on the results of such inspection.
   
   (3) Suspension of Use or Third-Party Provision
   The data subject may make a request for the suspension of use or third-party provision of personal data in accordance with the procedures separately prescribed by the Company. In that case, the Company will appropriately respond to such request in compliance with the Act.
    

7. Retention Period
   The Company will retain personal data for the period necessary, permitted, or required under applicable laws, in light of the purpose of obtaining the same.
    

8. Personal data of Children
   Minors under the age of 15 should provide the Company with their personal data in order to use the Company's services with the consent of their guardians
    

9. Point of Contact
   If you have any comments, questions, complaints, offers or any other inquiries concerning the handling of personal data, please contact the Company using the “recruit@pandolor.co.jp” details on the website.