Privacy Policy
Basic Policy
Japan Transport Engineering Company (“the Company”) shall comply with all laws and internal
regulations pertaining to the protection of personal information (defined as information pertaining
to living people wherein any name, date of birth or other datum may be used to identify any
individual). The Company shall protect personal privacy by obtaining and using personal
information appropriately, maintaining such information safe and up-to-date, and disposing of it
by appropriate methods.

Company-wide Privacy Protection Activities(1) The Company shall comply with privacy protection laws.
(2) The Company shall establish and comply with privacy protection regulations.
(3) The Company shall periodically ascertain whether or not personal information is being handledappropriately, and act to remedy any problems should they be discovered.
(4) The Company shall request cooperation from all companies in the JR East Group, and business
partners-corporate and otherwise- in achieving the objectives of the internal regulations.
(5) The Company’s privacy policy shall be made available to the public at all times, such as byposting it on the Company's website.

Handling Personal Information
The Company shall handle personal information as outlined below except where law permits
otherwise.

(1) Internal Systems
The Company shall assign administrators for each item of personal information, and shall manage
all such information appropriately.

(2) Obtaining Personal Information
The Company shall specify the purpose of use for and obtain personal information by appropriatemeans.

(3) Use of Personal Information
In using personal information, the Company fully acknowledges the importance of privacy
protection, and shall only use personal information for the stated purposes.

(4) Management
The Company shall implement all necessary safety measures in managing personal information.

(5) Personal Rights
The Company shall acknowledge and respect the rights of those whose personal information theCompany possesses. If any such person requests that their personal information be disclosed orrevised, or that the Company cease use of such information, the Company shall do so within areasonable period and within the scope of law.

(6) Improvements
The Company shall continually endeavour to improve its protection of personal privacy.

March 2021
Japan Transport Engineering Company

Details of How We Process Your Personal
Data
1. Personal data we collectIf you are located outside Japan, we collect the following personal data for the purposes ofbusiness operations and service provision.

(1) Collection of business contact information(A) Personal data related to exchanged business cards⚫

We collect your name, telephone number, e-mail address, company name, and address as
the business contact information.

(2) Recruitment(A) Personal data of potential employees⚫

We collect your name, contact details, employment history, skills such as languages, etc. andany necessary information for recruitment as recruitment information.

(3) Personal data we automatically collect when you use our online (website) services(A) Personal data related to the use of our web site⚫

We collect IP address as the access information.

If you do not provide personal data that are necessary for each operation and service, thebusiness and service may not be able to be provided.

2. The purpose of processing of the collected personal data
We process the collected personal data for the following purposes.

(1) Collection of business contact information(A) For providing information on rolling stock car and other information related to our businessactivities(B) For the conclusion and performance of a contract with business partners, and the managementof a contract(2) Recruitment(A) For recruitment activities and providing information related recruitment(B) For the employee management (including loan and transfer)(C) For the procedures and contact, etc. necessary for legal requirements(D) For the procedures and contact, etc. necessary for business operations(3) Personal data we automatically collect when you use our online (website) services(A) For ensuring security of our customers and employees(B) For the consideration and development of software, systems, equipment, devices etc. forensure security

3. The lawful basis for processing of personal data
We process personal data only when we obtain your consent or the processing is permitted by theJapanese law.
If you are located in European Union member states, Iceland, Liechtenstein, and Norway(Hereinafter defined as "EU"), we process your personal data only if we obtain your consent or atleast one of the following conditions applies.
(A) When the processing is necessary for the performance of a contract to which you are party or
in order to take steps at your request prior to entering into a contract(B) When the processing is necessary for compliance with a legal obligation to which we aresubject (e.g. when following the information disclosure orders from government/court based
upon laws and regulation announced by government agencies/courts)(C) When the processing is necessary in order to protect the vital interests of yours or of anotherindividual(D) When it is considered appropriate to investigate, prevent, or take measures against illegal or
suspicious acts
(E) When the processing is necessary for the purpose of the legitimate interests pursued by us orby a third party, except where such interests are overridden by your privacy related rights,interests, and freedom. The legitimate interests pursued by us or a third party are as follows:⚫

Customer satisfaction improvement;⚫

Service improvement;⚫

Direct marketing;⚫

Illegal act prevention;

⚫

Regular communication with business partners and others; and⚫

Protection of assets (security) of our customers and our company

4. Places where we store personal data
We store the data on a server located in Japan. Although Japan has not received the adequacy
decision from the European Commission regarding personal data protection, we will protect yourpersonal data by taking appropriate measures in accordance with the relevant regulations.

5. Retention period, deletion and disposal of personal data
After the purpose of processing is accomplished, personal data collected from you will be properly
deleted, disposed, or anonymized in the ways that the individuals can not be identified, inaccordance with the rules of personal data processing we specified.

６. Your rights
If you are located in the EU, you have the following rights regarding the processing of personaldata.
(A) Right to access to your personal data and related information(B) Right to rectification of your inaccurate personal data without undue delay(C) Right to erasure of your inaccurate personal data without undue delay(D) Right to restriction of processing your personal data
(E) Right to data portability(F) Right to object(G) Right to withdraw your consent at any time regarding the processing of personal data basedon your consent (The withdrawal does not affect the lawfulness of processing of personal data
based on consent before its withdrawal)

７. When you wish to exercise your rights
If you are located in the EU and wish to exercise your rights described above, you can contact us
via the following e-mail address. The personal data provided us during your request will be used
only for the purposes of contact with you and taking actions upon your request.
If you are located in the EU and dissatisfied with the processing of personal data by our company,
you can lodge a complaint to a supervisory authority, in particular in the EU of your habitualresidence, place of work, or place where infringement occurs.

８. Inquiry desk
Inquiry desk for Personal Data, Japan Transport Engineering Company
3-1 Okawa,Kanazawa-ku, Yokohama, Kanagawa,236-0043, Japan
E-mail address: i-desk@j-trec.co.jp

９. Revision
We may revise all or part of this "Details of How We Process Your Personal Data" without priornotice. In making revisions which we consider important, we will notify you in advance throughour web site.