TSUHO Support Center Co., Ltd.

Personal Information Protection Policy (Privacy Policy)

TSUHO Support Center Co., Ltd.
Representative Director, Shiho Maeda

We, TSUHO Support Center Co., Ltd., conduct our business activities mainly onreceiving reports from overseas (the “Service”). Our executives and employees shallstrictly protect the personal information we obtain in the course of our work. For
this purpose, we hereby formulate this personal information protection policy (this“Policy”) as follows. All of our executives and employees will comply with the Act
on the Protection of Personal Information (the “APPI”) in Japan, the General Data
Protection Regulation of the EU (the “GDPR”) and other laws and regulations
applicable to us, as well as other internal regulations. We will also continuously
review and improve our management system for the protection of personalinformation.
1.

Introduction

This Policy applies to all personal data obtained in connection with the Services, regardless ofcountry or region.
2.

Personal data that we collect and the purpose of processing personal data

(1) Data on the organizations and persons in charge of our business partners
We collect the following data for the purpose of promoting our business, managing ourcontractual relationships and providing information on seminars.
Name

Department

Position

Email addressTelephone number



Information on the company or organization (name of the company or organization,address, telephone number, etc.)

Other data we collect for the purpose of promoting our operations, managing contractualrelationships, and providing information on seminars.

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(2) Data obtained in the course of executing business entrusted by business partners andorganizations
We collect the following data for the purpose of fulfilling the duties entrusted by our businesspartners and organizations.
Company code

Name of company

Country/Area where the company is located

Name of whistleblower's department

Name of whistleblower

Email address of whistleblowerOther data acquired by us for carrying out business entrusted by other business partners
and organizations(3) Data on inquiries
We collect the following data for the purpose of contacting individuals and responding toinquiries.

3.

NameName of company or organization

Contact information (email address, phone number, etc.)

Contents of inquiries

Other data we obtain in order to respond to inquiries
Legal basis for the processing of personal data

We will process your personal data based on your consent to this Policy when using this Service;provided, however, that we may, when necessary, process your personal data to the extent
permitted by applicable laws and regulations, based on legitimate interests and other legal grounds
except for your consent, such as the promotion of our business and the management of ourcontractual relationship, in order to achieve the purposes set forth in paragraph 2 above.
4.

Disclosure and provision of your data

We may disclose to or provide the following persons with your personal data to the extent
necessary to achieve the purposes set forth in paragraph 2 above.
Our group companiesCompetent authorities as defined by applicable laws and regulations (including the courts
and other public authorities that have jurisdiction over us or our group companies)

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Any other third party that may reasonably require access to your personal data inconnection with the foregoing purposes

We may disclose or provide your personal data to third parties that provide services to us (suchas providers of cloud services that process and store data on our services). We will provide
necessary and appropriate supervision over such third parties.
We will not disclose or provide your personal data to any third party except in the above cases orin the following cases where:we obtain your consent

the handling of personal information is based on laws and regulations

the handling of personal information is necessary for the protection of the life, body orproperty of an individual and it is difficult to obtain the consent of the person

the handling of personal information is especially necessary for improving public health orpromoting the sound growth of children and it is difficult to obtain the consent of the person

the handling of personal information is necessary for cooperating with a state organ, a local
government, or an individual or a business operator entrusted by either of the former twoin executing the affairs prescribed by laws and regulations, and obtaining the consent of
the person is likely to impede the execution of the affairs concerned

5.

Transfer of personal data abroadYour personal data may be transferred to and stored or otherwise processed in a country or region
other than your location (including, without limitation, Japan). However, please be aware thatdata protection at the same level as your location may not be provided under the laws andregulations of such country or region. In that case, we will comply with our legal obligations andtake appropriate protective measures to protect your personal data.
When the GDPR is applied to the processing of your data, we transfer your personal data fromthe European Economic Area (the “EEA”) to outside the EEA only if such country or region
outside the EEA receives an adequacy decision under the GDPR.
6.

Holding period

We retain personal data for the period required to achieve the purposes stated in paragraph 2above. However, we will retain your personal data for more than the period specified above if
required in accordance with applicable laws and regulations.

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7.

Security

We take necessary and appropriate safety management measures to prevent leakage, loss, damage
and other problems involving personal data. We also take appropriate technical and organizational
measures to protect and ensure personal data in order to prevent unauthorized access orunauthorized disclosure. For details of our safety management measures, please make contact as
described in “12. Contact information” below.
8.

Your Rights

You have various rights to your personal data to the extent permitted by applicable laws.
Specifically, you may have the right to request to access your personal data (disclosure of personal
data and disclosure of records provided to third parties), copy your personal data, correct, add ordelete the contents of your personal data, restrict certain processing of your personal data, orexpress objections thereto. In addition, you may have the right to data portability.
If personal data is processed with your consent, you may have the right to withdraw your consent.
Withdrawal of this consent will not affect the prior processing of personal data that you havealready agreed to.
To exercise your rights with respect to personal data, please contact us as described in “12.
Contact information” below.
9.

Filing of Complaints

If you believe that we have handled your personal data illegally without complying with yourrequest, you have the right to file a complaint with the relevant Data Protection Agency, to theextent permitted by applicable law.
10.

Obligation to provide personal data

Except for the information listed in paragraph 2 (1) above, the provision of personal data by you
upon the use of the Services is not required by law or in the contract between us and the company
using the Services. However, if the personal data necessary for using the Services is not provided,
you may not be able to use all or part of the Services.
11.

Changes to this Policy.

We may revise this Policy from time to time in the future. When this Policy is revised, we will
post such change on our website.
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12.

Contact information

If you have any questions or opinions regarding this Policy, please contact our contact person asfollows.
TSUHO Support Center Co., Ltd.
Address: 7F 5-8-14, Hiroo, Shibuya-ku, Tokyo, Japan
Email address: respect@whistle.jp
The contact information for our representatives in the EEA region is as follows.
TSUHO Support Center EU SARL
Address: 43, rue de Liège 75008 Paris, France
Email address: respect@whistle-eu.com
The contact information for our data protection manager is as follows.
Email address: ytanaka@integrex.jp

Enacted on April 01, 20225