■ Processing Personal Data from the EU/EEA
Inabata & Co., Ltd. (hereinafter referred to as “Inabata”) complies with the GDPR and related laws and regulations concerning personal dataon EU/EEA residents, and appropriately manages and processes the provided personal data as set forth below:
1. Processing Personal Data
• Inabata and its affiliated companies lawfully collect, use, and maintain personal data from the EU/EEA for the following purposes andtakes necessary protective measures.
Data Subject

PurposeContent of Personal

Scope of Users

Legal Basis

DataTransfer

Data Retention

Outside ofPeriod

EU/EEA /ProtectiveMeasures(1) Business• Negotiations, communication,• Company name,• Inabata & Co., Ltd.

• Legitimate interests

Implement

The period

Partners

consultation, order placement andaffiliation, position,and its group* To deliver andone of thenecessary for thereceipt, settlement, or other forms ofname, and contact

companies

receive products andfollowing

purpose stated onprocessing relating to transactions

details (telephone• Partner companies

services withmeasures tothe left, such as the• Delivery and receipt of goods andnumber, fax number,necessary for thebusiness partners (theprotect thedelivery ofservices, etc. relating to transactions

email address, etc.) for

delivery of products

data subject), and todata

products and• Communication between businessthe contact at theand services toimplement othersubject’s

services, or thepartners and Inabata; notifications andbusiness partner andbusiness partners

direct marketingrights as

retention period

greetings in accordance with social

other personal data

activities

required bynecessary undercustoms; invitations andacquired through•The performance ofthe GDPR

audits, laws andcommunication regarding trade shows,transactions

a contract

whenregulations,*To fulfil ourtransferring

seminars, and other events1• Exchange of information and• Data equipment

contractual

the data

whichever is thecommunication with industry groups

identifiers such as thoseobligations or

outside of

longerand organizations relevant to Inabata’sof business partners’

exercise contractual

thebusiness

PCs used forrights with business

EU/EEAtransactions andpartners (the data

1) Sign ancommunications

subject)

SCC(2)• Exercise of rights and performance of• Shareholders’ name,• Inabata

Legitimate interests

regarding• The period

Shareholders

obligations pursuant to relevant laws

company (affiliation,• Financial institutions* To exercise rights

the transfer

necessary for theand regulationsposition), address,

such as securities

and performof personal

purpose stated on• Provision of benefits on account ofcontact details

companies and trust

obligations todata

the left, such as theshareholder status and implementation(telephone number, fax

banks that Inabatashareholders (the data

betweenexecution ofof measures designed to facilitate

number, email address,

entrusts with worksubject) and togroupshareholders’ rights

relationships with shareholdersetc.), as well as otherrelating to shares

implement othercompanies

and obligations or• Management of shareholder

personal data provided

administrative work2) Obtain

the provision of

information including compilation ofby shareholders

pursuant to related

individual

benefits, or theshareholder data pursuant to relevant

necessary for thelaws and regulations

consent

retention period

laws and regulations

execution of their rights•The performance ofafter having

necessary underand obligations undera contract

explained

audits, laws andrelated laws and*To fulfil ourthe purpose

regulations,regulations, and forcontractual

andwhichever is theInabata to provide

obligations orprotective

longerbenefits to shareholders

exercise contractualmeasures• Data equipment

rights to shareholders

whenidentifiers such as those(the data subject)

Inabataof PCs used in• Legal obligations

gathers andcommunications from* To comply withtransfers theshareholders

laws and regulations

2

(3)

• Provision and communication of• Applicant’s name,• Inabata

Legitimate interests

dataThe period

Applicants

information concerning recruitment

address and contact• Recruiters such as* To performdirectly.

necessary to review

in(including that for internships) bydetails (telephone

recruitment agencies

screening work, etc.

applications or theRecruitment

Inabata, and screening and hiring

number, fax number,that Inabata entrusts

for applicants (theperiod to respondActivities

decisionsemail address, etc.)with its recruitment

data subject)

to inquiries after• Provision of materials and• Information necessary

activities

communication in order to start work

to screen applicants

after making informal job offers(age, gender, academic

the selection
process (6 months)

background, career
history, reasons for
applying for the job,etc.)• Data equipment
identifiers such as thoseof PCs used incommunications fromapplicants(4) Inabata’s• Administrative communication and• Officers’, employees’,• Inabata• Legitimate interests• Period ofOfficers,

information exchange

and former employees’• Contractors that

* When necessary for

employment in

Employees,• Personnel management (transfers,names, addresses,

Inabata entrusts withpersonnel and labor

Inabata as officers

Formertemporary or permanent employment

contact details

its personnel affairs

management ofor employeesEmployees,

transfers, training and competence(telephone number, fax• Inabata’s laborhuman resources who• Period necessary

and Their

development, personnel evaluations,

number, email address,

union, health insurance

execute Inabata’s

to respond toFamilies

and promotions or demotions)etc.), dates of birth,

association, medical

operations

inquiries from• Remuneration management (payment

gender, academic

office, employee• Legal obligations

former officers andof salaries and bonuses, processing

background and career

shareholding* To comply withemployees

3attendance, severance/retirementhistory, dependents, andassociation, and grouplaws and regulations• Period necessary

allowance and retirement pensions,personnel informationcompanies

to calculate salaries,

to respond underasset formation, compliance with laws

such as positions,• Companies that

handle taxes, social

related laws andand regulations on taxes and socialqualifications,

accept employees

insurance work, andregulations such aswelfare)

remuneration, salary,

temporarily transferredstatutory medical

tax laws on behalf• Compliance with the Industrial

etc.

from the Inabata

examinations, etc.

of officers,

Safety and Health Act (regular medical• State of healthemployees, orexaminations, comprehensive medical

necessary for officers’

former officers andexaminations, specific healthand employees’ labor

employees

checkups, etc.) and healthcare

management, treatment

management

information and results• Responding to procedures stipulatedof statutory medical

in labor related laws and regulations,

examinations

and internal rules and regulations• Data equipment• Communication and sharing withidentifiers such as those

Inabata’s labor union, health insuranceof PCs used inassociation, medical office, employee

communications byshareholding association, and groupboard members,companies

employees, and former• Notifications and reports to public

employees

agencies and their affiliatedorganizations or organizations towhich Inabata belongs• Provision of welfare services,
introduction of various types of groupinsurance, and performance of related
procedures

4• Distribution of in-house newslettersand other materials• Communication in emergencies(5) Personal• Procedures, document preparation• Former officers’ andInformationand storage stipulated in relevant laws

on Former• Inabata• Legitimate interests• Period necessary

employees’ names,* To respond toto respond toand regulations

addresses, contact

various inquiries

inquiries relating toOfficers and• Communication after

details, gender, dates ofmade after

former officers andEmployees

resignation/retirement

birth, academic

resignation/retirement

employees andand Their• Response to inquiries made after

background and career• Legal obligations

their families

Families

resignation/retirement

history, and personnel* To comply with• Period necessary

information such as

laws and regulations

to respond underpositions, qualifications,to handle taxes andrelated laws andremuneration, salary,for social insurance

regulations such asetc.

work, etc.

tax laws on behalf• Personnel informationof officers andon former officers’ andemployees

employees’ families’
names, gender, and datesof birth, etc.

* In principle, Inabata does not process personal data on race, ethnic identity, political opinions, religious or philosophical beliefs, or tradeunion membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health(excluding data necessary for labor management and legally required data) or sensitive data concerning a natural person’s sex life or sexualorientation.
* Inabata does not engage in automated processing such as profiling when engaging in transactions or hiring employees, etc.
2. Rights of Data Subjects• Inabata respects the rights of data subjects stipulated in the GDPR.
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(1) Access
Data subjects can access their personal data retained by Inabata by taking specified procedures.
(2) Portability
Data subjects can transfer their personal data retained by Inabata to another company by taking specified procedures.
(3) Deletion and Correction, etc.
Data subjects can delete and correct their personal data retained by Inabata by taking specified procedures.
(4) Processing Restrictions
Data subjects can restrict the processing of their personal data retained by Inabata by taking specified procedures in cases that fall undercertain requirements (i.e. the accuracy of their personal data is contested).
(5) Withdrawal of Consent
Data subjects can withdraw their consent expressed to Inabata at any time without any effect on lawful processing pursuant to consent
prior to withdrawing consent by taking specified procedures.
(6) Lodging Other Complaints
Data subjects can lodge complaints with Inabata concerning their personal data by taking specified procedures, or data subjects canlodge complaints with the supervisory authority.
3. Security Control Measures for Personal Data
• Inabata and our affiliated companies take necessary protective measures for the appropriate and secure processing of personal data from theEU/EEA.
(1) Organizational Security Control Measures and Personnel Security Control Measures
We have established an organizational security control system for clerical work that processes personal data, and we will notify thesupervisory authority in case of a data leak without delay by the deadline stipulated in the GDPR.
(2) Physical and Technical Security Control Measures
Inabata has established standards including information security rules to prevent personal data leaks and we have implemented physicaland technical security control measures.
4. Outsourcing of Personal Data•

Inabata may outsource clerical work relating to the processing of personal data as necessary.
6•In such cases, we will execute an agreement that provides for the implementation of security control measures stipulated in the GDPRand ensure that necessary security control measures are properly taken.

5. Controller and Data Protection Officer

NameController

Data Protection Officer (DPO)

Inabata & Co., Ltd.

Corporate Communications Department, General Affairs
Office, Inabata & Co., Ltd.

Address

2-8-2 Nihonbashi-honcho, Chuo-ku, Tokyo 103-8448

Contact
Details

Please use the “Contact Us” link below to send an inquiry.

6. Disclosure, Correction, and Discontinuation of Use of Registered Information• When Inabata receives a request from an individual for disclosure, correction, discontinuation of utilization, deletion, or suspensionof disclosure, transfer or provision to third parties, etc., of his/her personal information handled by Inabata, Inabata will confirm theidentity of the individual making the request and respond promptly unless otherwise prohibited to do so by laws and regulations orother special circumstances.
Please use the “Contact Us” form on the Privacy Policy page to send a request.

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