Basic Policy on Handling of Personal Data
Japan International Consultants for Transportation Co., Ltd. (representative: Masahiko
NAKAI) (hereinafter referred to as ‘we’, ‘us’ and ‘our’) has established a self- management
system to comply with laws, regulations and other norms regarding the protection of personal
information (defined as any information relating to an identified or identifiable natural
person) of our customers, business partners, employees and others who use personal
information in the course of their work (hereinafter referred to as ‘Personal Data’). This
Policy is our top-level policy for the protection of Personal Data and we will ensure thatvarious measures are implemented in accordance with this Policy.
Handling of Personal Data1.

We manage Personal Data, appropriately and strictly, and take thorough security measures toprevent information leakage, loss, unauthorised access, destruction and falsification.

2.

We comply with all laws, regulations and other norms relating to the protection of Personal Data.

3.

We respond appropriately to inquiries about Personal Data and data protection.

4.

We collect Personal Data appropriately and does not provide it to third parties without the priorconsent of the individual, except in the cases described in "5. Scope of use of Personal Data".

5.

We will ensure that all directors, employees and relevant persons are aware of the above, and will
implement, improve and maintain them.

1.

Collection of Personal Data

We collect Personal Data by proper and lawful means.
2.

Scope of Personal Date we collected

We collect the following Personal Data from you who are located (or reside) outside Japan for the
purposes of business operations and service provision.
If you do not provide Personal Data that are necessary for each operation and service, the business andservice may not be able to be provided.
(1) Customer information for our business operations and service provisiona)Personal Data related to our business operations•

We collect your name, telephone number, e-mail address, company name, company
address, and title/position.

b)

Personal Data related to inquiries on the website•

We collect your name, address, age, occupation, telephone number, e-mail address, and1 / 8

other information if necessary.
c)Personal Data related to the provision of our service and other business activity information•d)

We collect your name and e-mail address.

Personal Data related to the collection of customer feedback•

We collect your name, address, age, occupation, telephone number, e-mail address, andother information if necessary.

(2) Business contact information we collect when attending events or meetingsa)Personal Data related to exchanged business cards•

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

b)

Personal Data collected for sending seasonal greetings and greeting letters•

We collect your business contact information which includes your name, telephone
number, e-mail address, company name and address (including company address).

c)Personal Data related to attendee lists•

We collect your personal data (your name, affiliation, and title/position) provided on
attendee lists at international conferences.

d)Personal Data used for meetings and invitations•

We collect your name, background information, career information, and photographwhen we meet you or invite you to visit us.

e)

Minimum required personal data of our business partners(3) Recruitmenta)Personal Data of potential employees•

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

(4) Management of employeesa)Personal Data necessary for the management of our employees•

For employee management purposes, we collect necessary information such as yourname, address (including place of residence and country of residence), telephone
number, birthdate, gender, family name, family employment information, health status,
contact details, background information (including highest level of education),
employment history, language skills, etc).

•

For employee management purposes, we collect information (your name, address,
telephone number, and e-mail address) included on our name list and in our contact

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network.
•

For administrative purposes related to our employees, we collect your passport number,visa number, social security number, and bank account information.

(5) Personal Data we automatically collect when you access our websitea)Personal Data related to the use of our web site•

We collect cookies, internet domain names, IP addresses, access status, and otherinformation in the form of access logs. A cookie is a technology that allows sites tostore information in the browser of your computer, etc. and the information can be
retrieved later. There are some contents using cookies in our web site. It is possible todisable cookies in your browser settings at any time, but please notice that in this casethere may be some contents which cannot function properly or be shown correctly. We,
however, does not use cookies to collect any information that allows it to identify
individual users. The browser can be set so that the functions of cookies are nullified.
Nullifying the functions of cookies does not affect the ability to use this website. For
more information about cookies, please visit our Cookie Policy.

•

This website uses Google Analytics to assess site usage. Google Analytics collects
information about users by means of cookies. For the Google Analytics terms of service
and privacy policy, see the Google Analytics website. We bear no responsibility for any
damage resulting from use of the Google Analytics service.

3.

Purpose of use of Personal Data

(1) Customer information for our business operations and service provisiona)

To conclude and fulfil contracts, including the provision of products and services (including
those for which we has been entrusted by third parties with sales and management operations,etc. The same applies below), to manage the contracts and to implement after-sales services
for the products and services providedb)

To contact you as necessary for the provision of products and servicesc)

To provide information on products and services and other information on our businessactivitiesd)To bill and collect fares and charges for goods and services and to protect receivables(including when requesting credit card or other payment procedures from consumer credit
companies, etc.)e)

To conclude and fulfil contracts with business partners and to carry out post-contract

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managementf)

To receive and respond to customer enquiries and opinions(2) Business contact information we collect when attending events or meetingsa)

To exchange business card etcb)

To provide information on our services/products and other information related to ourbusiness activitiesc)

To prepare attendee lists distributed at meetingsd)To hold meeting and invitationse)

To conduct the negotiation, conclusion and performance of a contract with business partners,
and the management of a contract(3) Recruitmenta)

To provide recruitment-related information and to perform tasks related to recruitment(4) Management of employeesa)To manage employment (including secondments and transfers)b)

To conduct operations relating to the payment of salaries and other benefitsc)

To conduct operations relating to welfare and other benefitsd)To conduct operations related to health care and other matterse)

To conduct various post-retirement proceduresf)

To conduct various procedures and communications required by lawg)

To conduct other procedures and communications necessary in the course of business(5) Personal Data we automatically collect when you access our websitea)

To conduct the market research on our business, or other researches or surveysb)

To conduct a business analysisc)

To ensure the security of customers and employeesd)To maintain and manage the facilities, equipment and machinery and their usee)

To examine and develop new products and services and the software, systems, facilities andequipment that provide them

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4.

Legal basis

The legal basis for processing your Personal Data is as follows: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 contractb)

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 anotherindividuald)When the processing is necessary for the purpose of the legitimate interests pursued by us
or by 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;- Protection of assets (security) of our customers and our company; and- Safety of our employees.

5.

Scope of disclosure of Personal Data

In order to run each business and service, we share/provide your Personal Data with our groupcompanies and external partners. We also share/provide the Personal Data of employees with publicorganizations in order to comply with laws and regulations. Our group companies and external partners
with whom we share Personal Data are as follows.
(1) Customer information for our business operations and service provision- our group company (located in Japan)

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- subcontractors and third parties who have made proper contract with us (located in Japan)(2) Management of employees- public organizations (located in Japan)(3) Personal data we automatically collect when you access our website- Google, LCC

6.

Transfers of Personal Data outside the EEA or the UKYour Personal Data may be transferred to, and stored by, a third party outside the EEA or the UK.
Where we transfer your Personal Data to a third party outside the EEA or the UK, we will ensure that:a)the recipient destination has been subject to a finding from the European Commission or
has been designated by the government of the UK as ensuring an adequate level ofprotection for the rights and freedoms that you possess in respect of your Personal Data; orb)

the recipient enters into standard data protection clauses that have been approved by theEuropean Commission, or other contracts for the transfer of Personal Data as required bydata protection laws, with us.

7.

Storage Period for Personal Data

We will retain your Personal Data that we collect for the period necessary to process such Personal
Data. However, this doesn’t apply if we are required by law to retain your Personal Data for a longer
period of time, in which case, we will retain it for the period required by law.
8.

Security Control Measures of Personal Data.

We implement the following items and other measures to ensure the safe management of Personal
Data. The followings are examples only and the specific measures for security management to be
implemented may vary depending on the each Personal Data.
a) Establishment of basic policy
We has established and publicly announced its "Basic Policy on the Handling of Personal
Information" for the proper handling of Personal Data.
b) Establishment of regulations regarding the handling of Personal Data etc.
We establish internal rules for the handling of Personal Data for the purpose of appropriateacquisition, storage, use, and management.
c) Organizational safety control measures
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We appoint a person responsible for the handling of Personal Data, clarify the employees
who handle Personal Data, and establish a system for contacting the person responsible in
the event of an accident such as the leakage of Personal Data (including cases where signs
are detected).
d) Security control measures by human factors
We regularly educate and train our employees on matters to keep in mind regarding thehandling of Personal Data, and include matters relating to the confidentiality regarding
Personal Data in our internal regulations.
e) Security management measures by physical factors
When disposing of or deleting Personal Data, we use methods that are difficult to restore,
such as cutting, dissolving or physical destruction.
f)

Security management measures by technical factors
When storing or transferring Personal Data outside us, we take the necessary measures toprevent leakage, such as encryption and setting passwords.

g) Understanding of the external environment
We will take the necessary and appropriate measures to ensure that Personal Data is managed
safely and securely, based on an understanding of the systems for the protection of Personal
Data in the foreign country where the Personal Data is stored.
h) Supervision of employee
We conduct an audit at least once a year to ascertain the status of the handling of Personal
Data by employees, to ensure that it is being operated in accordance with the law and ourinternal regulations, and to promptly make improvements if there are any problems.
i)Supervision of contractors
We conduct audits at least once a year to ascertain the status of the handling of Personal Databy contractors, to ensure that they are operating in accordance with the contract, laws andregulations, etc, and takes the necessary measures if there are any problems.

9.

Your Rights

You have a number of legal rights in relation to the Personal Data that we hold about you. These rights
may vary depending on where you are located and which data protection laws apply to the relationshipbetween you and us, but typically will include the following:a)Right to obtain information regarding the processing of the relevant Personal Data and toaccess the relevant Personal Data that we hold;b)

Right to request rectification of the relevant Personal Data if it is inaccurate or incomplete;c)Right to request erasure of the relevant Personal Data in certain circumstances;

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d)

Right to request that we restrict our processing of the relevant Personal Data in certain
circumstances;e)

Right to object to our processing of the relevant Personal Data;f)Right to receive the relevant Personal Data in a structured, commonly used, and machinereadable format and/or to request that we directly transmit such Personal Data to arecipient where this is technically feasible; andg)Right to withdraw your consent to our processing of the relevant Personal Data at any time(the withdrawal does not affect the lawfulness of processing of Personal Data based onconsent before its withdrawal).

You may exercise any of your rights by contacting us, using the information about us indicated in
Section 9 below. You also may lodge a complaint with the data protection authority if you believe thatany of your rights have been infringed by us.

10. Contact details for Personal Data
For any queries regarding the handling of Personal Data obtained by us, contact the 'Personal Data
Reception Desk' by email or mail. Note that we will not respond to any enquiries other than by thesemethods (including if you visit us in person).
[Personal Data Reception Desk]This contact point is dedicated to enquiries about the handling of Personal Data. Enquiries otherthan about personal information cannot be accepted.
○emailClick here to email us with enquiries about Personal Data.
kojinjyohou_uketsuke@jictransport.co.jp○mail3-4-1 Marunouchi, Chiyoda-ku, Tokyo 100-0005, Japan
Japan International Consultants for Transportation Co., Ltd.
Corporate Planning Headquarters, Personal Data Reception Desk

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