Handling of Personal Information

Privacy Policy

APASYS Co., Ltd. (the “Company”) recognizes that the proper handling of all personal information, including information concerning customers, business partners and employees, is a social responsibility. We have established the following privacy policy and require all officers and employees to comply with it in order to protect personal information.

1. When collecting personal information, we specify its intended purposes and use or provide it only within the scope of those purposes.
2. We collect personal information through lawful and fair means, with notification to or consent from the individual concerned.
3. We manage the personal information we hold so that it is relevant to the intended purposes, accurate, complete and up to date.
4. We manage collected personal information appropriately and take measures to prevent and remedy unauthorized access, loss, destruction, alteration and disclosure, seeking to maintain adequate security.
5. We work to keep personal information accurate and up to date, and to prevent, remedy and mitigate unauthorized access, loss, destruction, alteration and disclosure.
6. When handling personal information, we identify its purposes of use, categories, responsible administrator and recipients.
7. When we receive a request concerning personal information, we verify the requester's identity in accordance with our procedures and disclose the information without delay, except where laws or regulations provide otherwise. If the disclosed information is found to be inaccurate, we promptly correct it or suspend its use. We also respond appropriately and promptly to objections concerning the handling of personal information.
8. We recognize the importance of protecting personal information and are accountable for compliance with applicable laws, government guidelines and other standards. We establish internal rules and a management structure for personal information protection and improve them continuously.

Established September 27, 2026
APASYS Co., Ltd.
Representative Director and President: DUAN DAHAI

Handling of Personal Information

We manage and protect personal information concerning customers, business partners, job applicants and employees in accordance with our Privacy Policy.

Our specific handling practices are set out below.

1) Personal Information Collected and Collection Methods

The personal information we collect (A) and our collection methods (B) are as follows.

A. Personal Information Collected

1. Information concerning customers and business partners, and personal information entrusted to us in the course of contracted services (collectively, “customer-related personal information”), such as company name, department, name, address, telephone number and email address
2. Job applicant information, such as name, date of birth, address, telephone number, education and employment history
3. Employee information, such as name, date of birth, address, telephone number, employment history and family composition
4. Individual Numbers (My Number) of employees and other relevant persons

B. Collection Methods

1. Direct collection from the individual in writing or through a web form
2. Direct collection from the individual in writing
3. Collection directly from the individual or an authorized representative after identity verification

2) Purposes of Use

Pursuant to Article 21(1) of Japan's Act on the Protection of Personal Information and JIS Q 15001:2023, we announce that personal information will be used within the scope of the purposes set out below.

If we need to use personal information beyond purposes previously specified or announced, we will notify the individual concerned and obtain consent before doing so.

A. Customer-Related Personal Information

1. Responding to inquiries and requests
2. Billing, payments, contract administration and business communications
3. Other purposes notified in advance and agreed to by the individual concerned

B. Job Applicant Information

1. Providing and communicating recruitment information
2. Assessing job applications
3. Purposes incidental to the above

C. Employee Information

1. Personnel and labor management, including performance reviews, assignments (including secondment and transfer), training and recruitment
2. Compensation administration, including salary and bonus decisions and retirement benefit payments
3. Health management, including medical examinations and health guidance
4. Employee benefit administration, including employee savings schemes and arrangements for discounts on Company products
5. Security management, including crime prevention, disaster preparedness and occupational health and safety
6. Business administration, including work-related communications, report preparation and postings on groupware

D. Employee Individual Numbers (My Number)

1. Procedures for acquiring or confirming pension eligibility and receiving benefits
2. Procedures for acquiring or confirming employment insurance eligibility and receiving benefits, including administrative procedures at Hello Work and similar bodies
3. Medical insurer procedures, including collection of health insurance premiums; welfare benefit administration; public assistance; and other administrative measures for low-income persons
4. Inclusion in tax returns, notifications and statements submitted to tax authorities, and use in the authorities' internal administration
5. Other social security, local tax, disaster prevention and similar administrative matters specified by local government ordinances

Joint Use

Within the purposes described above, we may jointly use necessary information such as names, company names and addresses. In such cases, the Company is responsible for the appropriate management of that personal information.

Before joint use, we specify the information categories, scope of users, purposes of use and party responsible for management.

Security Measures

We appoint an administrator responsible for personal information and manage it internally in accordance with applicable laws. We also take appropriate security measures against foreseeable risks, as described below.

1. Basic Policy

   We establish basic policies on compliance with applicable laws and guidelines, complaint handling and related matters to ensure the proper handling of personal data.

2. Handling Rules

   We establish basic procedures for the collection, use, storage and other handling of personal data.

3. Organizational Safeguards

   Responsible personnel verify that personal data is handled in accordance with established procedures. We maintain reporting and communication channels between employees and those responsible.

4. Personnel Safeguards

   We provide employees with regular training on precautions for handling personal data.

5. Physical Safeguards

   We control access to areas where personal data is handled, restrict devices brought into those areas and prevent unauthorized persons from viewing personal data.

6. Technical Safeguards

   We identify the devices and employees authorized to handle personal data to prevent unnecessary access.

7. Understanding External Environments

   Where personal data is stored overseas, we implement security measures with an understanding of the relevant country's personal information protection framework.

Provision of Personal Information

We do not disclose or provide personal information to third parties except in the following circumstances.

1. Where the individual concerned has consented
2. Where required or permitted by law
3. Where necessary to protect a person's life, health or property and obtaining consent is difficult
4. Where personal information processing is outsourced within the scope necessary to achieve the purposes of use
5. Where a business is succeeded through merger, company split, business transfer or other circumstances

Requests Concerning Retained Personal Data and Third-Party Provision Records

We accept the following requests concerning notification of purposes, disclosure, correction, suspension of use and other handling of retained personal data, as well as disclosure of records of provision to third parties. Please contact our complaints and inquiries desk to submit a request.

1. Notification of purposes of use
2. Disclosure
3. Correction of information
4. Addition or deletion of information
5. Suspension of use
6. Deletion and suspension of provision to third parties

Identity Verification Documents

We verify the identity of the individual or representative using documents or details such as a driver's license, health insurance card, date of birth, address and telephone number. The following representatives may submit requests.

• A legal representative of a minor or an adult ward
• A representative authorized by the individual to make the request

Disclosure Request Fee

For a disclosure request, a fee of JPY 1,000, including applicable consumption tax, is payable when the application is accepted.

If the personal information we disclose is found to be inaccurate, we will promptly refund the fee.

Personal Information Inquiries

For questions about your personal information or this Privacy Policy, please contact our complaints and inquiries desk.

Complaints and Inquiries Desk