Personal Information Protection Policy (Privacy Policy)

To develop services that meet the diversifying needs of our customers and deliver valuable products to them, we, the Company, are fully aware of our social mission regarding the protection of all personal information handled by us and will comply with laws and regulations regarding the protection of the rights of the individual as well as personal information.

In addition, we hereby declare that we shall establish a personal information protection management system to realize the following policy and will make company-wide efforts to continuously improve the system while constantly recognizing the latest trends in IT technology, changes in social demands, and behaviors in the business environment.

1. Acquisition and Use of Personal Information

   We shall appropriately acquire, use, and provide personal information handled in its e-commerce wholesale business, direct web sales business, mail order wholesale business, product planning, and development business, and other businesses, as well as in its recruitment screening and human resource management. We will not handle personal information beyond the scope necessary to achieve the specified purpose of use. We will also take measures to do so.

2. Compliance with Laws and Regulations

   We shall comply with all laws and regulations, guidelines, and other norms set forth by the government regarding the handling of personal information.

3. Implementation of Safety Measures

   To prevent the risk of leakage, loss, or damage of personal information, we will take reasonable safety measures, inject management resources that correspond to the actual business conditions, and continuously improve the security system for personal information. We will continue to improve the security system for personal information. In addition, we will promptly take corrective measures in the event of an emergency.

4. Complaints and Consultations Regarding the Handling of Personal Information

   We shall respond promptly and sincerely to complaints and consultations regarding the handling of personal information.

5. Continuous Improvement of the Personal Information Protection Management System

   The personal information protection management system shall be reviewed and improved continuously in a timely and appropriate manner based on changes in the environment and the actual conditions surrounding the Company.

This policy shall be made known to all employees, and measures shall be taken to make it available to anyone at any time by posting it on the Company’s website, etc.

Date of enactment: April 24, 2009
Date of last revision: October 1, 2019
NAKAMURA Co. Ltd.
Akira Nakamura, Representative Director

I. Handling of Personal Information

1. Name of Business Owner

   NAKAMURA Co. Ltd.

2. Name, Title, Affiliation, and Contact Information of Administrator (or the representative)

   Administrator name: Miho Mayama, Personal Information Protection Administrator.

3. Purposes of Use of Personal Information

   (1) For the use of personal information obtained directly from the individual in writing, etc. (including through a website, e-mail, etc.; hereinafter referred to as "written documents") and the use of retained personal data.

   Customer Information	To ship products, provide related after-sales services, and introduce new products and services in the e-commerce wholesale business, direct web sales business, and mail-order wholesale business
   Client Information	For business negotiations and various business communications, order placement, and billing and payment operations
   Employee Information	For personnel and labor management, business management, health management, and security management of employees
   Applicant Information	For recruitment
   Inquirer Information	To respond to inquiries

   (2) For use when obtaining personal information from the individual in a manner other than directly in writing.

   Customer Information	For business related to orders and shipments of contracted services
   Business Partner Personnel Information	When acquiring information on subcontractor’s business partner personnel
   Job Applicant Information	For recruiting applicants from Hello Work, Rikunabi, Mynavi, and other job placement websites and recruitment agencies

4. Provision of Personal Information to Third Parties

   We will not provide your personal information to any third party except in the following cases:

   1. When you, the individual, have given consent.
   2. When required by law.
   3. When it is necessary for the protection of the life, body, or property of the individual and it is difficult to obtain the consent of the individual.
   4. When it is particularly necessary for the improvement of public health or promotion of the sound growth of children and it is difficult to obtain the consent of the individual.
   5. When it is necessary for cooperating with a national agency, a local government, or a person or entity entrusted by either a national agency or local government to conduct business prescribed by law and obtaining the consent of the individual is likely to impede the conduct of such business.
   6. When the handling of personal information is subcontracted in whole or in part within the scope necessary to achieve the purpose of use in order to facilitate the smooth conduct of business.
5. Subcontracting of the Handling of Personal Information

   We subcontract part of its business to third parties to provide better service to its customers. We may entrust personal information to these subcontractors, in which case we will select a contractor that is recognized as handling personal information appropriately and will make necessary arrangements in the contract to prevent leakage of customers’ personal information and ensure proper care via the appropriate management and confidentiality of personal information.

6. Request for Disclosure of Personal Information

   As the customer, you may request us to disclose your personal information (i.e., notification and disclosure of the purpose of use; correction, addition, or deletion of content; suspension or deletion of use; or suspension of provision to a third party) to the Company’s Personal Information Inquiry Desk, and we will respond within a reasonable period of time after confirming your identity.

7. Voluntary Nature of Providing Personal Information

   Whether or not you provide us with your personal information is at your discretion. However, if you do not provide us with the required items, we may not be able to provide you with the appropriate services.

8. In Case of Acquisition via a Method Not Easily Recognizable by the Individual

   Cookies are used to make it more convenient for you to browse our website when you visit it again, and they do not infringe on your privacy or have any adverse effect on your computer.

   In addition, our website uses an SSL (Secure Sockets Layer) data encryption system for all fields where personal information is entered. We have adopted measures such as installing firewalls to protect information within the website. However, due to the nature of Internet communication, we cannot guarantee complete security. Thank you for your understanding in advance.

Ⅱ. Guide to Request Procedures for Retained Personal Data

With regard to requests for notification and disclosure of the purpose of use; correction, addition, or deletion of content; suspension or deletion of use; or suspension of provision to a third party (hereinafter referred to as "Request for Disclosure, etc.") from the individual or the representative concerning personal data held by the Company, the following procedures shall be taken using the request form prescribed by us.

1. Requests for Disclosure, etc.

   Requests for Disclosure, etc. should be addressed to the Complaints and Inquiries Office on Personal Information by mail, enclosing the prescribed request form by the Company, necessary documents, and fee amount.

2. Documents to be Submitted when Making a Request for Disclosure, etc.

   When making a Request for Disclosure, etc., please fill in all the prescribed items on the request form in (1) above and mail it to us. The following request form will be sent to you by mail. To confirm your identity, you will need to enclose a copy of one of the identification documents listed in (iv) below.

   (1) Request form prescribed by the Company:

   1. For notification of purpose of use
      Request Form for Disclosure of Retained Personal Data, etc.
   2. For disclosure
      Request Form for Disclosure of Retained Personal Data, etc.
   3. For correction, addition, or deletion of content; suspension or deletion of use; or suspension of provision to a third party
      Request Form for Disclosure, etc. of Retained Personal Data.
   4. Driver’s license, passport, health insurance card, resident card, basic resident register card, residence card or special permanent resident card, My Number Card (front), or any other official document that can verify the identity of the individual.

      *Please note that the domicile information should be limited to the prefecture, and any information beyond that should be blacked out.

3. In the Case of a Request for Disclosure, etc. by a Representative

   If the person making the Request for Disclosure, etc. is a representative, please enclose a copy of one of the documents proving that you are the representative described in (1) of 3 below and a copy of one of the documents proving your identity described in (2) of 3 in addition to the documents in (1) of 2.

   (1) Documents proving that the person is a representative:

   <For representatives authorized by the individual to make a Request for Disclosure, etc.>

   1. A letter of attorney (original) from the individual.

   <If the representative is a legal representative of a minor>

   1. A copy of the family register.
   2. Certificate of residence. (showing the relationship between both parties)
   3. Other official documents that can confirm the right of legal representation.

   <If the representative is a legal representative of an adult ward>

   1. Certificate of registered matters concerning guardianship registration, etc.
   2. Other official documents that can confirm the authority of legal representation.

   (2) A copy of a document certifying the representative’s identity

   1. Driver’s license, passport, health insurance card, resident card, basic resident register card, residence card or special permanent resident card, My Number Card (front), or any other official document that can verify the identity of the individual.

   *Please note that the domicile information should be limited to the prefecture, and any information beyond that should be blacked out.

4. Fees for Request for Disclosure, etc. and its Collection Method

   The following amount (including the cost of our reply) will be charged per request only in the case of a request for notification or disclosure of the purpose of use.

   Please enclose a fixed postal money order for the following amount when you mail the request form.
   Fee amount: 10 USD

5. How to reply to a Request for Disclosure, etc.

   In principle, a response will be sent in writing (by post in a sealed envelope) to the address of the individual as stated in the request form.

   - Personal information obtained in response to a Request for Disclosure, etc., will be handled only to the extent necessary to respond to the request for disclosure, etc.

   - In the following cases, we may not be able to respond to your Request for Disclosure, etc., in which case we will notify you to that effect and the reason.
   Please note that a fee will also be charged for non-disclosure.

   1. When the identity of the individual or representative cannot be confirmed.
   2. When there is a deficiency in the prescribed application documents.
   3. When the subject of the Request for Disclosure, etc. does not fall under the category of Retained Personal Data (*)
   4. When notifying the individual of the purpose of use or publicly announcing it may harm the life, body, property, or other rights or interests of the individual or a third party.
   5. When notifying the person of the purpose of use or publicly announcing it is likely to harm the rights or legitimate interests of the Company.
   6. When it is necessary to cooperate with a national agency or local public body in conducting business prescribed by law, and in which notifying the individual of the purpose of use or publicly announcing it is likely to impede the conduct of such business.

      *Retained Personal Data is personal information that constitutes a systematic collection of information, and for which the Company has the authority to respond to all requests from the individual for notification and disclosure of the purpose of use; correction, addition, or deletion of content; suspension or deletion of use; or suspension of provision to a third party.

      However, if any of the following a) to d) applies, it shall not fall under the category of retained personal data:

      1. Where disclosure of the existence or non-existence of personal information to cause harm to the life, body, or property of the individual or a third party.
      2. Where disclosure of the existence or non-existence of personal information is likely to encourage or induce illegal or unjust acts.
      3. Where disclosure of the existence or non-existence of personal information is likely to cause harm to national security, damage the relationship of trust with other countries or international organizations, or cause disadvantages in negotiations with other countries or international organizations.
      4. Where disclosure of the existence or non-existence of personal information is likely to disturb the prevention, suppression, or investigation of crimes or the maintenance of public safety.