ENCORED JAPAN

PRIVACY POLICY

ENCORED JAPAN Privacy Policy

1. Handling of personal information

Compliance with laws, regulations and norms concerning the protection of personal information

ENCORED JAPAN Inc. (hereinafter referred to as “ENCORED”, “we”, “our” or “us”) will comply with laws and regulations, guidelines established by the national government, and other standards concerning the handling of personal information.

Specification of purpose of use

When handling personal information, we will specify the purpose of use of the personal information to the extent possible.

Purpose of use of personal information

For the purpose of providing energy big data services, etc., we will use, share and provide to a third party personal information within the scope necessary to achieve the following purposes of use. We will not collect personal information through fraud or other improper means:

To respond to inquiries from customers, provide guidance on procedures and information related to the use of our services and other customer support.
To calculate charges and fees.
To prevent unauthorized use of our services.
To improve the convenience and quality of our services, research and develop new services, and conduct various marketing surveys and analyses for the above purposes.
To develop statistical data and use analytical results for business analysis.
To distribute and display advertisements of ENCORED and other companies, including the introduction of products, services and campaigns of ENCORED and other companies, and optimize such distribution and display.
To provide support services in relation to our services such as work, maintenance, repair of terminal equipment failure, and troubleshooting including software update, etc.
To perform other services necessary for providing our services and any services incidental thereto.
To provide information to and contact applicants in recruitment and hiring activities.
To perform duties related to human resources management.
To process other affairs relating to the foregoing.
If we use personal information for any purpose other than the above, we will clearly indicate the purpose of use in advance when collecting the personal information.

Restrictions on purpose of use

We will not handle personal information beyond the scope necessary to achieve the purpose of use without obtaining the consent of the relevant individual.
However, this does not apply in the following cases:

Cases where it is based on laws and regulations.
Cases where it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of such individual.
Cases where it is specially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the relevant individual.
Cases where it is necessary for cooperating with a state organ, a local government, or an individual or an entity entrusted by either of the former two in executing the affairs prescribed by laws and regulations and obtaining the consent of the relevant individual is likely to impede the execution of the affairs concerned.

Restrictions on provision to third parties

ENCORED will not provide personal information to any third party without obtaining the consent of the relevant individual, except in the following cases:

Cases where it is based on laws and regulations.
Cases where it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of such individual.
Cases where it is specially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the relevant individua.
Cases where it is necessary for cooperating with a state organ, a local government, or an individual or an entity entrusted by either of the former two in executing the affairs prescribed by laws and regulations and obtaining the consent of the relevant individual is likely to impede the execution of the affairs concerned.

In following cases, the individual or entity receiving personal information shall not be deemed a third party referred to above:

Cases where we outsource the handling of personal information in whole or in part within the scope necessary to achieve the purpose of use.
Cases where personal information is provided as a result of the succession of business in a merger or otherwis.
Cases where personal information is shared with specific individuals or entities and where such fact as well as the items of personal information to be shared, the scope of joint users, the purpose for which the personal information is used by the users and the name or designation of a person responsible for the management of the personal information are informed to the relevant individual in advance or put in a readily accessible condition for the individual.

Purpose of use of employees’ personal information

The Company will use the following personal information for the respective purposes as follows:

1.Purpose of use of personal information of executives and employees

Item	Details	Purpose of use
Internally disclosed information	Name, employee ID number, department, title, employment status, company e-mail address, information on work terminal	For business communication
Basic information	Name, address, age, date of birth, sex, phone number, face photograph	For employment & HR management, assignment (including secondment/relocation), creation of staff register, payment of salary, provision of benefit packages, social insurance-related procedures, legally required procedures and other employment management
Pay-related information	Method to determine payment of annual and monthly earnings and bonus, retirement allowance	For determining payment of salary, tax withholding procedures, social insurance-related procedures, retirement allowance and benefit packages, asset formation, and other employment management
HR information	Performance evaluation, educational background, qualifications/licenses, title, professional background, disciplinary punishments/official commendations	For understanding human resources, decisions related to postings/assignment of responsibilities, secondment/relocation, training/skill development, promotion/demotion, and other employment management
Family and relative information	Family structures, living-together/separated status, presence of dependents, health conditions	For determining payment of salary, tax withholding procedures, social security-related procedures, baby-care/nursing care leave, benefit packages, and other employment management
Physical and health information	Health condition, medical records, physical or mental disabilities, results of health checkups	For healthcare, ensuring an appropriate labor environment, leaves of absence, determining postings, management of working hours, and other employment management

2.Purpose of use of applicants’ personal information

Item	Details	Purpose of use
Basic information	Name, address, age, date of birth, sex, phone number, face photograph	For considering and determining whether to offer employment, considering and determining employment conditions, responding to inquiries, and business communications
Pay-related information	Method to determine payment of annual and monthly earnings and bonus, retirement allowance
HR information	Educational background, qualifications/licenses, title, professional background
Family and relative information	Presence of dependents

3.Purpose of use of retired employees’ personal information

Item	Details	Purpose of use
Basic Information	Name, address, age, date of birth, sex, phone number, face photograph	For creation of HR data and communication after retirement
Pay-related information	Method to determine payment of annual and monthly earnings and bonus, retirement allowance
HR information	Performance evaluation, educational background, qualifications/licenses, title, professional background, disciplinary punishments/official commendations
Family and relative information	Family structures, living-together/separated status
Physical and health information	Health condition, medical records, physical or mental disabilities, results of health checkups

In the event that the Company intends to use the personal information of the types of employee above for purposes other than those above, the Company will make clear the purpose of use and obtain prior consent from the relevant employee(s).

Shared use

The Company may share the use of the following employee personal information for the following purposes.

（1）Shared use for business communication purposes

Shared use item	Internally disclosed information in employees, etc.
Scope of shared users	SoftBank Group Corp., other SoftBank Group companies (“shared users”), and companies (including subcontractors) which have concluded outsourcing agreements with joint users
Purpose of use by shared users	For business communication
Parties responsible for shared use	Head of Human Resources, ENCORED.

（2）Shared use for business operation

Shared use item	Items necessary to achieve the following purposes of use in relation to employees’ personal information
Scope of shared users	SoftBank Group Corp., SB Atwork Corp., other SoftBank Group companies, companies with secondment agreements, health insurance societies, companies handling employee benefit packages, and the labor union
Purpose of use by shared users	Service support necessary in the course of business for employment management, benefit packages
Parties responsible for shared use	Head of Human Resources, ENCORED.

Sharing of personal information

We may share personal information with our group companies in order for our group to provide comprehensive services. When sharing personal information, we will clearly indicate in advance at the time of collecting the personal information, the items of personal information to be shared, the scope of joint users, the purpose for which the personal information is used by the users and the name or designation of a person responsible for the management of the personal information.

Security management measures

We will take security management measures necessary to protect personal information.

Supervision of employees and contractors

In order to ensure the secure management of personal information, we will exercise necessary supervision over our employees who handle personal information and subcontractors to whom we outsource the handling of personal information in whole or in part.

Comments and consultations on personal information

We will respond to requests for, and comments and consultations on, disclosure, correction, deletion, suspension of use, etc. of the personal information based on laws and regulations and internal regulations.

2.How to contact us about disclosure or correction, etc. of personal information

(1) Procedures for notification of purpose of use, or disclosure, correction, or suspension of use, etc. of personal information

Please contact the inquiry desk regarding a request for “Notification of Purpose of Use”, “Disclosure”, “Correction” or “Suspension of Use”, etc. We will send an application form and the procedure guide.

When you make an application, you will be required to submit your completed application form and identification document(s) designated by ENCORED. In addition, in the case where an application is made by your proxy, identification document(s) of your proxy will also be required. Please check the procedure guide for details.
We will respond to your application after confirming the submitted documents and your identity. If we are unable to accept the application, we will promptly inform you of the reason.

(2) Fees and payment method

A fee of 1,000 yen (postal money order) will be charged per application for notification of purpose of use and disclosure of personal information.

Any revision of our “Handling of Personal Information” will be posted on the ENCORED website.

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