Article 1 (Personal Information)

“Personal Information” under this Policy refers to “personal information” as defined by the Privacy Laws. Specifically, it means any information relating to a living individual that can identify them, either directly (such as by name, date of birth, or other descriptions) or indirectly (including any individual identification codes).

Article 2 (Purpose of Use of Personal Information)

We may acquire and use Personal Information for the purposes set forth below. If we seek to use your Personal Information beyond the scope of these purposes, we will obtain the prior consent of the individual concerned (meaning customers and other data subjects; hereinafter referred to as “you”) by appropriate means.

1. Information Acquired from SkyDrive Group’s Customers and Business Partners
   1. ① To respond to and handle inquiries and consultations directed at SkyDrive Group;
   2. ② To provide SkyDrive Group’s products and services, including their planning, research, development, manufacturing, sales, management, and leasing;
   3. ③ To conduct advertising, publicity, and sales promotion activities for SkyDrive Group’s products and services;
   4. ④ To accept applications for SkyDrive Group’s products and services, and to provide such services;
   5. ⑤ To review and fulfill contracts between SkyDrive Group and its business partners;
   6. ⑥ To facilitate internal business communications within SkyDrive Group;
   7. ⑦ To facilitate emergency contact and provide information to business partners;
   8. ⑧ To handle administrative matters regarding SkyDrive Group’s shares, shareholders, creditors, and other related parties; and
   9. ⑨ To perform other operations related or incidental to any of the preceding items.
2. Information Acquired from Applicants for Employment with SkyDrive Group
   1. ① To provide recruitment and employment information, and to communicate with individuals who are interested in or have applied for employment; and
   2. ② To conduct screening and selection processes for hiring.
3. Information Acquired from SkyDrive Group’s Employees and Retirees
   1. ① To manage employment and personnel matters for SkyDrive Group’s employees;
   2. ② To conduct discussions and reviews necessary for the appropriate placement and assignment of employees within SkyDrive Group; and
   3. ③ To handle various procedures and communications following an employee’s retirement.

Article 3 (Management and Protection of Personal Information)

We will appropriately manage Personal Information as outlined below. Except in emergencies or as permitted by applicable laws and regulations we will not disclose or provide Personal Information to any third parties without your prior consent. We will take necessary and appropriate measures to secure Personal Information against risks such as leakage, unauthorized use, or computer viruses.

1. We will establish an organizational structure for the appropriate management of Personal Information, thoroughly disseminate this Policy and related internal regulations to all directors, Audit & Supervisory Board members, officers, and employees (including full-time, part-time, contract, temporary, and seconded employees, and all other individuals with an employment relationship or equivalent with SkyDrive Group), and strive to handle Personal Information appropriately in our day-to-day business operations.
2. We will designate a Personal Information Protection Management Officer, clarify their role, and ensure proper control and management of Personal Information.

Article 4 (Entrustment of Personal Information Handling)

We may entrust third-party subcontractors to handle Personal Information, in whole or in part, to the extent necessary to achieve the purposes of use mentioned herein. In such cases, we will carefully examine the eligibility of the subcontractors, obligate them to maintain confidentiality by contract, and conduct necessary and appropriate supervision over them.

Article 5 (Joint Use of Personal Information)

SkyDrive Group entities may jointly use Personal Information acquired by any of SkyDrive Group entities for the purposes mentioned in Section 2 (Purpose of Use of Personal Information), under the management responsibility of each respective SkyDrive Group entity that holds the Personal Information. Such Personal Information may include, without limitation, your name, phone number, email address, affiliation, department, and job title (and in the case of recruitment activities and talent acquisition, personal information such as address, skills, experience, education, and career background).

Article 6 (Requests for Disclosure, Correction, Suspension of Use, and Erasure)

When you request SkyDrive Group to disclose, correct, cease the use of, or erase Personal Information retained by SkyDrive Group, or when you lodge a complaint with us, we will respond appropriately in accordance with applicable laws, regulations, and our internal procedures. In addition, you may withdraw your consent to the handling of Personal Information at any time.

Article 7 (Procedures for Amending the Privacy Policy)

We will review the content of this Policy from time to time and endeavor to improve it. The content of this Policy may be amended unless otherwise provided by applicable laws and regulations or this Policy. The amended Policy will become effective from the specified effective date after we notify you or publicly announce the changes in advance by appropriate means.

Article 8 (Compliance with Privacy Laws, Regulations, and Rules)

We will comply with Privacy Laws and other applicable rules. Safety management measures for specific Personal Information (My Number data) are set out in separate internal rules titled the “Rules on Handling Specific Personal Information and Employment Management Information.”

Article 9 (Security Measures)

To protect the Personal Information provided by you from unauthorized access, loss, destruction, falsification, leakage, and other risks, we strive to implement organizational, physical, personnel, and technical security measures. These include restricting access to Personal Information files, maintaining access logs, and implementing security measures to prevent unauthorized external access.

Article 10 (Address, Representative, and Personal Information Protection Management Officer)

The registered address of SkyDrive as the entity responsible for this Policy, its representative, and the Personal Information Protection Management Officer are as follows:

Address: 1-3-13, Hirakawacho, Chiyoda-ku, Tokyo 102-0093, Japan

Representative: Tomohiro Fukuzawa, Representative Director, SkyDrive Inc.

Personal Information Protection Management Officer: Tomohiro Fukuzawa, CEO, SkyDrive Inc.

Article 11 (Contact)

For inquiries concerning the handling of Personal Information at SkyDrive Group, please contact: