Privacy Policy

This English text is a translation provided for reference only. In the event of any discrepancy, the original Japanese version shall prevail. Please refer to the Japanese Privacy Policy for the authoritative text.

1Introduction

CMC XMANICOM CO., Ltd. (hereinafter "the Company") fully recognizes the importance of the personal information of our customers and of individuals generally, and establishes and operates the following policy on its handling.

2Scope of application

This Privacy Policy applies when you provide personal information to the Company and when you use the Company's products and services.

3Basic policy on the protection of personal information

The Company complies with the laws and regulations of Japan relating to the protection of personal information, with guidelines and other norms established by national and administrative bodies, and with its own corporate ethics.
The Company appoints a personal information protection manager as part of its protection framework and makes its management structure clear. It also ensures that internal standards relating to the protection of personal information are fully communicated to all employees.
The Company handles personal information within the scope of the purposes of use disclosed to the individual concerned. It does not disclose or provide entrusted personal information to third parties except with the consent of the individual or where there is legitimate reason to do so, such as under laws and regulations.
The Company takes appropriate safety management measures to prevent leakage, unauthorized access, loss, destruction, damage, or falsification of personal information, and takes corrective action as necessary.
The Company provides employees with ongoing information security education, including training regarding the protection of personal information.
The Company responds appropriately and in accordance with laws and regulations to enquiries, complaints, consultations and disclosure requests concerning personal information received from the individual concerned.
The Company establishes, maintains and continually improves a framework for the protection of personal information based on the above.

4Purposes of use of personal information and handling within those purposes

The Company collects and handles personal information it already holds and personal information it acquires in the future within the scope of the purposes of conducting the activities set out below.

Main data subjects	Main activities
Users of products and services	Promoting the Company's businesses (manuals, training and education support, automotive technical support, DX tools) Gathering, providing and exchanging information relating to the Company's businesses, products and services Conducting, analyzing and responding to market research (surveys and the like), and using it for marketing, sales promotion and sales activities, including sending materials Planning, running and following up exhibitions, events and training sessions Building, maintaining and improving business processes Responding to and holding meetings on questions, enquiries and requests Exchanging information within the Company's group and conducting group training in relation to the above
Employees of business partners	Communications relating to the performance of work Accounting administration for business expenses Providing information and communications on our businesses, products and services Sending greetings, letters of thanks and announcements
IR-related parties	Providing information to, and exchanging information with, shareholders and investors
Job applicants	Communications regarding applications, information sessions and selection schedules Evaluation for selection purposes and communication of selection results Guidance on joining procedures * Personal information may be acquired and handled via the services of recruitment companies.
Employees (the Company's officers and staff)	Communications relating to the performance of work General affairs, human resources and labor administration [employee benefits, various insurance procedures, salary payment, attendance management, occupational health and safety (including health management), etc.] Emergency communications Internal communication (exchanging information, sharing facial data, sharing information in company newsletters, etc.) External communication (sharing contact details with external organizations and individuals, sharing facial data, introducing the working environment and how work is carried out on recruitment sites and elsewhere)
Personal contacts of current employees	Emergency communications Guaranteeing the identity of current employees
Former employees	Administration relating to former employees as required by law

* Personal information acquired from outsourcing clients or third-party providers is used within the scope of performing the contract with that client or provider.

5Handling personal information for purposes other than those stated

Where the Company handles personal information for purposes other than those set out in this Privacy Policy, it will, on each occasion, establish as necessary a privacy policy suited to that purpose, communicate or publish it to the individual concerned, and only then acquire and handle the personal information.

6Personal information collected

For the personal information we collect, please see "Personal information collected".

7Choice by the individual

In principle, the provision of personal information to the Company by customers and other individuals is a matter for the individual's own decision. However, if an individual does not provide personal information, they may be unable to use some or all of the products and services the Company provides.

8Supervision of contractors

In carrying out the stated purposes of use, the Company may entrust the handling of personal information to third parties. In such cases, the Company evaluates and selects the third party in advance, concludes a confidentiality agreement, and exercises the necessary supervision over the contractor.

9Shared use

The Company may share entrusted personal information with its group companies.

1Scope of parties sharing the information	The Company's group companies in Japan
2Purposes of use by the parties sharing the information	The same as the purposes of use set out in Section 4
3Items of personal information shared	Name, address, telephone number and other contact details, together with personal information and ICT-related information relevant to carrying out the purposes of use in relation to the Company's products and services
4Personal information protection manager of the organization sharing the information	The Company's personal information protection manager
5Method of acquiring the shared personal information	In writing, via ICT services (e-mail, websites, social media, etc.), and verbally

Where personal information is shared with parties other than the Company's group companies, the Company will, on each occasion, clarify and communicate or publish the following matters.
[Matters clarified and communicated or published for shared use]
- Scope of parties sharing the information
- Purposes of the shared use
- Items of personal information shared
- Personal information protection manager of the organization sharing the information
- Method of acquiring the shared personal information

10Provision to third parties

The Company does not disclose entrusted personal information to third parties without the consent of the individual concerned; however, it may provide personal information to third parties in the following cases. Note that providing personal information through outsourcing, or through shared use, does not constitute provision to a third party under this section.

Where the consent of the individual has been obtained
Where required by laws and regulations
Where necessary to protect the life, body or property of a person and it is difficult to obtain the individual's consent
Where it is necessary to cooperate with a national government body, a local government or a party entrusted by them in performing duties prescribed by law, and obtaining the individual's consent risks impeding the performance of those duties
Where statistical data processed so that individuals cannot be identified is provided or disclosed
Where personal information is provided in connection with the succession of a business due to a merger, company split, business transfer or other reason

11Transfer of personal information outside Japan

Where the Company provides personal information to a third party outside Japan (including contractors and parties engaged in shared use), it takes the measures required under the relevant laws and regulations.

12Use of data processed so that individuals cannot be identified

The Company may create data processed so that individuals cannot be identified on the basis of the personal information it has collected. After verifying that the processed data cannot identify individuals, the Company may provide it to third parties or use it without restriction in its business.

13A request to customers under 16 years of age

If you are under 16 years of age, please provide personal information to the Company only with the consent of a parent or guardian.

14Enquiries and requests concerning the handling of personal information

Where, at the request of the individual concerned, the Company discloses, changes, adds to, suspends the use of, deletes or erases personal information provided to it, and where it responds to opinions, enquiries, complaints or consultations regarding its handling of personal information, it does so appropriately and in accordance with laws and regulations.

However, the Company may be unable to comply with a request as made where doing so would significantly impede the conduct of its ordinary business, or where there is a risk of contravening laws and regulations.

15How to make enquiries and requests, and our contact point

For how to make enquiries and requests concerning the handling of personal information, and for our contact point, please see "Enquiries concerning personal information".

16Other privacy policies

In addition to this Privacy Policy, the following privacy policies are established.

Privacy policies governing personal information handled on websites and applications relating to individual products, services or businesses of the Company are set out in the terms of use of the relevant website or application.

17Changes to this Privacy Policy

The Company may change this Privacy Policy. Any changes will be posted on the Company's website, so please check the revised policy.

18Continual improvement

The Company establishes, maintains and continually improves a framework for the protection of personal information based on the above.

Our group companies (in Japan)

C.M.C. Co., Ltd.
CMC Solutions Co., Ltd.
Main Co., Ltd.
CMC XMEDICA CO., Ltd.
Fuchu Jidosha Co., Ltd.
Fit Co., Ltd.
Dreams Design Co., Ltd.

Personal information collected

The personal information the Company collects in order to carry out the purposes of use is set out below. The Company acquires and handles personal information by proper and fair means, in accordance with this Privacy Policy.

Basic information	Name
Personal information relating to business-to-business (BtoB) work	Workplace and other contact details (organization name, department, address, telephone number, fax number, e-mail address, social media IDs, etc.) Information relating to the accounting treatment of business expenses (bank account details, etc.) Information relating to the work, products and services associated with the individual (Where necessary for business purposes) photographs of the face, career history, qualifications held and other competency information (Where necessary for visitors from overseas) passport number and visa information
Personal information relating to business with individuals (BtoC)	Home and other contact details of the individual (address, telephone number, fax number, e-mail address, social media IDs, etc.) Information relating to the accounting treatment of business expenses (bank account details, etc.) Information relating to the work, products and services associated with the individual (Where necessary for business purposes) photographs of the face, career history, qualifications held and other competency information (Where necessary for visitors from overseas) passport number and visa information
ICT-related information	Where you use websites or applications relating to the Company or to its products and services, we may acquire the following personal information and personal-related information: Cookies, IP addresses, web beacons, tracking tags, subscriber-specific IDs of mobile devices, and social media or service IDs Usage status and behavioral log information relating to products and services
Personal information of job applicants	Résumé information of job applicants (home address, gender, telephone number, e-mail address, educational background, work history, qualifications, training, self-introduction and similar information) Facial image data (for recruitment purposes) Information relating to the accounting treatment of travel and accommodation expenses (bank account details, etc.)
Personal information of employees	The following information relating to employees: Résumé-type information (home address, telephone number, e-mail address, educational background, work history, qualifications, training, self-introduction information) Accounting-related information (salary payment account details, etc.) Human resources and labor administration [employee benefits, salary payment, attendance management, occupational health and safety (including health management), etc.] Family information, accounting-related information and emergency contact details required for statutory welfare administration My Number (individual number), passport number and visa information Facial image data (photographs, video, etc.) Third-party information required for identity guarantees Information relating to work, products and services in which the individual is involved or with which they are associated
Contract and dispatched staff	The following information relating to contract and dispatched staff: Résumé information (home address, telephone number, e-mail address, educational background, work history, qualifications, self-introduction information) Human resources and labor administration (attendance management, etc.) Emergency contact details (in preparation for major disasters, sudden illness and the like) Information relating to work, products and services in which the individual is involved or with which they are associated

Special care-required personal information

Except where the consent of the individual has been obtained or where required by laws and regulations, the Company does not acquire or use special care-required personal information (information requiring particular care in its handling so as not to cause unfair discrimination, prejudice or other disadvantage to the individual, such as race, creed, social status, medical history, criminal record, or the fact of having suffered harm from a crime).

Enquiries concerning personal information

Enquiries concerning personal information
Please direct enquiries concerning personal information to the contact point below.

Personal information enquiry desk

Corporate Planning Department, CMC XMANICOM CO., Ltd.
3-11-9 Ginza, Chuo-ku, Tokyo 104-0061, Japan

The personal information you submit will be used to respond to your enquiry and for no other purpose. Please make your enquiry only if you agree to the above.

For our handling of personal information, please see the Privacy Policy.
How to make an enquiry
Please send the required documents by post.
Identity verification
If you make an enquiry about personal information held by the Company, we will verify that you are the individual concerned. Please send the following documents by post with your enquiry.
- (1) Identity verification documents
  Copies of any two of the following: driver's license, health insurance card, passport, pension book
Fees
A fee of JPY 1,000 (excluding tax) will be charged per request.

Handling of cookies and similar technologies on this website

Handling of information on this website

Encryption of communications	Where individuals provide personal information, we protect that information using communication encryption technologies such as SSL (Secure Sockets Layer) / TLS (Transport Layer Security) on the relevant website. Please note that if you use a browser that does not support SSL/TLS, you may be unable to access the page in question.
Use of cookies, IP addresses and web beacons, and mobile device identifiers	This website may acquire and use access data through cookies, IP addresses, web beacons and mobile device identifiers, in order to understand and improve how the site is used.
Personal information collected	The personal information collected on this website is set out in "Personal information collected".
Points to note when using our services	Choice by the individual
Use of Google Analytics	This website uses Google Analytics, a service provided by Google, in order to understand how the site is used. Google Analytics uses cookies obtained from the Company to analyze how this website is used; the Company obtains the results of that analysis and uses them to understand how the site is used. Google Analytics Terms of Service https://marketingplatform.google.com/about/analytics/terms/us/ Google Privacy Policy https://policies.google.com/privacy?hl=en Google Analytics Opt-out Browser Add-on (allows website users to disable the use of data by Google Analytics JavaScript — analytics.js and gtag.js) https://tools.google.com/dlpage/gaoptout?hl=en

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