Handling of personal data

Privacy Policy

ARKRAY, Inc. and its affiliated group companies (ARKRAY Marketing Inc., ARKRAY Global Business, Inc., ARKRAY Factory, Inc., ARKRAY Infinity, Inc., Karada Lab, Inc., ARKRAY GLOBAL BUSINESS Inc.: hereinunder, "our group", "we") hereby establishes its personal data protection policy and creates mechanisms for personal data protection. In order to acquire and maintain the trust of clients and employees (including retired employees) and our related parties, our group will abide by the following policies and strive to ensure awareness among all employees of the importance of personal data protection.

1.Definition of personal information

"Personal information" is defined as information which can be used to identify an individual as under Japan's "Act on the Protection of Personal Information" and includes information such as a person's name, age, date of birth, telephone number, e-mail address, street address, place of employment, account number, information pertaining to purchased products and services, information pertaining to inquiries made, personal identification numbers, etc.

2.Basic policy for personal data protection management

1. We will carry out the collection / acquisition, use and provision of personal information in an appropriate manner.
2. We will endeavor to ensure that personal data only includes correct and up-to-date information.
3. We will put necessary and appropriate measures in place to prevent unauthorized access, loss, leakage, destruction or damage to personal data.
4. We will comply with laws concerning personal information as well as guidelines and internal regulations.
5. In instances where the handling of personal data is outsourced to external parties, only parties who meet the requirements of our group's regulations will be chosen as outsourcees, and appropriate management will be performed.
6. We will continue to make improvements to protect personal information.

3.Purpose of use of personal information

In the course of our group's business activities (the production of and distributor services for medical devices, health care IT; the creation and sale of software; and the provision of various online services) the personal information which we ask to be provided will be used for the following purposes in accordance with the law and our group's internal regulations. In addition, we will provide explanations in advance about the provision of private information, whether or not it is outsourced, and how to make inquiries concerning private information. *WeCheck use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements

	Types of personal information	Purpose of use
1	Personal information related to hiring, recruit applicants and internship applicants	Usage related to hiring, the provision of information to job applicants (including internship applicants) and other recruitment activities.
2	Records of customer's visits to our company	To ensure office safety
3	Information related to participants of exhibitions, workshops and seminars	Providing guidance for exhibitions, workshops and seminars
4	Inquiries from customers	Handling of inquiries related to after-sales services, etc. Sharing of information and communication with agents overseeing business transactions
5	Information related to clients (including joint research and development partners as well as persons who have exchanged business cards or had business meetings with the employees of our group)	1. Communication with clients regarding various types of business 2. Fulfillment of various types of contracts with clients 3. Communications with clients regarding business meetings 4. Communication with clients required for joint research of products or technologies 5. Applications, notifications, reports, etc. to government agencies concerning tax and social security 6. Payment of gratuities
6	Information related to employees (including retired employees) and their families	1.Personnel and labor management such as payroll calculation, employee benefits, and personnel evaluation 2.Responding to labor related laws concerning retired employees, communication with employees in the event of an emergency, etc. 3.Applications, notifications, reports, etc. to government agencies concerning tax and social security
7	Personnel information concerning user campaigns, applications and various other services provided by our group.	1. Performance of user questionnaires and campaigns 2. Procedures involved in the participation of campaigns (reception, communication, posting, etc.) 3. Mailing of mail magazines, DMs, etc. 4. Requests for surveys and other questionnaires 5. Provision information on our services or services related to our services. 6. To maintain, develop and improve our services 7. Marketing of our services
8	User information sent from smartphone applications (apps) including location info; information related to identification of the communication device such as device ID, etc.; referrer; communication device OS information and IP address.	1. Surveying and analyzing anonymized user information with the aim of improving services 2. Handing inquiries from users 3. Provision information, etc., related to various services as well as provision of customer support

4.Provision of personal information to third parties

Our group will not provide personal information to third parties without prior consent from the persons concerned. However, based on the provisions of Article 23, paragraph 1 of the Personal Information Protection Act of Japan, personal information may be provided to third parties in the following cases without the consent of the persons involved. Even in such cases, our group will require and supervise those supplied with information to ensure that they process personal information in a manner that is consistent with the terms and conditions of each service and with our groups' standards for handling personal information.

(1) Cases as prescribed by law
(2) Cases in which the provision of personal information is necessary to protect the life, body or property of an individual and in which it is difficult to obtain the consent of the person.
(3) Cases in which the provision of personal information is especially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person.
(4) Cases in which the provision of personal information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned

Our group may share personal information which it has obtained from customers only for the following purposes and within the following scopes.

(a)Parties to which personal information is provided

Our group (see the introduction of this Privacy Policy for a list of applicable group companies) as well as partner distributors which are providing or will provide services to customers

(b) Purposes of providing personal information

Engaging in communication and business negotiation with customers
Confirming product sales destinations, installation locations, and service history, etc., in order to handle inquiries, etc., from customers and improve services, etc., provided to customers
Providing guidance for exhibitions, seminars, products and services, etc.
Collecting information regarding product quality and feedback for product development and production

Name
Place of employment as well as affiliated department, address, telephone number and e-mail address
The contents of business negotiations and requests
Information obtained from the use of the application

(d)Party responsible

ARKRAY, Inc.

5.Requests for the disclosure, etc., of personal information.

Regarding requests for "notification of the purpose of use"; "disclosure"; "correction, addition or deletion"; "suspension"; "removal" or "discontinuation of provision to third parties" of personal information which has been provided to our group: Please fill in the necessary information on the request form (PDF

), attach documentation to identify the sender as the person concerned or their representative, and send it to the "Contact" link below for prompt response.
[Note]
The personal information subject to this request is pieces of personal information that constitute (1) a collection of information systematically constructed so that it can be searched using a computer, or (2) a collection of information organized and classified in accordance with a certain system systematically constructed so that specific personal information can be easily searched for by attaching a table of contents, index, codes, etc. Our group can only disclose, correct, add to or delete from, discontinue the use of, erase, or discontinue the provision to third parties of that information which the person concerned has the authority over to issue such requests (personal information subject to disclosure).

6.Other, usage of analytical tools

Our group makes use Google Analytics for the analysis of statistics, etc., obtained via customer usage of several websites belonging to our group in the interest of improving customer convenience. Google Analytics makes use of cookies, and creates logs that do not contain information which identifies specific persons. Logs obtained via the use of Google Analytics are managed under the priacy policy of Google LLC. Please see below for the privacy policies of Google Analytics and Google LLC.
About Google Analytics(https://www.google.com/analytics/terms/us.html)

〈Contact〉
Inquiries regarding disclosure requests, comments, questions, complaints and other handling of personal information by our group will be accepted at the following.

ARKRAY, Inc. Group Support Division, General Affairs Team
602-0008, Yousuien-nai, 59 Gansuin-cho, Kamigyo-ku, Kyoto
TEL:050-5527-9303 FAX: 075-431-1202
E-mail: somuteam@arkray.co.jp