[1. Basic Policy]
Nissin Tekko Kensetsu Co., Ltd. (hereinafter referred to as "our company") considers it our social responsibility to properly manage personal information in order to protect the rights and interests of individuals. We have established the following policy on personal information protection, and will strive to further protect personal information by making sure that all employees and related parties are fully aware of it.


1. Collection, use and provision of personal information
We will establish a system for protecting and managing personal information, and will establish and comply with internal rules regarding the appropriate collection, use and provision of personal information.

2. Safety measures for personal information We take thorough measures for safety management in accordance with the following:

(Organizational safety control measures)

The person in charge confirms that personal data is being handled in accordance with the established handling procedures

Establish a reporting and communication system for employees to the person in charge

(Personnel safety management measures)

Regular training for employees on important points regarding the handling of personal data

Matters concerning confidentiality of personal data are entered into at the time of employment contract

(Physical security measures)

Measures to prevent personal data from being easily accessed by anyone other than employees who are authorized to handle the data and the person in question

Measures will be taken to prevent theft or loss of devices, electronic media, documents, etc. that handle personal data, and measures will be taken to prevent personal data from being easily identified when such devices, electronic media, etc. are carried, including when moving within the workplace.

(Technical security control measures)

Clarify the devices that can handle personal data and the employees who handle those devices, and prevent unnecessary access to personal data.

Implement a mechanism to protect devices that handle personal data from unauthorized external access or malicious software.

(Understanding the external environment)

If personal data is to be stored in a foreign country in the future, we will implement safety management measures after understanding the systems for protecting personal information in that foreign country.

3. Confirmation, correction, and suspension of use of personal information If a person in question requests confirmation, correction, or suspension of use of the information, we will investigate the matter and respond appropriately in accordance with separately established internal rules.

4. Compliance with laws, regulations and other rules regarding personal information We will comply with laws, regulations and other rules regarding personal information.

5. Education and Continuous Improvement In order to properly maintain the personal information protection system, we will thoroughly educate and train our employees and continually review and improve our internal rules.

7. Provision and disclosure of personal information
The provision and disclosure of information will be determined separately.

8. Complaints Desk
For inquiries regarding personal information, please use the following contact point.

Department in charge: Personal information inquiry desk

Address: 4-8-5 Nishishinkoiwa, Katsushika-ku, Tokyo 124-0025

Contact: 03-3694-4848



Established on January 22, 2018

April 1, 2022 (revised)



Nisshin Iron Works Construction Co., Ltd.

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2. Scope of Application
This Personal Information Protection Policy sets out the policy that our company will follow when handling personal information or similar information of customers, related parties (business partners, related organizations), and employees in the various businesses that we conduct.



[3. Acquisition of personal information and purpose of use]
We will use all personal information provided to us in the course of our operations for the following purposes:

Target Audience

Purpose of Use

Regarding customers and related parties (business partners, related organizations)

personal information

1. Provision of products, technologies and services

2. Planning, design, construction and inspection

3. Accounting, bookkeeping and document preparation

4. Investigation, handling and reporting of troubles, accidents, etc.

5. After-sales maintenance

6. Cooperation with OJT training

7. Providing information by e-mail, direct mail, etc. Proposals regarding products, technologies, and services handled by our company, and other information

8. Proposals for repairs, support, and maintenance of products handled by our company, and provision of other information

9. Providing information on campaigns, fairs, and events

10. Providing information regarding surveys and monitors

11. Conducting business negotiations and meetings with customers (sales partners and end users), and contacting them, etc.

12. Other management and operation tasks related to customers (business partners and end users)

13. Providing information to and contacting business partners (suppliers, distributors, infrastructure providers, etc.)

14. Liaison, cooperation, and negotiation with business partners (suppliers, distributors, infrastructure contractors, etc.)

Fulfillment of contracts, requests for performance, etc.

15. Requests for the processing of personal information from business partners (suppliers, distributors, infrastructure providers, etc.)

In the event that the whole or part of the business is outsourced,

For proper and smooth execution

16. Ceremonial greetings, sending and offering gifts

17. Contact regarding planning, consideration, and holding of meetings, roundtable discussions, etc. with related parties such as related organizations to which you belong

18. Sharing information about business activities with related parties, such as affiliated organizations

19. Application, notification, and reporting to government agencies or organizations such as related organizations to which you belong

Recruitment and recruitment activities;

Regarding internship applicants, employees and retirees

personal information

1. Hiring and recruitment activities (including internships)

2. Providing information and contacting applicants

3. Use related to recruitment and hiring activities

4. Providing information and contacting former employees

5. Personnel and Labor

6. Calculation, determination and payment of remuneration

7. Training

8. Dismissal/Resignation

9. Other employment management, performance management, and ensuring proper business operations

10. Health information for purposes deemed beneficial to employees, such as maintaining or improving their health

11. Personnel and labor affairs of employees entrusted to tax accountants and social insurance and labor consultants, calculation of remuneration, etc.

To the extent necessary

12. Provision of personal data (excluding personal numbers) to the company on the condition that it will be used only to the extent necessary for labor management, etc. at the company

13. Notification of results to employees regarding health examinations commissioned by business operators; medical compensation

Consulting or submitting notices to medical professional organizations, insurance companies, etc. regarding liability insurance, etc.

14. Other uses related to employee affairs

Use of personal numbers of employees, etc. based on the Numbering Act



1. Preparation of legal documents related to salaries, retirement benefits, and retirement pensions

2. Employment insurance notification procedures

3. Health insurance and employee pension insurance notification procedures

4. Notification of National Pension No. 3 insured persons

5. Preparation of payment records for remuneration, fees, contract fees and prizes

6. Other matters related to personal numbers as stipulated by laws and regulations



4. Management of personal information
We will thoroughly implement the following measures in managing information provided by customers, related parties (business partners, related organizations), and employees.

(1) Ensuring accuracy of information

We will endeavour to ensure that the information you provide is accurate and up-to-date.

(2) Safety control measures

With regard to the organizational management of personal information, we have established strict internal regulations that stipulate how such information should be handled, and we strictly follow these rules when handling such information.

(3) Supervision of employees

Based on our internal regulations, we ensure strict application of regulations regarding the handling of personal information.

(4) Supervision of contractors

When outsourcing the handling of personal information, we will only entrust it to contractors who meet the requirements based on our internal regulations, and will manage the information appropriately.

(5) Retention period and disposal

We will set a retention period for the information you provide, and will discard it after the retention period has ended.In addition, if the information is no longer needed, it will be discarded immediately, even if it is still within the retention period.



5. Provision to third parties
We will not provide personal information provided by customers, related parties (business partners, related organizations), or employees to third parties. Furthermore, if we decide to provide personal information to a third party in the future, we will present the information to be provided and the purpose of the provision, and will only provide the information to a third party with the consent of customers, related parties (business partners, related organizations), and employees. Furthermore, we may entrust personal information to other businesses within the scope necessary to achieve the purpose of use.



[6. Disclosures regarding opt-out]
Currently, there is no opt-out option. If you choose to opt-out, we will handle it appropriately.



[7. Disclosure items regarding joint use]
Currently, we do not share personal information. If we do share personal information, we will handle it appropriately.



[8. Items to be disclosed regarding anonymously processed information]
(1) Measures to ensure the proper handling of anonymously processed information

We may continually create personal information of customers that has been processed so that a specific individual cannot be identified (hereinafter referred to as "anonymously processed information") as follows:

(2) Matters concerning safety control measures

The Company will take necessary and appropriate safety control measures to manage the Anonymously Processed Information, etc., including preventing leakage, loss, or damage. In addition, the Company will provide necessary and appropriate supervision to employees and contractors (including subcontractors, etc.) who handle the Anonymously Processed Information, etc. Safety control measures for Anonymously Processed Information, etc. are set out in separate internal regulations.

(3) Items of information about individuals contained in anonymously processed information and items of information provided to third parties

N/A



[9. Disclosure items regarding retained personal data]
The Company will disclose the following information regarding personal data it retains:

(1) Receiving requests for disclosure, etc.

Please fill out the designated forms ("Request for Notification of Purpose of Use", "Request for Disclosure of Personal Information Subject to Disclosure", "Request for Correction, etc. of Personal Information Subject to Disclosure") and mail or bring them to the address below. Disclosure, etc. request forms are available at the counter.

[Internal contact point for requests for disclosure, etc.]

Department in charge: Personal information inquiry desk

Address: 4-8-5 Nishishinkoiwa, Katsushika-ku, Tokyo 124-0025

Contact: 03-3694-4848

(2) Identity Verification

To verify your identity, please submit or bring in the following identification documents along with the "designated form."

A copy of a photo that can be used to verify the identity of the person requesting disclosure, such as a driver's license, passport, personal identification number card or basic resident registration card (with address), residence card, or special permanent resident certificate (with the name and address of the person requesting disclosure, etc.)

• Copy of residence certificate (created within 30 days prior to the date of request for disclosure, etc.)

(3) Verification of agent's qualifications

If a representative is carrying out the procedure, in addition to the "designated form" and "identification documents," please mail or bring in the following documents.

• A document verifying the identity of the representative, such as the representative's driver's license, passport, personal identification number card or basic resident registration card (with address), residence card, special permanent resident certificate, etc., that can be used to identify the representative (with the name and address of the representative requesting disclosure, etc.)

A copy of the representative's residence certificate (created within 30 days prior to the date of the request for disclosure, etc.)

• If the representative is a lawyer, a document showing the registration number. • A letter of attorney indicating the representative.

(4) Payment of fees

A fee is required when making a request for disclosure, etc. Please bring the fee together with all documents to the counter and pay the fee in cash.

・Handling fee: 1,000 yen per ticket (tax included)

(5) Handling of requests

We will respond to requests for disclosure, etc., once we have received the designated form and confirmed the identity and representative of the person making the request. However, we may not be able to respond to requests for disclosure, etc., in the following cases:

• When there is a risk of harm to the life, body, or property of the person or a third party. • When there is a risk of encouraging or inducing illegal or unjust acts. • When there is a risk of harming national security, damaging trust with other countries or international organizations, or causing disadvantage in negotiations with other countries or international organizations.

• When there is a risk of impeding the prevention, suppression, or investigation of crimes or the maintenance of public safety and order.

• When there is a risk of causing significant disruption to the proper execution of our business • When there is a violation of laws and regulations

- When it is necessary to cooperate with a national government agency or local government entity in carrying out legally required duties, and informing the individual of the purpose of use or making it public would be likely to impede the performance of said duties.

(6) Disclosure, etc.

We will respond to disclosure requests without delay using the following methods.

• In the case of notification or disclosure of the purpose of use of personal information, a document containing such details will be handed over to the individual or sent by mail with restricted delivery.

• In the case of correction, notification or deletion of the contents of personal information, suspension of use, erasure, or suspension of provision to a third party, a "Notice of decision to correct personal information, etc." will be handed over to you or mailed to you by personal delivery mail.

・If disclosure, etc. is not made for legal reasons, a "Notice of Decision Not to Disclose Personal Information, etc." will be handed over or mailed by personal delivery mail to the address of the individual as written on the designated form. If the legal domicile is indicated on the document verifying the identity of the individual or the agent, you may erase it. Documents verifying the identity of the individual or the agent will be disposed of responsibly within six months of receipt.

(7) Contact point for complaints regarding the handling of retained personal data

Complaints regarding the handling of retained personal data should be filed as follows:

Department in charge: Personal information inquiry desk

Address: 4-8-5 Nishishinkoiwa, Katsushika-ku, Tokyo 124-0025

Contact: 03-3694-4848





Nisshin Iron Works Construction Co., Ltd.

Personal Information Protection Manager

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