Axis International Corporation

1. Philosophy

Axis International Co., Ltd. (hereinafter referred to as “our company”) has a corporate philosophy of “make people happy with IT” and work on business activities to realize a rich society by providing products and services related to information technology. When providing products and services related to information technology, our company handles a large amount of personal information, including customers, and conducts business. Therefore, we recognize that once an accident such as a leak of personal information occurs, we may cause a serious situation that may shake the business foundation. Proper use and protection of personal information is the foundation of our business, and employees and everyone else involved in our company must recognize the importance of protecting personal information and strive to maintain and manage it. We declare that we will establish a management system on personal information protection and work on protection of personal information.

2. Policy

We will comply with relevant laws and regulations and other norms regarding personal information such as clients and business partners who handle products and services related to our business, and take account of international trends and voluntarily Rules and systems, and declare that they will be implemented and maintained to contribute to the advocacy of stakeholders. As a company trusted by customers, in providing products and services, we aim to earn the trust of customers and contribute to business development by appropriately managing personal information and preventing incidents. will do. We will work on a personal information protection management system based on the policy set out below.

(1) Complying with related legal requirements and other requirements (contracts, agreements, etc.).
(2) Complying with applicable requirements related to the management system.
(3) Establishing, implementing, operating, monitoring, reviewing, maintaining and continuously improving a management system to improve performance.
(4) Assessing the impact of our business activities on risks and opportunities, and set goals for important items to the extent that is technically and economically possible.
(5) Disseminating the importance of all employees and related personnel and continuously carry out education and awareness raising activities.
(6) The policy will be communicated in writing to all employees and will be disclosed outside the company.
(7) Acting as a company-wide activity, recognizing the necessity to promote activities with priority, especially for the following items, in all phases of our business activities.
1) In order to obtain information, it is in principle to obtain consent from the person who has personal information.
2) We do not acquire personal information by an unauthorized method.
3) The Company clearly defines the purpose of use to the extent necessary for business operation and appropriately acquires, uses and provides personal information. Within the scope of the purpose of collection, only the person in charge will use the acquired personal information only when it is necessary for business, and will take measures not to use it outside the purpose.
4) We will keep personal information accurate and up-to-date, and strive to prevent, correct or prevent unauthorized access to personal information, loss, destruction, falsification and leakage of personal information.
5) We will respond promptly and in good faith to inquiries, complaints, disclosures, etc. regarding personal information from clients.
6) We handle personal information within the scope of the purpose of use specified to the requester. In addition, we never disclose or provide personal information provided by the requester to a third party, without the case we have a requester's consent or rightfulness.
7) We never remove the contents of consultations and requests other than the requester or the adviser.
8) As a rule, we will only contact the designated contacts.
9) Responsible for storage management and disposal of forms and records received upon consultation and request.

3. Basic Policy on the Proper Handling of Personal Numbers and Specified Personal Information

(1) Name of business
Axis International Corporation
(2) Compliance with relevant laws, regulations, guidelines, etc.
With regard to the handling of personal numbers and specified personal information (hereinafter referred to as “Specified Personal Information, etc.”), we shall comply with the “Act on the Use of Personal Information to Identify Specific Individuals in Administrative Procedures” (My Number Act), the “Guidelines for the Proper Handling of Specified Personal Information (Business Operators' Edition)”, the “Act on the Protection of Personal Information” (Personal Information Protection Act), and the guidelines of each government agency. The “Act on the Protection of Personal Information” (Personal Information Protection Act) and the guidelines of the relevant ministries and agencies shall be complied with.
(3) Purpose of Use
We will use the Specified Personal Information, etc. provided to us for the following purposes.
(4) Security Control Measures
We shall implement safety control measures to prevent leakage, loss, deletion, or damage of personal information. In addition, we shall prepare appropriate measures to deal with accidents related to personal information and to prevent the spread of damage. The security control measures taken by the Company include the conclusion of appropriate contracts with and supervision of contractors and employees.
(5) Outsourcing Handling
We may outsource the handling of specified personal information, etc. to a third party. In such cases, the Company will exercise necessary and appropriate supervision over the consignee in accordance with the Number Law and the Personal Information Protection Law.
(6) Continuous Improvement
We will strive to continuously improve our handling of Specified Personal Information, etc.
(7) Disclosure of Specified Personal Information, etc.
When we receive a request from the person concerned or his/her representative for notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to a third party of said specified personal information, etc., we will respond without delay, except as otherwise provided by law.
Establishment: December 26, 2022
Hiromi Nakatani, Representative Director AXIS International Corporation

4．Scope of Application

Handling of all personal information handled in our business

5．Handling of personal information

(1) Purpose of use of personal information
We will use personal information within the scope of the following purposes of use.
(2) Matters concerning retained personal data or records of provision to a third party
Name and address of the organization, name of the representative Axis International Corporation
6F Tsukiji Ogawa Building, 7-10-2 Tsukiji, Chuo-ku, Tokyo 104-0045, Japan
Hiromi Nakatani, Representative Director
Personal Information Protection Manager
Hiromi Nakatani, Personal Information Protection Manager
Personal Information Protection Officer Yuki Noguchi
Purpose of Use of Retained Personal Data
With regard to personal information held by the Company, the individual or his/her representative may request disclosure of “notification of purpose of use, disclosure, correction, addition or deletion of content, suspension of use, deletion, suspension of provision to third parties, and record of provision to third parties”.

1. purpose of use of specified personal information

No.	subject	purpose
1	Specified personal information, etc. of business partners	○ The following are the details of the business activities of the Company.
2	Specified Personal Information, etc. of our shareholders	○ The amount of the dividend payment record
3	Specified Personal Information, etc. of our company's employees (including former employees) and their spouses, relatives, etc.	○ Legal record related affairs, withholding tax related affairs, payment record related affairs, retirement allowance and other payment record related affairs by recipient, etc. ○ Social insurance related affairs, labor insurance related affairs, etc. ○ Other related affairs, etc. for which specified personal information may be provided as stipulated in the Number Law.

2. purpose of use of personal data

No.	subject	purpose
1	Personal information related to customers and business partners	Our Business 1. planning, design and development of application software 2. Design, construction, and maintenance of network security systems 3. Sales of products related to network security systems Information security audit services, vulnerability assessment services, and security monitoring and operation services 4. Information security audit services, vulnerability assessment services, and security monitoring and operation services 5. education and training services related to project management, cyber security and IT for the following purposes 【Provision of products and services, provision of information on products and services】 ○ To communicate, cooperate, negotiate, provide information, perform contracts, request performance, and provide information on payment of rewards. ○ For inquiries, shipping, provision, maintenance, support, and after-sales service of our products and services. ○ To control access to the facility. ○ To introduce the agency, sales and service contact. ○ To provide information on seminars, events, and other related information. ○ To provide information on, advertise, propose, sell, and guide products and services, and to send catalogs and pamphlets. ○ To improve product and service development, research and analysis. ○ To provide services such as the provision of Internet-based content, distribution of results and service proposals based on security diagnoses, and e-mail distribution. ○ To provide appropriate services in response to requests and to manage member information. 【questionnaire survey】 ○ To conduct questionnaire surveys and monitor tests for planning, development, sales promotion, and other business activities of the Company and its affiliates regarding the Company's products and services. 【Other】 ○ To send prizes, giveaways, and other distribution materials. ○ To respond to various inquiries and requests for information materials. ○ To prepare statistical data for use as basic information for product development and service improvement. ○ To respond to investigations, records, notifications and reports to government and public agencies, and audits in accordance with laws and regulations, etc. ○ To provide the information to third parties within the scope necessary to achieve each of the above purposes of use, with the consent of the person in question or in accordance with laws and regulations.
2	Personal Information on Shareholders	○ To exercise rights and perform obligations under the Companies Act. ○ To provide various benefits from the issuer with respect to the status as a shareholder. ○ To implement various measures to facilitate the relationship between both parties in terms of members of the association and the association, even within the relationship between shareholders and the company. ○ To manage shareholders, including the preparation of shareholder data in accordance with prescribed standards under various laws and regulations.
3	Personal information related to seminars and events	【participant】 ○ To communicate (including attendance confirmation, issuance of course certificates, etc.), manage correspondence, and provide information. ○ To provide information on seminars, events, and other related information. ○ To provide information on related products and services. ○ To conduct research, analysis, publicity, advertising, etc. on behalf of our business partners. ○ To deliver purchased products and services and to settle payment. 【Management and Instructors】 ○ To communicate, manage correspondence, provide information, and pay compensation.
4	Personal information related to employment	○ To contact, manage correspondence, provide information, and select candidates for employment. ○ To improve services related to recruitment (materials, website, etc.).
5	Personal information regarding employees (including retirees) *Excluding personal numbers.	○ To contact employees, etc., from the company. ○ For human resources, labor and attendance management, wage management such as salary and compensation, training and human resource development services, termination of employment and retirement, and social insurance services. ○ For health care, business management, welfare services, security management, etc. ○ To perform personal information protection management system operations and disclosure operations. ○ For public relations. ○ To provide personal data to the transferee to the extent necessary for labor management, etc. at the transferee's location. ○ To perform other tasks associated with the execution of the Company's business, and tasks incidental to the tasks up to the preceding item.
6	Personal information about employees (including retirees) (personal number)	○ For personal number use business. ① Preparation of legal documents related to salaries, retirement allowances, and retirement pensions ② Notification of employment insurance ③ Notification of health insurance and welfare pension insurance ④ Notification paperwork for National Pension Plan's Category 3 insured persons ⑤ Preparation of payment records for remuneration, fees, contracts, and monetary awards ⑥ Other personal number-related work stipulated by laws and regulations, etc.
7	Other personal information related to inquiries, etc. to the Company	○ To contact, manage correspondence, provide information, send related materials, etc.

Request Form

【Procedures for responding to requests for disclosure, etc. of personal information (retained personal data) and records provided to third parties】
We will respond to requests regarding personal information subject to disclosure. If you have any requests, please contact our Complaint Consultation Desk.
1) Contents of response
Requests for notification of purpose of use, disclosure, correction, addition or deletion of contents, suspension of use, deletion and suspension of provision to third parties, and disclosure of records of provision to third parties
2) Documents to be submitted for disclosure
① Request form regarding the matters requested in 1) above (After your request, we will send you a document prescribed by us)
② Identification documents
・ A copy of a driver's license, my number card, passport, or other document that can verify the identity of the applicant with a photograph (validated copy with the name and address of the person making the request for disclosure, etc.)
・ A copy of the certificate of residence (made within 30 days prior to the date of the request for disclosure, etc.)
③ Additional documents in case of proxy
・ A document certifying the agent, a copy of the agent's driver's license, My number card, passport or other document that can verify the agent's identity with a photograph (validated with the name and address of the agent making the request for disclosure, etc.)
・ A copy of the representative's certificate of residence (made within 30 days prior to the date of the request for disclosure, etc.)
・ If the representative is an attorney, documentation showing registration number
・ Power of Attorney indicating representation
3) commission
For each request for notification of purpose of use, disclosure, or disclosure of records of provision to third parties, a handling fee of 1,000 yen will be charged.
4) Disclosure Method
We will inform you of our policy for responding to requests for disclosure, etc. without delay by the following methods.
① For notification of the purpose of use of personal information, disclosure of personal information, and requests for records concerning the provision of personal information to third parties
We will respond to your request by the method you specify. If it is difficult to disclose the information by the specified method, we will respond to the request in writing or by other means.
② Correction, addition, deletion, suspension of use, erasure, or suspension of provision to third parties of personal information
We will contact you by phone or e-mail to let you know that we have responded.
③ Cases in which disclosure, etc. is not possible
Regardless of (1) or (2) above, we will contact you by phone or e-mail.
5) Other
The letter shall be sent to the address of the person or his/her representative as indicated on the prescribed form.
If the document proving the identity of the applicant or his/her representative clearly indicates the place of residence, it may be erased.
Documents proving the identity of the applicant or his/her representative will be disposed of responsibly within 6 months of our obtaining them.
【Measures taken to ensure the security of retained personal data】
In order to handle personal information more strictly, we operate a personal information protection management system based on a personal information protection policy in accordance with JIS Q 15001, personal information protection regulations, etc., and an understanding of the external environment.
In addition, in the actual handling of personal information, we have implemented safety control measures from four perspectives: organizational, human, physical, and technical.
For more information on safety control measures, please contact us using the “Request Form”.

Request Form