Simplex Holdings, Inc. (hereafter referred to as the Company) has enacted and abides by the following Personal Information Protection Policies in order to ensure the protection of personal information.
1.Appropriate handling
Except where required by law, the Company will not handle personal information beyond the scope necessary to achieve its Purpose of Use without obtaining the prior consent of the person concerned. Furthermore, when personal information is obtained directly in writing, its Purpose of Use will be clearly disclosed each time.
2.Personal information security measures
The Company implements the measures (including organizational, personnel, physical, and technical security measures) necessary and appropriate to prevent the leakage, loss, or damage of personal data handled by the Company and to otherwise securely manage personal data. In addition, the Company also exercises necessary and appropriate supervision over its employees and contractors.
3.Supervision of Officers and Employees
When the Company has officers and employees handle personal information, necessary and appropriate supervision shall be undertaken in order to ensure security and protection of such personal information.
4.Supervision of Subcontractors
The Company may partially or completely entrust the handling of personal information to subcontractors and when entrusting such information, necessary and appropriate supervision of the subcontractor shall be undertaken to ensure the security and protection of personal information.
5.Compliance with relevant laws, regulations, guidelines, etc.
The Company complies with all relevant laws, regulations, guidelines, etc., related to the protection of personal information.
6.Continuous improvement
The Company takes efforts to continuously improve its handling of personal information.
Enacted January 1, 2017
Last revised April 1, 2024
Hideki Kaneko, CEO
Simplex Holdings, Inc.
Public Disclosures based on the Act on the Protection of Personal Information
1.Name of the business operator handling personal information
Simplex Holdings, Inc., led by President and CEO Hideki Kaneko
2.Purpose of Use
Unless otherwise stipulated by laws and regulations, we will use the acquired personal information within the scope necessary to achieve the stated purposes of use, in accordance with the following table.
| Type of Personal Information | Purpose of Use |
|---|---|
| (1) Information concerning Company shareholders |
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| (2) Information obtained through the Company’s public relations and IR activities |
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| (3) Information obtained through the sale or provision of the products or services of Simplex Holdings |
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| (4) Information obtained through the sale or use of the Company’s products or services |
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| (5) Information on people who apply for, attend, or participate in events hosted or participated in by Simplex Holdings |
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| (6) Information regarding the officers or employees of the Company (including those who have retired, resigned, or departed the company) |
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| (7) Information on persons who applied for employment consideration, and persons who have requested information on employment consideration |
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| (8) To maintain information on persons who visit the Company |
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| (9) Information regarding persons who make inquiries to the Company |
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| (10) Information that Simplex Holdings has been entrusted with handling |
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| (11) Information obtained upon consenting to the Purpose of Use disclosed by the Company |
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3.Personal information security measures
The Company implements the following security measures for the retained personal data.
| Type of security measures | Contents |
|---|---|
| (1) Organizational Security Measures | Based on the internal personal information protection regulations, we specify the person responsible for handling personal data, and have established escalation procedures in case facts or signs of violations against laws or regulations are recognized, as well as conducting regular audits by the system audit department. |
| (2) Human Security Measures | We conduct regular training for employees and contractors, and provide explicit guidance on the handling of confidential information, including personal information, in employment regulations and other documents. |
| (3) Physical Security Measures | We implement appropriate area segregation and strict access control. |
| (4) Technical Security Measures | We implement appropriate access control based on the Information System Operation Regulations and Information System Usage Regulations. |
4.Provision of personal information to third parties
The Company will not provide personal data to third parties without the individual’s consent, except as required by laws or regulations.
5.Shared use
The Company shares personal information when necessary. The items shared and scope of shared use are as follows.
| Category | Content |
|---|---|
| (1) Personal information items that are shared | Of the personal information acquired and retained by Simplex Group companies, that which is necessary and minimal to carry out the Purpose of Use |
| (2) Scope of shared use |
Simplex Group companies
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| (3) Purposes of Use by parties sharing the information | As described in “2 Purpose of Use” |
| (4) Party responsible for managing shared personal information |
Simplex Holdings, Inc. Person in charge of personal information management |
| (5) Acquisition methods |
Written, verbal or other [Examples] Online input forms, contract documents, application documents, email, fax, letters, questionnaires |
6. Disclosure, Correction and Deletion
With respect to personal data retained by the Company, individuals can request notification of the purpose of use, disclosure, correction, addition or deletion of content, suspension of use, deletion, suspension of provision to third parties, and disclosure of records of provision to third parties (hereinafter referred to as "Disclosure, etc.") through a request from the individual.
7. Inquiries about personal information
For any requests for disclosure, inquires, opinions, or complaints concerning personal information, and other inquiries, please contact the following. We will respond within a reasonable period within the scope of laws and regulations after confirming that the inquiry is from the individual.
Attention: Privacy Inquiries
1-23-1 Toranomon, Minato-ku, Tokyo 105-6319, Japan
Simplex Holdings, Inc.
Attention: Privacy Inquiries