KOBELCO Group Privacy Policy

(1) Approach to the Protection of Personal Information

Kobe Steel Ltd. (hereinafter referred to as "Kobe Steel") and each of its group companies (Kobe Steel and such group companies are hereinafter collectively referred to as "KOBELCO Group") recognizes that it is important to protect the personal information of all individuals who provide personal information to us, including customers and business partners (hereinafter referred to as the "Principal"), and in order to fulfill this responsibility, we will handle personal information in accordance with the following policies.

1. We, KOBELCO Group will comply with the Act on the Protection of Personal Information and other relevant laws and regulations applicable, and will handle personal information appropriately in accordance with generally accepted practices relating to the handling of personal information. In addition, we will endeavor to improve our handling of personal information as necessary.
2. We, KOBELCO Group shall clarify the rules for the handling of personal information and ensure that all of our employees are fully informed of such rules. We will also provide necessary and appropriate supervision to a person to whom we entrust handling of personal information (hereinafter referred to as the "Trustee").
3. In handling personal information, KOBELCO Group will specify, notify, or publicly announce the purpose of use and handle personal information according to the purpose of use.
4. In order to prevent leakage, loss, alteration, etc. of personal information, KOBELCO Group will implement the necessary measures to appropriately manage such information.
5. We, KOBELCO Group will accept requests from the Principal for disclosure, correction, addition or deletion, cessation of utilization, erasure, and cessation of a third-party provision concerning personal information held by us at the designated reception desks and will respond in good faith thereto.

(2) Utilization Purposes of Personal Information

Each of us, KOBELCO Group companies will acquire and use personal information to the extent required for the specific purposes, such as business communications and responses to the relevant inquiries. For further details regarding the purposes, please contact each of KOBELCO Group companies to which you provided your personal information.

(3) Disclosure and Provision to Third Parties

We, KOBELCO Group will not disclose or provide personal data, etc. (including non-identifiable person-related information) to any third party except for the cases in which we provide personal data to Trustees or the cases falling under any of the following:

1) Cases in which the Principal consents to the disclosure or provision.
2) Cases in which data is disclosed or provided in a manner that makes it impossible to identify the Principal, such as statistical data.
3) Cases in which it is required to disclose or provide personal data based on laws and regulations.
4) Cases in which there is a need to provide or disclose personal data to protect a human life, body, or fortune, and when it is difficult to obtain the Principal's consent thereto.
5) Cases in which there is a need to provide or disclose personal data to cooperate with central government organizations, local governments, etc. performing public affairs, and when there is a possibility that obtaining the consent of the Principal thereto would interfere with the performance of the said affairs.
6) Cases in which we jointly utilize personal data with specific persons and notify the Principal of, or publicly announce, in advance the required information regarding the joint utilization.
7) Cases in which personal data is disclosed or provided in connection with business succession.

(4) Joint Utilization

We, KOBELCO Group may jointly use the acquired personal information among us as follows:

Categories of jointly utilized personal information	Information related to name, affiliation (name of company, department, title, etc.), business contact information such as address of the place of work or similar, telephone number, FAX number and e-mail address and other information related to the Principal obtained through business interactions.
Scope of jointly utilizing persons	KOBELCO Group
Utilization purposes for the utilizing persons	Purposes described in “(2) Utilization Purposes of Personal Information” above
Person responsible for controlling the jointly utilized personal information	Kobe Steel, Ltd. The address can be found here. The name of the representative can be found here.

（5）Request from the Principal for Notice of Utilization Purpose, Disclosure, Correction, Addition, Deletion, Cessation of Utilization, Erasure, or Cessation of a Third-Party Provision

1) Notice of utilization purpose
Upon receipt of a request from the Principal for notice of utilization purpose of his/her own personal data retained by KOBELCO Group, we will respond thereto within a reasonable period and scope after confirming that the submitter of such request is actually the Principal. (Please also note that a request for notice of utilization purpose concerning certain data retained by us based on certain laws and regulations may not be accepted.)
2) Disclosure
Upon receipt of a request from the Principal for disclosure of his/her own personal data retained by KOBELCO Group or included in the record on a third-party provision, we will respond thereto within a reasonable period and scope after confirming that the submitter of such request is actually the Principal.
3) Correction, Addition, and Deletion
Upon receipt of a request from the Principal for correction, addition, or deletion concerning his/her own personal data retained by KOBELCO Group, we will make such correction, addition, or deletion concerning the data within a reasonable period and scope if any of the contents therein are not factual, after confirming that the submitter of such request is actually the Principal.
4) Cessation of Utilization, Erasure, and Cessation of a Third-Party Provision
Upon receipt of a request from the Principal for utilization cease, erasure, or cessation of a third-party provision concerning his/her own personal data retained by KOBELCO Group, we will make such utilization cease, erasure, or cessation of a third-party provision concerning the data within a reasonable period and scope, after confirming that the submitter of such request is actually the Principal. Please be advised in advance that, in the event of such utilization cease, erasure, or cessation of a third-party provision of part or all of your personal data, we may not be able to continue providing services as requested by you. We appreciate your understanding and cooperation in this matter. (Please also note that requests of utilization cease, erasure, or cessation of a third-party provision concerning certain data retained by us based on applicable laws and regulations may not be accepted).

(6) Security Control Measures

KOBELCO Group has taken the following security control measures regarding personal information:

Formulation of a basic policy	In order to ensure the proper handling of personal information, we have established this “KOBELCO Group Privacy Policy”.
Development of disciplines regarding the handling of personal data	We develop and put into practice internal rules, manuals, etc. regarding the handling of personal information.
Systematic security control measures	We establish responsible persons for the handling of personal information, and conduct management of ledgers for, and audits regarding, personal information.
Human security control measures	We regularly train employees on matters of concern regarding the handling of personal information.
Physical security control measures	We conduct access control for our buildings and floors, keep the documents under lock and key, and impose restrictions on taking out of electronic media, etc.
Technical security control measures	We impose restrictions on the use of, and conduct access control over, external recording media, and take measures to prevent unauthorized access from outside sources, etc.
Understanding of the external environment	We conduct a research on systems regarding protection of personal information in the countries and regions where personal information is stored, and conduct security control measures, etc.

(7) Others

(8) Inquiry

Any requests concerning personal data retained by KOBELCO Group as set forth in Article (5) above or any other inquiries concerning the handling of the personal information should be directed to the department of individual KOBELCO Group companies to which you provided your personal information. If you are not sure where to contact, please contact the specified contact point of Kobe Steel.

Kobe Steel's Handling of Privacy & Personal Information

Last updated: April 1, 2023

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