Personal Information

In order to implement the Personal Information Protection Policy, MCo shall establish the “Rules for handling personal information,” make sure that its employees (including general officers and employees, part-time workers, and dispatched workers) and other relevant parties are fully aware of the protection of personal information for implementation, and improve and maintain these rules.

1. MCo obtains personal information by specifying the purpose for which it is used, and by using lawful and fair means.
2. MCo will not acquire personal information through deception or other wrongful means.
3. MCo will not collect, use or provide special care-required personal information.

1. MCo uses personal information for the following purposes:
   • Business-related contacts
   • Conclusion (including preparation) and performance (provision of information and services, receipt of securities, disbursement of loans, etc.) of contracts
   • Providing notifications on information and services handled by MCo
   • Providing notifications on seminars, lectures and such like organized by MCo
2. Personal information shall be used within the scope of the purpose of collection and only by persons authorized in accordance with specific operations, to the extent necessary for the execution of operations; provided, however, that this does not apply if the consent of the individual to the use of personal information is obtained, if the use of personal information is in accordance with laws or regulations, or if the use of personal information is necessary to protect the life, health, property or other material interest of the individual or a third party.
3. MCo will not use personal information outside the scope of purpose of use, take it out of the ordinary place of use, nor leak personal information, including sending it to an external party.
4. The employees of MCo shall not disclose personal information obtained in the course of business to a third party without good reason nor use it for an improper purpose. The same shall also apply to employees who leave the position pertaining to the business, to whom necessary measures shall be taken.

MCo shall endeavor to keep personal data accurate and up-to-date to the extent necessary to achieve the purpose of use and to delete the personal data without delay when it is no longer necessary to use.

MCo takes appropriate information security measures, such as measures against unauthorized access and computer viruses, to prevent the loss, destruction, alteration, and leakage of personal data.

1. MCo will not any provide personal data to any third party except in the following cases or with the consent of the individual.
   1. When it is in accordance with laws and regulations;
   2. When it is necessary for the protection of the life, body or property of an individual and in case it is difficult to obtain the consent of the individual;
   3. When it is particularly necessary for the improvement of public health or the promotion of sound upbringing of children and in case it is difficult to obtain the consent of the individual;
   4. When it is necessary to cooperate with a national government agency, a local government, or a person entrusted by a national government agency or a local government in carrying out affairs prescribed by laws and regulations and in case obtaining the consent of the individual in question is likely to interfere with the execution of the said affairs; or
   5. When it is joint use stipulated in the following paragraph:
2. When MCo deposits personal data with a third party for the purpose of jointly using the personal data with the third party or entrusting a work to the third party, it shall investigate the third party, conclude the necessary agreement, and take other necessary measures under laws and regulations.

Notwithstanding any other provision relating to the provision to third parties in this Personal Information Protection Policy, in the case of providing personal data to a third party in a foreign country, MCo shall obtain the consent of the individual concerned, except in the following cases:

1. When the foreign country concerned is specified under the Rules of the Personal Information Protection Commission as a foreign state that has a system concerning the protection of personal information recognized to be at the same level as that of Japan in protecting the rights and interest of individuals;
2. When personal information is provided to a party that has established a system that conforms to the standards prescribed by the Rules of the Personal Information Protection Commission as being necessary to continuously take measures equivalent to the measures to be taken by a personal information handling business operator pursuant to the provisions of the Act on the Protection of Personal Information with regard to the handling of personal data;
3. When it is in accordance with laws and regulations;
4. When it is necessary for the protection of the life, body or property of an individual and in case it is difficult to obtain the consent of the individual;
5. When it is particularly necessary for the improvement of public health or the promotion of sound upbringing of children and in case it is difficult to obtain the consent of the individual; or
6. When it is necessary to cooperate with a national government agency, a local government, or a person entrusted by a national government agency or a local government in carrying out affairs prescribed by laws and regulations and in case obtaining the consent of the individual in question is likely to interfere with the execution of the said affairs.

When MCo exchanges personal data with a third party, if required by Relevant Laws and Regulations, MCo will appropriately confirm and record such information in accordance with the provisions of Relevant Laws and Regulations.

MCo will appropriately respond to requests for notification, disclosure, correction, etc. and suspension of use, etc. of matters concerning the retained personal data pursuant to the Act on the Protection of Personal Information. For these requests, please contact the following hotline.
MCo CFO Office email: info@mcokk.com