About Personal Information Protection

1. Definition of Personal Information and Activity of its Protection

Proterial Metals, Ltd. (hereinafter referred to as "Proterial Metals") shall define that personal information means information about individuals, including the name, birth date and other descriptions about them, or a number, symbol, code, image or sound assigned to them, that identifies the individuals (it shall also include the information that cannot identify individuals by itself, but can, as it easily can be verified with some other information.) In addition, it shall not be limited to personal identifiers, but shall include any information that indicates a fact, recognition and assessment about the attribute of individuals, including a physical characteristic, property, occupation or status.

Proterial Metals protects and manages the personal information by establishing a manager on a department basis with the greatest care and the best effort based on the "Proterial Metals Privacy Policy".
And, from the viewpoint of the protection of the rights and interests of the Concerned Persons, Proterial Metals makes efforts to consider the following points.

1. Responding to request from Concerned Persons about their retained personal data by voluntarily stopping its use, etc., such as stopping the sending of direct mail to the Concerned Person.
2. Whether information is entrusted to others or not, promoting the clarification of outside processing, such as clarifying the details of work done outside the business by outsourcers.
3. Clarifying the purpose of use more to the Concerned Persons through activities such as the business voluntarily limiting the purpose of use based on the selections of the Concerned Persons or the business limiting and showing the purpose of use by type with consideration to the details of the work.
4. Specifying as concretely as possible the source personal information was acquired from and the method of acquisition (the type of acquisition source, etc.) on the procedures to meet requests for disclosure and others.

2. Scope of Application

This document, "About Personal Information Protection," establishes the Proterial Metals' procedures for handling personal information.

3. Handlig Policy of Personal Information - Collection/Usage Purpose and Provision to Third Party

1. In relation to Proterial Metals' main business activities, Proterial Metals will collect and use personal information only to achieve each purpose. For more details of our business activities, please see our website.

   1. Execution of a contract concluded between Proterial Metals and a customer.
   2. Contacts for business negotiations and meetings with a customer.
   3. Delivery of after-sales service on products, and sending of information on events and new products.
   4. Execution of business, including system development, operation and maintenance, entrusted by customers.
   5. Delivery of various membership services.
   6. Affairs of stocks.
   7. Response to various inquiries from a customer.
   8. Analysis based on questionnaires to improve products and services.
   9. Provision of personal information to the group company in case of co-operation with them.

   When Proterial Metals requires a person to provide the personal information as is written in a document directly from the person, Proterial Metals will clearly state the purpose of the use beforehand to obtain the consent.

2. Proterial Metals will not provide the personal information with a third party without first obtaining consent of the person, except in the following cases:

   1. Cases in which the provision of personal information is based on laws
   2. Cases in which the provision of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person
   3. Cases in which the provision of personal information is specially necessary for improving public hygiene or promoting the sound growth of children and in which it is difficult to obtain the consent of the person
   4. Cases in which the provision of personal information is necessary for cooperating with a state institution, a local public body, or an individual or entity entrusted by one in executing the operations prescribed by laws and in which obtaining the consent of the person might impede the execution of the operations concerned
   5. Cases in which an entry handling personal information entrust the handling of personal information in whole or in part within the scope necessary for the achievement of the Purpose of Use
   6. Case in which personal information is provided as a result of the take-over of business in a merger or otherwise

3. When required to do so for business activities in which Proterial Metals is co-operating with the group companies, Proterial Metals may provide such group companies with personal information such as a name, workplace or home addresses, telephone number, fax number, e-mail address, etc. If this is the case, the personal information will be provided in print or electronic media. In addition, the person may request us to stop the provision of the personal information with the group companies.

4. Handling of Specific Personal Information

1. In our main business activities, as well as the provision of information services, when handling specific personal information, our Company will comply with the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (hereinafter referred to as the "Act on the Use of Numbers"), Act on the Protection of Personal Information, and Guidelines for proper handling of Specific Personal Information (for private entities).

2. Our Company considers our "personal information protection policy" as the "basic policy for the proper handling of specific personal information", and will ensure the proper handling of specific personal information.

3. Our Company considers the performance of administrative procedures relating to social security, taxes, and countermeasures against disasters stipulated in each paragraph in Article 9 of the Act on the Use of Numbers to be the scope of use of specific personal information, and will obtain and use specific personal information to the extent necessary to achieve a purpose.
   The main scope of use of specific personal information handled by our Company is as follows:

   1. Clerical work in which upon receipt of specific personal information provided by, for example, our employees, our Company states such information in necessary documents, such as certificates of tax deducted for employment income and retirement income, payroll payment reports, unemployment insurance notifications, notifications of qualified persons covered by health insurance and corporate employees' pension insurance, and legal written records including claims pursuant to the Industrial Accident Compensation Insurance Act, and submits the aforementioned documents to the director of a taxation office, the mayor of a municipality, Japan Pension Service, or other organizations.
   2. Clerical work in which upon receipt of specific personal information, our Company states such information in various reports of payment, such as reports of payment of remuneration and fees; reports of payment of dividends, distribution of surplus, and interest on funds; reports of payment of rental charges, such as for real estate; and reports of payment in consideration of the transfer of, for example, real estate; and submits the aforementioned reports to the director of a taxation office.
   3. Performance of operations that involve clerical work entrusted to our Company by an administrative organization or other private entity for the handling of specific personal information.

4. Our Company will not provide specific personal information of a person to any third party, apart from cases stipulated by laws and regulations concerning specific personal information. Our Company will not jointly use such information. However, for any case that falls under any of the items stipulated in Article 19 (Restrictions on the Provision of Specific Personal Information) of the Act on the Use of Numbers, specific personal information may be provided.

5. Our Company may entrust handling of specific personal information within the scope of purpose of use stipulated by laws and regulations.

5. About Usage of Cookies and Web beacons

Proterial Metals uses cookies^*1 and Web beacons (clear GIF)^*2 in part of the website to make it more conveniently to use for person.
A person can refuse to receive a cookie, or can display a warning message when receiving a cookie by changing the setting of a web browser. For more details, please see the instructions of a web browser you are using. Moreover, a person can reject a Web beacon by setting to refuse the receipt of a cookie.
But, in the first case, please note that a person may not be able to use the all or part of our services provided in the website.

Glossary

^*1 Cookies:
Mean information exchanged one another between a web server that controls a web site and a web browser that a person uses. Cookies may be saved as files in the disk of a person's PC. If you use a cookie, the web server can track and record information about which pages in the web site the particular computer visits etc. However, we cannot identify the person unless he or she enters the personal information into the web site.

^*2 Web Beacons:
Mean technology that functions with a cookie to check how many times a person accesses a particular page. However, we cannot identify the person unless he or she enters the personal information when receiving cookies.

Enacted April 1, 2016