Pole To Win Holdings Co., Ltd., in recognizing its social responsibility and professional mission when using personal information collected directly in its operations or entrusted by clients, will comply with laws and regulations regarding the protection of personal information and has established and implemented the following policy for its business activities.

• Collection, use, and provision of personal information will be limited to the minimum necessary for business operations. Additionally, we will implement this considering the requests from customers.
• We will comply with laws, regulations, and ordinances related to personal information protection.
• We will implement reasonable and effective security measures to eliminate risks such as leakage, damage, and unauthorized access to personal information.
• We will periodically and appropriately review the handling of personal information and continuously improve the management level.
• This policy will be posted in all departments and distributed to all employees, as well as provided to relevant outsourcing companies to ensure thorough awareness. We will also strive to educate and raise awareness among employees and include definitions in contract terms with outsourcing companies to promote heightened awareness of personal information protection.

The above policy also applies as the personal information protection policy for job applicants and our employees.

Company: Pole to Win Holdings Inc.
Address: 14th Floor, Shinjuku NS Building, 2-4-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 163-0814, Japan.
Representative: Teppei Tachibana, President and CEO

On our website, you may be required to provide personal information such as your name, address, phone number, and email address when making inquiries or similar requests. In such cases, we will use this information within the scope notified to you, in accordance with the above 'Personal Information Protection Policy,' and handle it in a secure environment with assured security.

Please note that our website contains links to other websites (businesses or individuals). We are not responsible for the protection of personal information on these external websites. Please exercise caution when accessing linked sites.

When you access our website again, we may send a recognition token called a cookie to your browser to make your experience more convenient. This industry-standard technology allows us to recognize your computer, but we cannot identify specific individuals unless you input personal information. You remain anonymous.

You can refuse to accept cookies by adjusting the settings on your web browser. However, doing so may result in some or all of the services on the website becoming unavailable.

For more details about cookies, please refer to our Cookie Policy.

We hereby disclose the handling of personal information that we collect, use, and provide as follows.

Purpose of Using Personal Information.

We will use personal information for the following purposes and within the scope of purposes previously specified.

Except in the cases outlined below, we do not provide personal information to third parties without obtaining prior consent from the individual.

• When required by law
• When necessary to protect someone's life, body, or property, and obtaining the individual's consent is difficult
• When especially necessary for the improvement of public health or the promotion of the sound development of children, and obtaining the individual's consent is difficult
• When it is necessary to cooperate with a national or local public organization, or a third party entrusted by them, in carrying out duties prescribed by law, and obtaining the individual's consent would hinder the performance of such duties.

We may outsource personal information to other businesses within the scope necessary to achieve the intended purposes. In such cases, we select outsourcing partners with established personal information protection systems, conclude contracts concerning personal information protection, and provide necessary and appropriate supervision.

(1) About Shared Use

Personal data collected by us will be jointly used by us and the companies within the Pole To Win Holdings (PHD) Group.

(2) Items of Personal Data Shared

Name, company name, department, position, address, phone number, fax number, email address, order history, etc.

(3) Scope of Shared Use

For the names of the businesses sharing the data, please refer to the corporate website of Pole To Win Holdings Inc.
https://www.phd.inc/

(4) Purpose of Use

The shared use will be within the scope of the purposes outlined in (1) 'Personal Information of Our Customers and Business Partners.'

(5) Company Name, Address, and Representative Responsible for Personal Data Management

We are responsible for managing the personal data shared.
Our address and representative are as mentioned above.
For inquiries about shared use, please contact:

Pole To Win Holdings Inc. Personal Information Protection Officer
Inquiry: Corporate Inquiries

When providing personal information to third parties located abroad, we will obtain the consent of the individual in advance, except in cases where exceptions are permitted by law. When obtaining consent in advance, we will provide the individual with information regarding the personal data protection system in the foreign country, the measures taken by the third party to protect personal data, and other relevant information. Additionally, if personal information is provided to a third party located abroad (limited to those who have established the system specified in Item 1) based on consent, we will take necessary measures to ensure the continued implementation of appropriate measures by the third party and will provide information about these measures upon the individual's request.

Creation of Anonymized Processed Information

When creating anonymized processed information (which is personal information that has been processed to prevent identification of specific individuals according to legal measures, and which cannot be restored to its original form), we will take the following actions.

• Perform appropriate processing in accordance with the standards prescribed by law.
• Implement security measures to prevent leakage of deleted information and information about processing methods, in accordance with legal standards.
• Publish the categories of information contained in the created anonymized processed information.
• Refrain from actions that would identify individuals from whom the original personal information was derived.

(2) Provision of Anonymized Processed Information

When providing anonymized processed information to third parties, our company will disclose the categories of information contained in the anonymized processed information and the method of provision. Additionally, we will clearly indicate to the third parties that the information being provided is anonymized processed information.

(3) Security Management and Complaint Handling

When creating anonymized processed information, we will voluntarily implement measures such as security management and complaint handling to ensure proper handling of the anonymized processed information, and will make efforts to publicly disclose the details of these measures.

(1)When creating pseudonymized processed information, our company will process personal information in accordance with the standards prescribed by law.

(2)When creating pseudonymized processed information or acquiring pseudonymized processed information and related deletion information, we will implement measures for the safe management of deletion information in accordance with the standards prescribed by the Personal Information Protection Commission regulations, to prevent the leakage of such information.

(3)Unless required by law, we will not handle pseudonymized processed information beyond the scope necessary to achieve the purpose of use. When creating pseudonymized processed information based on personal information we hold, we will carry over the purposes of use listed in this privacy policy as the purposes for using the pseudonymized processed information. When obtaining pseudonymized processed information through outsourcing, business succession, or joint use, we will promptly disclose the purpose of use. Additionally, if the purpose of use changes, we will disclose the revised purpose of use.

(5)In handling pseudonymized processed information, we will not cross-reference pseudonymized processed information with other information to identify the individuals related to the personal information used in the creation of that pseudonymized processed information.

(5)When pseudonymized processed information and deletion information are no longer needed, we will strive to delete such personal data and deletion information without delay.

(6)We will take necessary and appropriate measures for the safe management of pseudonymized processed information, including handling complaints related to the creation and other handling of pseudonymized processed information, to ensure its proper handling.

(7)We will implement necessary and appropriate measures for the safe management of pseudonymized processed information, handle complaints related to the creation and other handling of pseudonymized processed information, and take other necessary measures to ensure the proper handling of such information.

(8)We will not use contact information or other data included in pseudonymized processed information for purposes such as contacting the individual.

In the event of requests for disclosure, correction, suspension of use, etc., we will respond based on the methods prescribed by our company. For specific procedures, please contact us at the inquiry contact provided below for further guidance.

Please be aware that if you do not provide the personal information requested by us, or if there are any deficiencies in the information provided, it may result in the inability to provide subsequent products or services.

We implement necessary security management measures and properly manage personal information to prevent leakage, loss, and other incidents.