PRIVACY POLICY

Through our Precious Metals Business and Environmental Preservation Business,Lorene Japan Co., Ltd. is committed to preserving limited natural resources, preserving the global environment, and contributing to the realization of a sustainable world. Regarding the personal information collected during the course of business activities, we understand how important these assets are in today’s society of advanced information and communication, recognize that it is our important responsibility to properly handle personal information, and hereby declare that we will strive to protect personal information in accordance with the following policies.

1. Compliance with Laws and Regulations Regarding the Protection of Personal Information

We will comply with laws and other standards regarding the protection of personal information, and will handle personal information properly.

2. Acquisition of Personal Information

When we acquire personal information, we will notify, disclose, or specify the purpose of use, and we will acquire personal information through legal and fair means.

3. Purpose of Use of Personal Information

We will use the personal information we have acquired only to the extent necessary for the performance of our business, within the scope of the following purposes of use. In addition, if we entrust the handling of personal information to a third party, we will supervise the third party to ensure the proper use of personal information.

(1) Responding to customer inquiries and requests
(2) Conducting work related to recruitment and screening
(3) Providing services to shareholders
(4) Carrying out other activities related or incidental to the above smoothly

4. Provision of Personal Information to Third Parties

We will not provide personal information to third parties unless one of the following is true.

(3)法令に基づき提供を求められた場合

(1) When the individual agrees in advance
(2) When entrusted to an external party to the extent necessary to achieve the purpose of use
(3) When it is demanded based on laws and regulations
(4) When it is necessary for the protection of a person’s life, body, or property and it is difficult to obtain the individual’s consent
(5) When it is necessary to cooperate with a national or local public organization in implementing the work prescribed by laws and regulations, and obtaining the consent of the individual may interfere with the performance of such work
(6) When statistical data is provided or disclosed (information that cannot identify the individual)
(7)When it is provided to an entity listed in the scope of joint users as set forth in the following Article

5. Safety Management Measures for Personal Information

We maintain the accuracy and currency of personal information, manage it securely, and take necessary and appropriate safety management measures to prevent and correct unauthorized access, loss, destruction, tampering, and leakage of personal information. In addition, we will provide the necessary and appropriate supervision of employees and entrustees who handle personal information (including those who are referred to as re-entrustees). Safety management measures are specified separately in the “Personal Information Handling Regulations,” but the main contents are as follows.

(Formulation of Personal Information Protection Guidelines)
• In order to ensure the proper handling of personal data, these guidelines (Privacy Policy) have been formulated for “compliance with relevant laws, regulations, guidelines, etc.” and “a contact point for handling questions and complaints.”


(Establishment of rules concerning the handling of personal data)
• We have formulated the “Personal Information Handling Regulations” for handling procedures, persons in charge and personnel, their duties, etc. at each stage, including acquisition, use, storage, provision, deletion, and disposal.


(Systematic Safety Management Measures)
• In addition to establishing a person responsible for handling personal data, we have also clarified the scope of personal data handled by employees and those who handle it, and have established a system to report violations or signs of violations of the Personal Information Protection Act and the Personal Information Handling Regulations to the person responsible for handling personal data.


(Individual Safety Management Measures)
• We regularly train employees on matters to be aware of regarding the handling of personal data.
• Matters concerning the confidentiality of personal data are described in the Employment Regulations.


(Physical Safety Management Measures)
• Measures are in place to prevent unauthorized persons from viewing personal data in areas where personal data is handled.
• Measures have been taken to prevent theft or loss of equipment, electronic media, and documents, etc. that contain personal data.


(Technical Safety Management Measures)
• Access control is implemented to limit the scope of personnel in charge and personal information databases, etc. handled.
• A system has been introduced to protect information systems that handle personal data from unauthorized access or software from outside sources.

6. Disclosure, Correction, Suspension of Use, and Deletion of Personal Information

In the event of a request from the individual or their agent to disclose personal information or records of provision to third parties, or to correct, delete, or suspend the use of personal information, we will promptly respond to the request in accordance with laws and regulations after confirming their identity, unless one of the following is true.

(1) When there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party
(2) When it could significantly interfere with the proper performance of our company group’s work
(3) When it would violate laws or regulations

7.Personal Information Consultation Desk

For requests, complaints, inquiries, and confirmation regarding the disclosure, etc. of personal information, please contact the “Personal Information Consultation Desk” below.

135-0063
9F Ariake Frontier Building Tower B, 3-7-26 Ariake, Koto-ku, Tokyo
Lorene Japan Co., Ltd. Tokyo Head Office
Personal Information Consultation Desk

135-0063
9F Ariake Frontier Building Tower B, 3-7-26 Ariake, Koto-ku, Tokyo
Lorene Japan Co., Ltd.
Ehud Lotan, Representative Director

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