Basic Policy on the Proper Handling of Individual Numbers and Specific Personal Information

COMISMA Inc.
Representative Director: Koki Sato

1. 1. Compliance with applicable laws, regulations, guidelines, etc.

   Comisma Inc. (hereinafter referred to as “”we”” or “us”) complies with the “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures” (hereinafter the “”My Number Act””), the “”Guidelines for the Proper Handling of Specific Personal Information (For Businesses),”” the “”Act on the Protection of Personal Information”” (hereinafter the “”Personal Information Protection Act””) and ministry and agency guidelines regarding the handling of individual numbers and specific personal information (hereinafter “”Specific Personal Information””).

2. 2. Purposes of use

   We use the Specific Personal Information provided to us for the following purposes.

   1. (1) Specific Personal Information of business partners
      • Preparation of payment records related to real estate transactions
      • Preparation of payment records related to remuneration, fees, contracts, and monetary awards
   2. (2) Specific Personal Information of shareholders
      • Preparation of payment records related to dividends and distribution of surplus
   3. (3) Specific Personal Information of employees, etc.

      [Taxation]

      • Preparation of withholding tax certificates
      • Preparation of dependent exemption (change) declarations, insurance premium deduction declarations and special deduction for spouse of salaried worker declarations
        (*) Salary payment reports and severance income special withholding slips are included within the “”preparation of withholding tax certificates””

      [Social insurance]

      • Preparation of health insurance and employee pension insurance notifications, applications and claims
      • Preparation of unemployment insurance and workers’ compensation insurance notifications, applications and claims, and certificates
   4. (4) Specific Personal Information of spouses and relatives of employees, etc.

      [Taxation]

      • Preparation of withholding tax certificates
      • Preparation of dependent exemption (change) declarations, insurance premium deduction declarations and special deduction for spouse of salaried worker declarations

      [Social insurance]

      • Preparation of health insurance and employee pension insurance notifications
3. 3. Matters related to security control measures

   In order to prevent the leakage, loss, and damage of Specific Personal Information, and for the appropriate management of individual numbers, we have established and comply with our “”Individual Number and Specific Personal Information Handling Regulations””.

4. 4. Handling of consignment

   We may consign the handling of Specific Personal Information to third parties. In this case, we will supervise the contractor as necessary and appropriate in accordance with the My Number Act and the Personal Information Protection Act.

5. 5. Continuous improvement

   We strive to continuously improve our handling of Specific Personal Information.

6. 6. Disclosure of Specific Personal Information

   When we receive a request for disclosure of Specific Personal Information from an individual or their representative, we will respond without delay, except in the following cases.

   • If there is a risk of harm to the life, body, property, or other rights or interests of the individual or a third party
   • If there is a risk of significant hindrance to the proper conduct of our business
   • If it would violate a law or regulation

Please direct inquiries regarding the disclosure of Specific Personal Information and any questions or complaints to the following address.

[Personal Information Hotline]
Company: Comisma Inc.
Contact: Director of Information Security Office
Address: 9th Floor, PMO Jimbocho, 2-10-4 Kanda-Jimbocho, Chiyoda-ku, Tokyo
E-mail：pms@comicsmart.co.jp
Hours of operation: Weekdays from 10:00 to 16:00 (excluding year-end and New Year holidays and other designated holidays)

Established: January 1, 2016
Revised: February 1, 2017
Revised: January 1, 2018