MISUMI Group Inc.

Privacy Policy for Shareholders

This Privacy Policy (“Policy”) sets forth how MISUMI Group, Inc. (“MISUMI”) handles the personal information of shareholders acquired and used for its business.
MISUMI will appropriately handle the personal information of shareholders by observing the MISUMI Group Fundamental Privacy Policy, this Policy, and applicable law and regulations.
 

Article 1 Definition

Article 1 Definition

Terms in this Privacy policy shall be defined as follows:

(1)

“Shareholder” shall mean a person, a company or any organization who owns shares of MISUMI.

(2)

“Personal Information” shall mean information relating to a living individual and that either contains a name, date of birth, or other personal descriptions which identify a specific individual (including those which can be readily collated with other information and thereby identify a specific individual), or contains an individual identification code.

(3)

“Principal” means the person who is identified by such personal information.

Article 2 Personal Information that MISUMI Acquires

Article 2 Personal Information that MISUMI Acquires

MISUMI may collect the following Personal Information of Shareholders to use them for the Purpose of Use set in Article 3:

(1)

Names, the names of company or organization representatives if the shareholder is a company or organization, address, number of shares, the date of acquisition of shares, phone numbers, email address, and similar types of information.

(2)

Contents of communications between Shareholder and MISUMI such as conversations, written communications, telephone calls, emails, interviews, etc.

Article 3 Purpose of Use

Article 3 Purpose of Use

1.

Personal Information that MISUMI collects shall be used for the following purposes. MISUMI will not use the Personal Information for any other purposes without the Principal’s consent.

(1)

To exercise Shareholders’ rights or pursue the obligations based on the Company Act.

(2)

To provide information to Shareholders regarding business operations of MISUMI and its affiliates and subsidiaries.

(3)

To take actions to improve the relationship between Shareholders and MISUMI.

(4)

To provide payments such as dividends or information about the status of the same to Shareholders.

(5)

To manage shareholders, such as by aggregating or reviewing Shareholders data based applicable laws and regulations, statistics, or in any other way.

(6)

To respond to the inquiry from Shareholders.

2.

MISUMI will not alter this Purpose of Use beyond that reasonably necessary to the previously disclosed Purpose of Use without notifying the Shareholder. MISUMI may notify Shareholder of alterations of this Purpose of Use through publication on MISUMI’s website.

Article 4 Disclosure to Third Parties

Article 4 Disclosure to Third Parties

MISUMI will not disclose Personal Information of Shareholders to a third party without  obtaining the Principal's consent, except in the following cases:

(1)

When Personal Information is provided for the Purpose of Use set in Article 3, after concluding non-disclosure agreements requiring the entrusted parties to refrain from using Personal Information for any other purpose than the entrusted matter.

(2)

When permitted as an exception under applicable laws and regulations.

(3)

When Principal has explicitly consented to the disclosure.

(4)

When necessary under applicable laws and regulations.

Article 5 Disclosure, Correction, and Suspension etc.

Article 5 Disclosure, Correction, and Suspension etc.

MISUMI shall respond promptly and in good faith to Shareholder requests to:

(1)

notify the Shareholder of the Purpose of Use; 

(2)

disclose, correct, add, delete, and suspend the use of retained personal data;

(3)

suspend the provision of retained personal data to third parties; or

(4)

disclose a record of provision to third parties of Shareholder’s Personal Information
Please contact MISUMI at the following address. Note that a fee, which will be specified by MISUMI, will be charged separately for notification of the Purpose of Use and disclosure of retained personal data (including disclosure of records of provision to third parties.)

<Contact>

<Contact>

Corporate Relations Department, IR/SR Team, MISUMI Group Inc.

Article 6 Matters relating to the Retained Personal Data

Article 6 Matters relating to the Retained Personal Data

1.

Information of Personal Information Handling Business Operator
MISUMI Group Inc.
KUDAN-KAIKAN TERRACE 6-5,Kudanminami 1-Chome, Chiyoda-ku, Tokyo, 102-8583, Japan
Representative Director and Chairman Kosuke Nishimoto

2.

Security Control Action
MISUMI takes necessary and appropriate security control measures, in order to manage personal data and prevent leakage, loss, damaging etc. The security control measures are as follows:

(1)

Organizational Security Control
MISUMI has established internal rules, such as our Information Security Basic Policy, Information Security Guidelines, and Rules for Handling Personal Information, and handles personal data according to these internal rules. MISUMI has also appointed a person responsible for handling of personal information, and conducts periodical investigation on the status of personal data handling, and has a system to respond to any incidents such as a leakage accident.

(2)

Human Security Control
MISUMI periodically conducts information security training for its employees, including how to handle personal information to ensure that personal data is handled appropriately. When personal information is provided as set forth in Article 4, MISUMI manages and supervises such parties so that the personal data is handled appropriately.

(3)

Physical Security Control
MISUMI uses security cards for entry to its offices where personal data is stored, and implements other security control actions to protect the information from being stolen or lost such as locking devices and encrypting electronic media. In the case a device or electronic media is stolen or lost, MISUMI has implemented measures such as encryption or password protection to prevent personal data from being accessed. Additionally, when personal data is to be deleted, or devices or electronic media including personal data are to be discarded, MISUMI implements measures to ensure that personal data is not recoverable from the deleted or discarded media.

(4)

Technical Security Control
Access to personal information is controlled by access restrictions to limit the scope of those who have access, and identification and authentication are performed for those who access information systems that handle personal data. Additionally, MISUMI uses its security controls to protect the systems that handle personal data to prevent unauthorized access, illegal software, or information leakage.

(5)

Understanding the environment in other countries.
When MISUMI processes personal data in other countries, MISUMI understands all applicable legal requirements for personal data protections in those other countries and applies appropriate security control measures to comply with them.

April 1, 2022

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