PRIVACY POLICY

Axelspace Holdings Corporation ("Axelspace HD") fully understands the importance of personal information protection and, in order to fulfill its social responsibilities while conducting business activities, will comply with the Act on the Protection of Personal Information (Act No. 57 of 2003, "APIP") and other related laws, regulations, and guidelines, and will handle personal information in accordance with the following privacy policy.

  1. Acquisition of Personal Information

    Axelspace HD will acquire personal information by legal and fair means within the scope necessary for business purposes.



  2. Purposes of Use for Personal Information

    1. Personal Information Acquired Directly by Axelspace HD

      1. Personal information of shareholders

        • To exercise rights and perform obligations under the Companies Act and other laws
        • To plan, review, and implement various measures to build and maintain a smooth relationship between shareholders and Axelspace HD
        • To provide information related to Axelspace HD 's or its group companies' products or services (collectively "Services, etc.") and information about newly developed Services, etc.
        • To manage shareholder information
        • To respond to inquiries
      2. Personal information of customers (including administrators and staff)

        • For the purpose of reviewing, managing, and implementing transactions
        • To provide guidance and communication regarding the Services, etc., that have been used
        • To respond to inquiries
        • To propose, advertise, and perform other marketing for Services, etc., of Axelspace HD or its group companies other than the Services, etc., that have been used
        • To use as reference for the improvement of Services, etc., and for the planning, research, development, and marketing of new Services, etc.
        • For the purpose of requesting and conducting interviews, surveys, etc.
      3. Personal information of individuals who have requested materials or made other inquiries to Axelspace HD

        • To respond to inquiries
        • To provide information related to the Services, etc., of Axelspace HD or its group companies, or information that Axelspace HD considers beneficial to customers
        • For the purpose of requesting and conducting interviews, surveys, etc.
      4. Personal information of individuals who have applied or participated in Axelspace HD 's recruitment activities ("Recruitment Candidates")

        • To determine whether a Recruitment Candidate matches Axelspace HD 's hiring criteria
        • To confirm past application history with Axelspace HD
        • To contact Recruitment Candidates for the purpose of selection
      5. Personal information of employees and officers of Axelspace HD ("Employees, etc.")

        • To provide information on other employment opportunities to Recruitment Candidates
        • To review and formulate future recruitment policies for Axelspace HD and its group companies
        • To provide information to Recruitment Candidates about recruitment-related events of Axelspace HD and its group companies.
        • To perform necessary procedures for employment, social insurance, provision of welfare benefits, business communication, various procedures required by law, payment of various wages or compensation, and other necessary procedures for employment management
        • To perform necessary procedures and communication for various congratulatory and condolence events, and other necessary procedures for changes in the personal status of Employees, etc.
        • To ensure the life and health of Employees, etc., by the company taking appropriate measures so that Axelspace HD can fulfill its duty of care and other legal obligations to Employees, etc.


    2. Personal Information Handled by Axelspace HD on Consignment from Customers

      1. Personal information handled on consignment from customers in conjunction with the provision of services to customers

        • To perform services for customers and other tasks consigned by customers


  3. Provision of Personal Data

    1. Provision to Third Parties

      Axelspace HD will not provide personal data to third parties without the consent of the data subject, except in the following cases or as otherwise provided by law.

      1. When based on laws and regulations
      2. When it is necessary for the protection of a person's life, body, or property and it is difficult to obtain the consent of the data subject
      3. When it is particularly necessary for the improvement of public health or the sound development of children and it is difficult to obtain the consent of the data subject
      4. When it is necessary to cooperate with a national agency, a local government, or a person entrusted by them in executing the affairs prescribed by laws and regulations, and obtaining the consent of the data subject is likely to impede the execution of the said affairs
      5. When personal data is provided to an academic research institution, etc., and the said academic research institution, etc., needs to handle the said personal data for academic research purposes (including cases where a part of the purpose of handling the said personal data is for academic research purposes, and excluding cases where there is a risk of unjustly infringing on the rights and interests of the data subject)
    2. Joint Use

      Notwithstanding the above (1), Axelspace HD may jointly use the personal data described below with companies within the Axelspace HD Group within the scope of the purposes of use described below.

      • Personal information of individuals who have requested materials or made other inquiries to Axelspace HD

        • Items of personal data: Name, address, phone number, email address, name of affiliated company or organization, name of affiliated department
        • Purpose of use: As per 2. (1) c above
        • Responsible party for the management of personal data: Yuya Nakamura, Representative Director, Axelspace Holdings Corporation
          Clip Nihonbashi Building, 3-3-3 Nihonbashi Honcho, Chuo-ku, Tokyo 103-0023
      • Personal information of Recruitment Candidates

        • Items of personal data: Name, address, phone number, email address, date of birth, educational background, nationality, work history, record of rewards and punishments
        • Purpose of use: As per 2. (1) d above.
        • Responsible party for the management of personal data: Yuya Nakamura, Representative Director, Axelspace Holdings Corporation
          Clip Nihonbashi Building, 3-3-3 Nihonbashi Honcho, Chuo-ku, Tokyo 103-0023
      • Personal information of Employees, etc.

        • Items of personal data: Name, address, phone number, email address, date of birth, educational background, nationality, work history, information on graduation certificates, information on residence cards for foreign nationals, emergency contact information, pension number, employment insurance number, information on health insurance cards
        • Purpose of use: As per 2. (1) e above.
        • Responsible party for the management of personal data: Yuya Nakamura, Representative Director, Axelspace Holdings Corporation
          Clip Nihonbashi Building, 3-3-3 Nihonbashi Honcho, Chuo-ku, Tokyo 103-0023
    3. Provision to Consignment Parties

      Notwithstanding the above (1), if Axelspace HD consigns all or part of the handling of personal data, it will provide the personal data to the consigned party without obtaining the consent of the data subject. In this case, Axelspace HD will exercise necessary and appropriate supervision over the consigned party to ensure the safe management of the consigned personal data.



  4. Safety Management Measures

    Axelspace HD will take necessary and appropriate measures for the prevention of leakage, loss, or damage of personal data, and for other safe management of personal data. For inquiries regarding the safety management measures taken by Axelspace HD, please contact via the inquiry form listed in "7. Contact Point" below.

  5. Use of Cookies

    Axelspace HD may use cookies for purposes such as remembering the settings of websites, etc., for users of Axelspace HD 's websites, etc. ("Users"), analyzing website usage, and delivering advertisements that match Users' interests and concerns. A cookie is a small text file that is stored on a User's device when they access a website. By writing an identifier (Cookie ID) into this cookie, the User can be identified when they access the website again from the same device by referring to this identifier. By the User's browser sending the information stored in the cookie to Axelspace HD, Axelspace HD can know information such as the User's website browsing history.

  6. Disclosure of Retained Personal Data, etc.

    • Based on the provisions of APIP, data subjects can request the notification of the purpose of use of retained personal data, the disclosure of retained personal data or records of provision to third parties, the correction, addition, or deletion of content, or the suspension of use, erasure, or suspension of provision to third parties (collectively "Disclosure, etc."). When a request for Disclosure, etc., of retained personal data is made based on APIP, Axelspace HD will confirm that the request is from the data subject themselves and will perform the Disclosure, etc., without delay, and will notify the data subject of that fact (if there is no applicable retained personal data or if Axelspace HD decides not to perform Disclosure, etc., for a reason prescribed by law, Axelspace HD will notify the data subject of that fact).
    • Please note in advance that a fee (1,500 yen per request) is required for requests for the disclosure of retained personal data or records of provision to third parties.
    • Requests for Disclosure, etc., must be made using the prescribed form of Axelspace HD, and we cannot accept requests made in any other format. Please contact us via the inquiry form listed in "7. Contact Point" below for the prescribed form of Axelspace HD.
    • Personal information acquired in connection with a request for Disclosure, etc., will be handled appropriately only within the scope necessary to respond to the request.
  7. Contact Point

    Axelspace HD strives to respond sincerely and promptly to questions, opinions, complaints, etc., regarding the handling of personal information. For questions, etc., regarding the handling of personal information, please contact via the inquiry form.

    August 13, 2025
    Yuya Nakamura
    Representative Director
    Axelspace Holdings Corporation