Chapter 1: Ateam’s Basic Personal Data Protection Policy

Ateam Inc. (hereinafter, “we” or “us”) recognize the social importance of protecting personal information and is committed to adhering to the following policy concerning the protection of the various kinds of personal information entrusted to us.

Chapter 2: Handling of Personal Data

We comply with all laws and regulations concerning personal information protection and handle it in an appropriate manner as described below. There are some situations in which all of the provisions of this Section 2 do not apply, and alternatively, provisions related to the handling of personal information that are separately published at each link apply. Please reference provisions defined at each link for details.

1. Handling Personal Information of shareholders
   https://www.a-tm.co.jp/ir/strategy/privacypolicy/ (Japanese)
2. Handling Personal Information of applicants for recruitment of us and our affiliated companies (hereinafter “Our Group Companies”)
   https://www.a-tm.co.jp/recruit/importantnote/ (Japanese)

1. Personal Data Management

1. We strive to protect personal data (including personal information that we have obtained or intends to obtain and that is intended to be treated as personal data, the same shall apply hereinafter) and have implemented appropriate safety measures in accordance with laws, guidelines, and internal regulations to prevent personal data leaks, loss, or destruction/damage. Our employees are trained in the correct handling of personal data and take all possible measures for its protection.
2. Within the scope necessary to achieve the purpose of use, we may outsource personal data handling operations in part or in whole to a third party. In such a case, we shall provide necessary and appropriate direction to the third party to ensure they safely handle personal data.
3. If you wish to know the details of the safety management measures, please contact the “Ateam Inc. Customer Support Center" described in Chapter 1, Section 5.

2. Acquisition and Purpose of Use

Definition of "Personal Information"
"Personal Information" means information relating to a living individual described below.

1. Name, date of birth or other details contained in such information, that can identify the specific individual (including information that in reference to other information enables identification of a specific individual).
2. Information which contains an individual’s Identification Code prescribed by Cabinet Order under Article 2, paragraph (2) of the Act on the Protection of Personal Information.

Purpose of Use
Unless otherwise specified, we acquire personal information for the following purposes and use it within the scope necessary to achieve the purpose:

1. To provide information regarding us or Our Group Companies;
2. To introduce services operated by Our Group Companies;
3. To create statistics data regarding the activities of us or Our Group Companies;
4. To respond to inquiries, we or Our Group received;
5. To send important notice to use services operated by Our Group;
6. To conduct research analytics regarding services developed and operated by Our Group Companies;
7. To notify and operate campaigns that we or Our Group Companies hold or cooperated;
8. To ensure the safe provision of services operated by Our Group Companies;
9. To implement business management and internal management of Our Group Companies; and
10. To proceed office processing regarding each above smoothly and appropriately.

3. Provision of Personal Information to Third Parties

We do not provide personal information to any third parties, except in the following cases:

1. Prior consent is obtained from you;
2. We outsource personal information handling operations in part or in whole within the scope necessary to achieve the purpose of use;
3. The personal information is provided in connection with a business succession due to merger, company split, business transfer, or any other reasons;
4. Provision of personal information is necessary for the protection of a human life, body, or property, and acquiring your consent is difficult;
5. Provision of personal information is necessary for cooperating with a governmental organization or a local government, or an individual entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining your consent is likely to impede the execution of affairs concerned;
6. The disclosure of personal information is required by a court, public prosecutor's office, police, or other organization that possesses authority similar to these through appropriate procedures;
7. When provided to academic research institutions, etc., for the purpose of academic research (including cases where part of the purpose is for academic research and except in cases where there is a risk of unjust harm on the rights and interests of individuals.); or
8. When otherwise permitted by the Act on the Protection of Personal Information or other laws and regulations.

4. Joint Use

We may jointly use personal information described below.

• Scope of Joint Use
  Our Group Companies (see below for details)
  https://www.a-tm.co.jp/en/about/outline/
• Purpose of Joint Use
  Refer to 2.2 of Section 2
• Personal Information in Joint Use
  Name, date of birth, address, phone number, attribute information such as e-mail address, occupation, gender and other information provided, contents of inquiries, etc.
• Entity Responsible for Management of Personal Information in Joint Use
  Ateam Inc.
  Dai Nagoya Building, 28-12 Meieki 3-chome,Nakamura-ku, Nagoya 450-6432, Japan
  Takao Hayashi, President
• Method of Acquisition
  Oral, documents (including application forms, electromagnetic records, websites, etc.), audio or video recording, electromagnetic means, or other appropriate means through business operations and inquiries of each Our Group Companies

5. Request of Disclosure, etc. and Procedures Regarding Personal Information

If you wish to disclose, amend, add to, or remove personal information, please contact the "Customer Support Center" described in Chapter 1, Section 5. Please be aware when making inquiries that identity confirmation is required (except when identity confirmation is not required by law).

6. Handling of Cookies, Etc. on Websites

Use of Cookies and Web Beacons
We acquire statistical usage data from cookies and web beacons to improve provision of information, analyze statistics data in connection with us and Our Group Companies.

A “cookie” is a small piece of data sent from a website and stored in your web browser to make websites more convenient to use. We use cookies when you access our websites. You may set your browsers to refuse reception of cookies, but should be aware that such action may make all or portions of our website unavailable. We are not responsible for the handling of personal information of websites operated by other companies, which are linked to our website.

A "web beacon" is a small image file embedded in a website that we use to track whether someone has visited our website, number of visits, etc. that we use to analyze performance. Web beacons contain no information that can be used to identify an individual.

Advertisements Through Third-Party Distributors (*1)
Our corporate site and recruitment site do not use third-party distributors. However, there are some situations that services which have linked in each of above websites, operated by Our Group Companies, use third-party distributors.

Use of Access Analysis Tools
We use access analysis tools provided by third-party operators for the purpose of improving our websites, etc. These access analysis tools send to the third-party operators that provides the tools, for analysis, data about your activity on our websites, including data about the pages you visit. This information is collected anonymously and cannot identify an individual. However, we may link the personal information we stored to the analysis information and use it to grasp the usage situation, etc. in order to display information that may be useful for you on our websites. Information collected by these third-party operators directly is managed subject to their own privacy policies. Please refer to the following for the name of the third-party operators of the access analysis tools we introduce, the name of the access analysis tools, the terms of use, privacy policy, opt-out method of the operators, and the content of the provision of information to the operators.

• Use of Access Analysis Tools
  Google Analytics(Google LLC)
• Terms of Service
  https://marketingplatform.google.com/about/analytics/terms/jp/
• Privacy Policy
  https://policies.google.com/privacy
• Opt-Out Method
  https://tools.google.com/dlpage/gaoptout
• Provided Contents
  Cookie

7. Amendment

Ateam Inc. may amend this Privacy Policy in accordance with changes or other amendments in the law.