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Privacy Policy

PRIVACY
POLICY

BREXA Group Privacy Policy

The BREXA Group (the companies in which BREXA Holdings, Inc. ("the Company") directly or indirectly holds a majority of the issued and outstanding voting shares or interests (the "Group Companies"; the Company and the Group Companies collectively, the "BREXA Group") is committed to protecting the trust of its customers, applicants, and related parties. In order to protect the relationship of trust with customers, applicants, and related parties, BREXA Group recognizes the importance of protecting the personal information of customers, other business partners, applicants, and related parties handled by the business, and all employees of the Group, at the head office and all branch offices, and will appropriately protect personal information based on the following privacy policy (hereinafter referred to as "this policy"). We will protect personal information appropriately based on the following privacy policy (hereinafter referred to as the "Policy").

The terminology used in this policy shall be as defined by the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"). The terminology used in this policy is based on the definition of the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act").

1. appropriate protection of personal information

The BREXA Group will appropriately and safely manage personal information obtained by establishing an organization to protect and manage personal information, and will take protective measures to prevent unauthorized access to personal information by outside parties and unauthorized use, loss, destruction, alteration, or leakage of personal information.

2. Appropriate acquisition, use and provision of personal information

When acquiring personal information, we will determine the purpose of use in light of the nature of our business, and acquire, use, and provide personal information within the scope of that purpose. All employees and other related parties (hereinafter collectively referred to as "employees, etc."), regardless of their titles, including representative directors, directors, auditors, executive officers, advisors, directors, employees, contract employees, part-time employees, etc. All employees and other related persons (hereinafter collectively referred to as "Employees, etc.") understand the purposes for which personal information is used, and will not use personal information for purposes other than those necessary to achieve the purposes of use. In addition, we will take measures to prevent the use of acquired personal information for purposes other than the intended use.

3. Compliance with laws, national guidelines, and other norms regarding the handling of personal information

We will keep abreast of laws, national guidelines, and other norms related to the handling of personal information that are relevant to our business, and promptly reflect them in the BREXA Group's personal information protection management system when they are enacted, revised, or abolished.

4. Management of contractors

The BREXA Group will instruct and supervise subcontractors to whom it discloses personal data obtained in accordance with the preceding paragraph, to enter into confidentiality agreements and to handle and protect such data appropriately.

5. Prevention and correction of risks to personal information

We recognize the risk of leakage, loss, or damage of personal information, and will take reasonable security measures to protect personal information from physical, human, technical, and operational perspectives. In addition, we will periodically review the risks to personal information and the effectiveness of our security measures, and take corrective actions to ensure that they remain effective.

6. Complaints and consultation regarding personal information

We will establish a contact point to respond appropriately and promptly to any complaints or consultations from the individual regarding the handling of personal information and the personal information protection management system.

7. Continuous Improvement of Personal Information Protection System

In order to maintain appropriate protection of personal information, BREXA Group will formulate and implement rules and regulations based on this policy and continuously improve them through periodic monitoring of their contents.

Please note that this policy is subject to change without notice. Any changes to the privacy policy will be posted on the BREXA Group website.

Date of enactment: July 1, 2025

BREXA Holdings Inc.

Kenji Kamiyama, Chairman and Representative Director

For inquiries, please contact

For inquiries regarding our privacy policy, please contact us at the contact information below.

For inquiries regarding the contents of the Privacy Policy, please contact
BREXA Holdings Inc.

Personal Information Management System Secretariat (Information Security Section, Compliance Management Division)

1-8-3 Marunouchi, Chiyoda-ku, Tokyo 100-0005, Japan

e-mail: information-security@brexa.com
TEL: 03-3286-4888 FAX: 03-3286-4999

Handling of Personal Information by BREXA Holdings, Inc.

The Company will not use any personal information it acquires (excluding specified personal information (personal information that includes personal numbers and personal numbers in its contents). Please see * below for more information on Specified Personal Information) ) will be used for the following purposes. Personal information requiring special consideration will be obtained only with the consent of the person concerned, except in cases where such information should be treated as an exception under laws and regulations. In cases where the purpose of use of personal information is separately specified to the person at the time of acquisition, such personal information will be used for the purpose specified at the time of acquisition.

Personal information about customers Responding to inquiries, etc.
Sending of materials, etc. upon request
Information on executives and employees of business partners Information on services provided by the Company and related information
Requests for questionnaires, surveys, etc. regarding the services we provide and related information
Accepting applications for various seminars
Management of business partners
Business communications and contract performance
Response to inquiries, etc.
Information on users of human resources services Registration Procedures
Provision of the human resource services for which you have applied
Registration procedures for job placement, interviews, consultations and provision of job information (including job information from business partners)
Providing information to employers
Provision of information to business partners for job placement
Provision of information on human resources services, including information and proposals
Counseling, career support, etc.
Planning, development, and improvement of human resource services and campaigns, as well as research, statistics, and analysis for these purposes
Important notices and other communications regarding human resources services
Improvement of operation, etc. related to job placement
Other work related to or incidental to job placement
Information on Reapplication
Compliance with Laws and Regulations
Responding to inquiries, consultations and complaints
Information about applicants for jobs Receipt of applications for employment selection, implementation and notification of results
Improvement of management and other aspects of recruitment and selection
Other work related to or incidental to recruitment and selection, etc.
Proper assignment (placement) of employees, including medical checkups at the time of hiring
Employment management, labor management and personnel evaluation after joining the Company
Providing education and training, and various welfare services
Business communication, emergency communication in the event of a disaster, etc.
Requests for questionnaires for the purpose of service improvement, etc.
  • However, with regard to specified personal information, regardless of whether or not the person concerned has given consent, the "Act on the Use of Personal Identification Numbers for the Purpose of Identifying Specific Individuals in Administrative Procedures
     (hereinafter referred to as the "Number Utilization Law"). (hereinafter referred to as the "Number Utilization Law"), the Company will use the information only within the scope of the following purposes
  • Clerical work related to notification, etc. of employment insurance
  • Administration related to health insurance and employees' pension insurance notifications, etc.
  • Affairs related to notification, etc. of National Pension Plan No. 3 insured persons
  • Preparation and submission of withholding tax certificates and other clerical work related to withholding tax
  • Administration related to the preparation of declarations, notifications, and application forms related to property-formation housing savings and property-formation pension savings
  • Affairs related to the preparation and submission of payment records for remuneration, fees, contracts, and monetary awards
  • (4) Affairs related to the preparation and submission of payment records for real estate royalties, consideration for the transfer of real estate, etc.
  • Affairs related to each of the above items.

3. joint use

We may share the personal data we have acquired with other companies as follows. However, the Company will not share personal data beyond the scope necessary to achieve the purpose of use.

Items of Personal Data to be Shared

Attribute information such as address, name, telephone number, age, gender, and e-mail address, as well as information and inquiries obtained

Scope of joint users

Domestic Subsidiaries

Purposes of use by persons who share use

Same as the purpose of use described in "2. Purpose of Use of Personal Information

Persons responsible for the management

Name: BREXA Holdings Inc.

Address: Marunouchi Trust Tower Main 19F, 1-8-3 Marunouchi, Chiyoda-ku, Tokyo

Name of Representative: Kenji Kamiyama

4. management of personal information

The Company will not use any personal information (excluding Specified Personal Information) that it acquires. Please refer to * below for Specified Personal Information.) ) will be managed strictly and appropriately in accordance with the Company's rules and regulations. Personal information that is no longer needed for use will be promptly deleted or disposed of in accordance with the Company's prescribed procedures.

  • OSBS, a subsidiary of the Company's domestic group, will be entrusted with the management of the specified personal information.
     We will manage personal information strictly and appropriately in accordance with the laws and regulations concerning specified personal information and our company's rules.

5. implementation of safety control measures

We have implemented the following measures for the secure management of personal data.

Personnel safety control measures

We provide regular training to our employees on matters concerning the handling of personal data. In addition, we have obtained a written pledge that includes items related to the confidentiality of personal data.

Physical Safety Control Measures

Necessary measures are taken to control the area where personal data is handled, to prevent theft of equipment and electronic media, etc., to prevent leakage when electronic media, etc., are carried, to delete personal data, and to dispose of equipment and electronic media, etc.

Technical Safety Control Measures

Necessary measures are taken with respect to information systems, including access control, identification and authentication of access persons, prevention of unauthorized access from outside, and prevention of leaks associated with the use of information systems.

6. provision of personal data to third parties

The Company shall not use any personal data it has acquired (excluding Specified Personal Information. Please refer to * below for Specified Personal Information). ) to third parties other than subcontractors without the consent of the individual. In addition, we will not provide any personal-related information that is expected to be acquired as personal data at the recipient to any third party without the consent of the person in question. However, this does not apply to cases where there is a legitimate reason, such as when disclosure is required by law.

  • Specified personal information will not be provided to third parties, with or without the consent of the individual, except to subcontractors or in accordance with Article 19 of the Act on the Use of Personal Information Numbers and other laws and regulations.

7. Retention period of personal information, disposal, etc.

Personal information acquired will be retained for the legally required number of years and then promptly disposed of or deleted in accordance with our company's prescribed procedures.

Disclosure, Correction, Suspension of Use, etc. of Retained Personal Data

If you wish to request disclosure, correction, etc. (correction, addition, or deletion) or suspension of use, etc. (suspension of use or deletion and suspension of provision to a third party) of personal data in our possession that identifies you in accordance with laws and regulations, or if you wish to request disclosure of records pertaining to provision of personal data in our possession to a third party that identifies you in our possession, or records pertaining to confirmation of the provision of your personal data to a third party, please contact us promptly after confirming your identity. If you wish to request disclosure of records pertaining to the provision to a third party of personal data that identifies you or records pertaining to confirmation of the provision to a third party of personal data that identifies you with respect to personal data held by us, please contact us at the contact point listed at the end of this policy, and we will respond promptly within reasonable limits after confirming your identity.

However, this does not apply to cases in which the information infringes on the rights of other third parties, or in which the Company determines that the information will significantly interfere with the proper execution of the Company's business, or in which the information is in violation of laws and regulations.

Contact for complaints and inquiries regarding the handling of personal information

If you have any questions, concerns, complaints, or other inquiries regarding our personal information protection efforts, please contact the "Personal Information Consultation Desk" below.
(We do not accept requests made in person at our office. Thank you in advance for your understanding.)

Contact]

Personal Information Consultation Service, BREXA Holdings Inc.

1-8-3 Marunouchi, Chiyoda-ku, Tokyo 100-0005, Japan

e-mail: pi-jinji@brexa.com

TEL:03-3286-5144 FAX:03-3286-4999

BREXA Group Cookie Policy

The BREXA Group (the companies in which BREXA Holdings, Inc. ("the Company") directly or indirectly owns a majority of the outstanding voting shares or interests (the "Group Companies", and collectively with the Company and the Group Companies, the "BREXA Group") has established this policy. The websites and web services operated by the BREXA Group may use cookies and similar technologies to collect certain information in accordance with this policy.

About Cookies

  1. Cookies" are a type of file that is sent from a web server to your computer when you access a website.
    A cookie is a small file that is sent to the browser of your computer or mobile device and stored on the hard disk drive of that device. When you visit the BREXA GROUP website again, the BREXA GROUP can recognize your browser using a cookie.
  2. Cookies set by BREXA Group are "1st Party Cookies", third parties with whom we work
    Cookies set by the "3rd Party Cookie" are called "3rd Party Cookies".
  3. Cookies used by the BREXA Group themselves do not contain any personal information such as your name, address, telephone number, or e-mail address.

2. purpose of use of acquired information

  1. Analyze website usage (access, traffic, routing, etc.) to improve the performance of the website itself.
  2. To improve and inform customers of the services provided by the BREXA Group through the website.
  3. The BREXA Group utilizes the advertising services (display advertising/ remarketing/ retargeting functions) of ad-serving companies to deliver notices (advertisements) to past visitors to this site when they visit certain pages. In such cases, cookies are used to obtain information on the history of visits to this site.

3. provision of acquired information

We may classify you according to specific conditions inferred from the information obtained by cookies, and provide information about this classification to our partners such as ad-serving companies, media companies, advertising companies, and advertisers.

4. access analysis and advertising distribution services used by the BREXA Group

Source. Types of information to be collected Collection Method opt-out link Privacy Policy
Facebook User ad click history, site visit history Set up by Facebook Pixel to measure the effectiveness of ads and provide targeted advertising. opt out Facebook Privacy Policy
Google (WWW search engine) User's site visit history and operation history It is set up by Google Analytics to track user visits to the site and analyze site performance. opt out Google Privacy Policy
Google (WWW search engine) Conversion data, ad click history It is configured by Google Tag Manager and provides conversion link functionality. opt out Google Privacy Policy
Bing User ad click history, site visit history Set up by Bing Ads to measure the effectiveness of your ads and provide targeted advertising. opt out Microsoft Privacy Policy
an unknown User session ID, ad click history It is set up by X to identify the user's session and provide targeted advertising. opt out X Privacy Policy

5. cookie rejection/restriction

You can reject or limit cookies by changing the settings of your browser, etc., and you can delete cookies created on your device at any time. However, if you do not accept or delete cookies, you may not be able to use certain features of the BREXA Group website.

6. Changes to Cookie Policy

Please note that this policy is subject to change without notice.

Any changes to our cookie policy will be posted on our website.

July 1, 2025 Establishment