In accordance with the Act on the Protection of Personal Information, we hereby announce the following

1. Purpose of Use

     We handle personal information and personal data for the following purposes of use. If these purposes of use are changed, we will notify the person concerned or announce the change on our website.

（1）Personal information of our executives and employees (including former executives and employees) and their family members

    ・Recruitment, retirement, wages and other matters related to working conditions.
    ・Personnel evaluations, awards, disciplinary actions, and personnel transfers (including transfers to other companies and organizations).
    ・Matters related to management, labor management, and employee benefits.
    ・Payment of salaries, bonuses, benefits, retirement allowances, pensions, etc.
    ・Procedures for social insurance, welfare benefits, and payment of taxes.
    ・Ensuring occupational health and safety and confirming the safety of employees in the event of a disaster.
    ・In addition to the above, administrative work stipulated in the employment regulations, administrative work related to our company’s management in accordance with laws and regulations.
    ・To contact you in the course of business.

（2）Personal information of applicants for our new graduate and career employment

     To provide information to applicants, to conduct selection activities, or to contact applicants in connection with these activities.

（3）Personal information when engaged in our business

     To contact you in the course of business, to manage your access to our company, and to hold meetings regarding business matters when you are engaged in some kind of business, such as as a member of a project team, etc., for the purpose of implementing business.

（4）Personal information concerning applicants for and participants in seminars, symposiums, exhibitions, lectures, etc. hosted or co-hosted by the Company

    To process your application, contact you after your application, guide you to similar seminars, etc., and respond to your inquiries, etc.

（5）Personal information of those who contact us for complaints, consultation, etc.

    To respond to complaints and consultations, and to contact you in order to respond to such complaints and consultations.

（6）To research and analyze the usage of our website, etc.

    To understand the trends of our site users. This is intended to see what kind of people our activities are contributing to, and will not be used for any other purpose. We use Google Analytics and Microsoft Clarity as described below.

（7）Other cases than above

    When we directly acquire personal information, we will promptly notify or publicly announce the purpose of use in writing or by an alternative method. However, this excludes cases where the purpose of use is clear from the circumstances of the acquisition of personal information.

2. Security Management Measures

（1）Security management measures for organizations

    As internal regulations, we have established rules for handling personal information to comply with the Personal Information Protection Law and other laws and regulations, and have appointed a person responsible for handling personal information to take necessary actions at each stage of personal information acquisition, use, storage, provision, deletion and disposal, etc. In addition, in case of accidents, etc. (including the fear of such accidents), the Company has established emergency response procedures. The Company conducts periodic self-inspections of the status of personal data handling.

（2）Human safety management measures

    In addition to stipulating confidentiality matters in its employment regulations, the company provides its employees with training at the time of hiring and periodically thereafter.

（3）Physical safety management measures

    In areas where personal data is handled, the Company implements access control for employees, restricts the equipment, etc. that they may bring into the office, and implements measures to prevent unauthorized persons from viewing personal data. We take measures to prevent theft or loss of equipment, electronic media, and documents that handle personal data, and implement advanced encryption for personal data when such equipment, electronic media, etc. are carried, including within the business site.

（4）Technicall safety management measures

    We have introduced a system to protect information systems that handle personal data from unauthorized external access and malware, and we limit the scope of access to personal information databases, etc. by granting the minimum necessary access privileges.

（5）External environment

    When handling personal data in a foreign country, we take necessary and appropriate measures for security management, including advanced encryption and confidentiality of personal data, based on our understanding of the systems for the protection of personal data in that foreign country.

3. Joint Use of Personal Data

    In seminars, symposiums, exhibitions, lectures, etc. (hereinafter referred to as "Seminars, etc.") that we co-sponsor with other companies, etc., we may share the use of personal data with such co-sponsors. In such cases, we will notify or publicly announce the joint use of personal data, the items of personal data subject to the joint use, the scope of the joint users, the purpose of use of the joint users, the name and address of the person responsible for managing personal data, and in the case of a corporation, the name of its representative, at the time of the announcement of the seminar or other event.

4. Provision of Personal Data to Third Parties

    We will not provide personal data to third parties without the consent of the individual. However, we may provide personal data to third parties in the following cases as stipulated in each item of Article 27, Paragraph 1 of the Personal Information Protection Law.

1．When required by law or regulation.
2．When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the person in question.
3．When it is especially necessary to improve public health or to promote the sound growth of children and it is difficult to obtain the consent of the individual concerned.
4．When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining your consent is likely to impede the execution of such affairs.
5．Where the Business Operator Handling Personal Information is an Academic Research Institution, etc., and the provision of said Personal Data is unavoidable for the publication of the results of academic research or for teaching (except where there is a risk of unjustified infringement of the rights and interests of individuals).
6．Where the Business Operator Handling Personal Information is an academic research institution, etc., and it is necessary to provide said Personal Data for academic research purposes (including cases where a part of the purpose of providing said Personal Data is for academic research purposes, but excluding cases where there is a risk of unreasonable infringement on the rights and interests of individuals). (limited to cases where the Business Operator Handling Personal Information and the third party concerned conduct academic research jointly).
7．Where said third party is an academic research institution, etc., and it is necessary for said third party to handle said personal data for academic research purposes (including cases where part of the purpose of handling said personal data is for academic research purposes, but excluding cases where there is a risk of unjustified infringement of the rights and interests of individuals).

5. About Google Analytics

    We use Google Analytics. Google Analytics is a service provided by Google, Inc. that collects information about your visits to this website, analyzes your activity history, and compiles statistical information. Google Analytics uses cookies to track your use of this site. However, we limit the sharing of your access history with Google Analytics to the extent possible and have set the setting to "do not share". In addition, neither the website administrator nor Google will be able to identify you from individual accesses in the course of this process.

■Opt-out
    If you still feel that this is a violation of your privacy, you can prevent it by using the "Google Analytics Opt-out Add-on"
(https://tools.google.com/dlpage/gaoptout/?hl=en).

Google Analytics Terms of Service： https://www.google.com/analytics/terms/us.html
Google Privacy Policy： https://www.google.com/intl/ja/policies/privacy/

6. About Microsoft Clarity

    The websites we manage use Microsoft Clarity, a service of Microsoft Corporation (‘Microsoft’), to collect information about how the websites are used. Microsoft Clarity stores information about the pages you visit, the time spent on the site, the path taken and what you click on. This information is not used to identify you. We receive analysis results from Microsoft to determine how you use the website. This information is collected and managed by Microsoft in accordance with its privacy statement and is used by Microsoft for purposes such as the delivery of advertisements, etc. For more information on Microsoft’s privacy statement, please visit Microsoft’s website.

Microsoft Clarity Terms of Use： https://clarity.microsoft.com/terms
Microsoft Privacy Policy： https://privacy.microsoft.com/ja-jp/privacystatement

7. Handling of Anonymized Information

※In handling the vehicle probe data provided by Hino Computer System Co., Ltd., we handle the following anonymously processed information.

■Anonymized Information
    We will continue to utilize and provide to third parties anonymized processed information that has been continuously created after taking measures required by law to ensure that specific individuals cannot be identified and that personal information cannot be restored.

（1）Handling of Anonymized Information

    Anonymized information handled by our company is as follows.　

    Items of Information on Individuals Contained in Anonymous Processed Information
    　・Information on the vehicle (VIN number, vehicle type, date of delivery and information on the vehicle registration except owner/user, maintenance history, etc.)
    　・Vehicle status information (operation information, location information, control information, failure information, etc.)
    Location information is subject to de-identification and confidentiality processing as described below to prevent individuals from being identified through the accumulation of location information.

    De-identification process
    　・Delete travel history and most concentrated areas in the origin and/or destination area.
    　・Mesh the location information of the target vehicle and the time of reception by region and time zone, etc.

    Hidden process
    　・Mask the VIN number so that individuals cannot be identified, etc.
    　・Delete a few values so that individuals cannot be identified, etc.

（2） Provision of Anonymized Processed Information to Third Parties

    We have provided and will continue to provide anonymized processed information to third parties.
    When providing anonymized processed information, we will clearly indicate to the third party to whom the information is provided that the information is anonymized processed information.

    Items of information about individuals included in anonymized processed information provided to third parties
    　・Same as  Items of information about individuals included in anonymized processed information  in (1) above.
    　・Upload to the server provided
    　・Provision by electromagnetic recording media

（3）Inquiries about anonymized processed information

    For inquiries regarding anonymized processed information, please contact the “Personal Information Consultation Desk.

    　Business Operators Handling Anonymized Processed Information
    　　LocationMind Inc.
    　　2-8-1 Kanda Tsukasa-machi, Chiyoda-ku, Tokyo 101-0048, Japan

    　Administration manager
    　　Admin Office　LocationMindInc.
    　　Shinsuke Asano

8. Request for Disclosure

    With respect to personal information that we have received or acquired, you may request notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, elimination, or suspension of provision to a third party (hereinafter referred to as “disclosure, etc.”).

    For requests for disclosure, etc., a fee of 1,000 yen (consumption tax included) will be charged. If it is obvious that the cost of conducting disclosure, including the processing of the data to be disclosed, will exceed the said amount, an additional fee equivalent to the actual cost of conducting disclosure will be charged, depending on the content of the request. We will separately contact you in advance with an estimate of the amount of the fee.

    Please transfer the commission fee to the account designated by us. Please note that bank transfer fees are the responsibility of the requester.

9. Contact

＜Our Personal Information Consultation Desk＞
    Procedures for responding to requests for notification of purpose of use, disclosure, correction, etc., and suspension of use of retained personal data, as well as the request for fees, should also be directed here.

    2-8-1 Kanda Tsukasa-machi, Chiyoda-ku, Tokyo 101-0048, Japan
    LocationMind Inc. Personal Information Consultation Desk
    Email: privacy@locationmind.com

＜A third-party organization that accepts complaints from our consumers＞
    【Only complaints regarding the handling of personal information will be accepted.】

    General Incorporated Association
    LBMA Japan Secretariat of Authorized Personal Information Protection Organizations
    405, Yamato Building, 1-6-16, Kanda-Izumi-cyou, Chiyoda-ku, Tokyo, 101-0024, Japan
    Email: info@lbmajapan.com

Revised on November 1, 2023
4F, PMO Kanda Tsukasa-machi Building,
2-8-1 Kanda Tsukasa-machi, Chiyoda-ku, Tokyo, Japan
LocationMind Inc.