gram-international Inc. (hereinafter referred to as “the Company”) fully recognizes the importance of personal information and considers the appropriate protection of such information to be an important social responsibility of the Company. In our business activities, all executives and employees will comply with laws, regulations, and other norms related to the protection of personal information, and we will work to continuously manage and improve our personal information protection system based on this policy.

１．Fundamental Policy

1. Acquisition and use of personal information
   We will acquire personal information by legal and fair means and use it within the scope of the purposes of use that are made clear at the time of collection or on our Internet homepage, etc. We will not use personal information for any other purposes than those stated in this Privacy Policy.
2. (i) To deliver information on products and services.
   (ii) To confirm and respond to questions and comments to the Company.
   (iii) To provide and improve products and services, and to develop new services.
   (iv) To publish statistically processed information as survey results.
3. Restrictions on Provision to Third Parties and Joint Use
   

   （1）We will not disclose or provide personal information under our management to any third party or share it with any third party without the consent of the individual, except in the following cases

   (i) When sharing personal information with third parties such as subcontractors and related parties with whom we have concluded confidentiality agreements regarding personal information, to the extent necessary to achieve the purpose of use
   (ii) When required by law or in order to protect the public's life, property, health, or other vital interests

   (2) In the above cases, or when the individual concerned has consented, the Company shall provide prior notice of the recipient, purpose of use, items of personal data, and means of provision.

   (3) Items of personal data to be provided and shared (e.g.) Name, address, telephone number, fax number, etc.

   (4) The provision of personal information to third parties, such as subcontractors and related parties, will be stopped at the request of the person who provided the information.

4. Respect for Rights Related to Personal Information
   We respect the rights of information subjects regarding their personal information, and will respond sincerely to inquiries, consultations, and complaints from them when we receive them.
5. We will comply with laws, regulations, and contractual requirements related to the company's business and information security.
6. Identify and manage information assets according to their value.
7. Identify and manage information asset vulnerabilities and risks that may threaten information assets.

２．handling

1. Consideration for provision and entrustment
   When we provide or entrust personal information to a third party, we will select the party to which we will provide or entrust the information with due consideration, and will do so only after concluding a confidentiality agreement with the party.
2. Implementation of Appropriate Security Measures
   In order to prevent unauthorized access, loss, destruction, falsification, leakage, etc. of personal information, we have established an appropriate management system, including the establishment of a committee on personal information, information system security measures, and employee training.
3. Actions to be taken in response to requests from the individual providing the information
   If a person requests disclosure of his/her own personal information or correction or deletion of incorrect personal information, we will promptly respond to such requests within reasonable limits.
4. Inquiries Regarding Personal Information
   Inquiries regarding complaints, corrections, suspension of provision to third parties, and deletion of personal information are accepted at the following contact point.

gram-international Inc.
〒541-0041 2-4-13 Kitahama, Chuo-ku, Osaka
E-mail: info@gram-international.co.jp