Privacy Policy

This Privacy Policy has been established by Nabtesco Corporation (the “Company”) and its group companies (collectively, the “Nabtesco Group”) based on the recognition that the Nabtesco Group has a social responsibility to properly handle personal information. All officers and employees of the Nabtesco Group are committed to ensuring the protection of personal information by complying with this Privacy Policy.

1. Basic stance

In the course of handling the personal information of customers, business partners, shareholders, job applicants and all other relevant individuals (collectively, “Customers”), the Nabtesco Group will comply with applicable laws and regulations and other codes concerning the proper handling of personal information.

2. Purposes of using personal information

The Nabtesco Group will use the personal information received from Customers solely within the scope of permissible use described below.

– Introduction of products or services
– Response to inquiries and questions about products or services
– Business communication, actions and management necessary for the conclusion and performance of agreements
– Operations related to the delivery of products or the provision of services
– Operations for the settlement of payment for products or services
– Confirmation of the status of use of products or services and collection of feedback from users of products or services and provision of support
– Invitation to events, exhibitions, etc. and actions related to the management thereof
– Registration for e-mail distribution services or other services available on the Nabtesco Group’s websites and distribution, confirmation and other actions in relation to those services
– Actions in response to the use of the Nabtesco Group’s facilities by Customers
– Planning of and actions for human exchange activities, including acceptance of seconded personnel
– Shareholder management and notification to shareholders as prescribed in the Companies Act of Japan
– Provision of recruitment information to job applicants; screening and selection of prospective employees
– Creation of information about an individual which is obtained by processing personal information so that the individual cannot be identified and by which the relevant personal information cannot be restored (anonymously processed information)
– Creation of information about an individual which is obtained by processing personal information so that the specific individual cannot be identified unless collated with other information (“pseudonymously processed information”)
– Investigation and reporting related to compliance
– Other purposes of use as announced on websites, etc. that introduce products or services of the Nabtesco Group

3. Purposes of using pseudonymously processed information

The Nabtesco Group may use pseudonymously processed information for the following purposes.

– Development of the Nabtesco Group’s products or services, improvement of their quality, research for new services, and various kinds of marketing survey and analysis aimed at the foregoing activities
– Preparation of statistical data for business analysis and utilization of analytical findings
– Provision of information that the Nabtesco Group may find beneficial for Customers

4. Shared use of personal data

The Nabtesco Group may share personal data received from Customers (excluding specified personal information) for use in accordance with the following conditions.

(1) Shared use within the Nabtesco Group
Items of personal data that may be shared
Customers’ attribute information, including name, address, telephone number, age, gender and e-mail address, information provided by Customers and falling under personal data, and the details of inquiries, etc.
Scope of those who may share personal data
Nabtesco Group companies within and outside Japan（Group companies in Japan,Group companies outside Japan）
Purposes of shared use
The purposes described in Section 2 (Purposes of using personal information)
Administrator for shared use
Nabtesco Corporation

(2) Shared use of personal information at the Nabtesco Group’s construction sites
Items of personal data that may be shared
– Customers’ attribute information, including name, address, telephone number, date of birth, age, gender and e-mail address and information provided by Customers and falling under personal data
– Job type
– Whether or not enrolled in medical insurance under the Health Insurance Act/National Health Insurance Act of Japan, pension under the National Pension Act/Employees’ Pension Insurance Act of Japan and employment insurance under the Employment Insurance Act of Japan
– Whether or not the person is qualified for mutual aid under Article 2, Paragraph 7, of the Small and Medium-sized Enterprise Retirement Allowance Cooperative Act
– Details of education on health and safety, if the person has received such education
– Qualifications related to knowledge and technique or skills for construction work
– Other items that need to be entered in the work ledger, etc. pursuant to the Construction Business Act of Japan, etc.
Scope of those who may share personal data
– Companies that placed an order for work, prime contractors that placed an order for work to Nabtesco Group companies, Nabtesco Group companies, and distributors, agents and partner companies that sell, construct, maintain or otherwise handle the Nabtesco Group’s products
Purposes of shared use
– Creation and management of a work ledger, list of workers, etc. as required by the Construction Business Act of Japan and other laws and regulations
– Communication and information sharing for execution of construction work
– On-site safety management
Administrator for shared use
– Nabtesco Group companies that placed/received an order for work (excluding the types of work to which the Construction Business Act is not applied.)

5. Provision of personal data for third parties

The Nabtesco Group will never disclose or provide any of Customers’ personal data without their consent, to or for any third parties other than the parties included by the Nabtesco Group in the scope of those who may share personal data, the Nabtesco Group’s outsourcing partners or those taking over a business from the Nabtesco Group, except when such disclosure is required by law or is justifiable on any other reasonable grounds.

*Specified personal information of Customers will not be provided to any third party, regardless of whether their consent has been obtained or not, except when such information is provided to an outsourcing partner of the Nabtesco Group or under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures or any other applicable law or regulation.

6. Management of outsourcing partners

The Nabtesco Group will conclude a non-disclosure agreement with any outsourcing partners to which the Nabtesco Group will disclose personal data of Customers pursuant to Section 5 above and direct and supervise the outsourcing partners so that they will properly handle and protect the personal data.

7. Overseas transfer of personal data

For overseas transfer of personal data of Customers, the Nabtesco Group will implement necessary measures in line with the relevant laws and regulations.

8. Disclosure, correction, etc. or cessation of use, etc. of retained personal data

If Customers desire disclosure, correction, etc. (meaning correction, addition or deletion) or cessation of use, etc. (meaning cessation of use or deletion and cessation of provision for third parties) with regard to their own personal data retained by the Nabtesco Group, they will be required to contact the Human Resources Department of Nabtesco Corporation. After verifying the identity of the person, the Nabtesco Group will take the necessary action as soon as reasonably possible.

However, the foregoing does not apply when acting as requested by the person would be detrimental to any right of a third party, or is deemed to significantly disrupt the proper business operations of the Nabtesco Group, or would be in violation of a law or regulation.

9. Matters related to data security management measures

When handling personal data, the Nabtesco Group will appropriately manage such data, thereby preventing illegal access to the data from outside the Nabtesco Group as well as data loss, destruction, falsification, leakage and other incidents, and will implement data security management measures at an appropriate and reasonable level. In the event of an incident, the Nabtesco Group will promptly take corrective measures. If you have any questions about the Nabtesco Group’s data security management measures, please make an inquiry to the contact point described in Section 11 below.

10. Names, addresses and representatives of Nabtesco Group companies

If you are browsing the website of Nabtesco Corporation https://www.nabtesco.com/en/about/company/overview/
or of a Nabtesco Group company in Japan,group companies in Japan please refer to the website of that company for the name, address and representative of the business operator handling personal information.

11. Inquiries

Any inquiries or questions regarding personal information can be directed to the contact point for which Customers provided their personal information. If you are unaware of such contact point, please click the following link to contact the Human Resources Department of Nabtesco Corporation.

Contact for inquiries

Please note that this Privacy Policy may be revised without notice from time to time.

Revised on January 1, 2023

Privacy Policy for Personal Information of Nabtesco Group Members

Nabtesco Corporation (the “Company”) and its group companies (collectively, the “Nabtesco Group”) undertake to properly handle personal information of employees or other personnel serving in the Nabtesco Group (“NTS Group Members*”) pursuant to the conditions described below, in compliance with the Act on the Protection of Personal Information of Japan, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures of Japan (the “Number Use Act”) and other codes.

*NTS Group Members refer to officers, employees and any other persons who are currently engaged in business operations of the Nabtesco Group, those who will be engaged in the same (prospective employees) and those who were engaged in the same (retirees).

1. Purposes of using personal information of NTS Group Members

The Nabtesco Group will acquire, retain and use the personal information of NTS Group Members for the following purposes.

– Communications in the course of business operations (including emergency communications); operations for the management of equipment and facilities
– Reassignment, personnel evaluation, commendation, disciplinary action and other operations for human resources management
– Clerical work for workforce management
– Operations for wages, bonuses, retirement benefits, corporate pension plans and the like
– Operations for expense reimbursements, allowances and various certifications
– Operations for personnel education and training
– Operations for employee welfare and benefits
– Operations for safety and health, health management and the like
– Operations for employment insurance and social insurance
– Operations for tax affairs, social security and other statutory or regulatory affairs
– Operations related to immigration control and status of residence
– Operations for the employee shareholding plan
– Operations for the creation of statutory documents, such as invitation letters, and for the management of stock option exercise
– Operations for the management of inventors as part of the management of patent applications, etc.; for the payment of rewards for intellectual property; and for the registration and management of user IDs for intellectual property-related databases
– Operations for IR, PR, advertising, recruitment and the inclusion of articles in the in-house magazine
– Investigation and reporting related to compliance
– Operations related or incidental to any of the operations listed above

2. Purposes of using specified personal information of NTS Group Members and their dependent relatives

The Nabtesco Group will acquire, retain and use specified personal information of NTS Group Members and their dependent relatives for the following purposes, solely to the extent necessary for the intended purpose in each instance.

– Clerical work for insurance claims based on the Industrial Accident Compensation Insurance Act of Japan
– Clerical work for regulatory notifications in relation to health insurance or employees’ pension insurance
– Documentation for the property accumulation savings plan for employees
– Documentation for the employee shareholding plan
– Documentation for the public pension plan and the like
– Clerical work for regulatory notifications for tertiary insured persons under Japan’s national pension plan
– Preparation of payment reports for remunerations, fees and the like
– Preparation of payment reports for shares
– Preparation of payment reports for real estate usage fees, consideration for acquisition of real estate and the like
– Other clerical work related to any of the matters listed above

3. Shared use of personal data

The Nabtesco Group may share personal data (excluding specified personal information) of NTS Group Members for use in accordance with the following conditions.

(1) Shared use between Nabtesco Group companies

Items of personal data that may be shared

The following personal data of NTS Group Members acquired and retained by the Nabtesco Group, but only including such data required to achieve the purposes of shared use.

(i) Name, employee code or other identification number assigned on an individual basis, residential address, division or department, job position, e-mail address and other basic information about each NTS Group Member
(ii) Information about an NTS Group Member’s family members including their names and dependency status
(iii) Job qualifications, reassignment, job performance evaluation, commendation, disciplinary action and other information related to human resources management of each NTS Group Member
(iv) Information about wages, bonuses, retirement benefits, corporate pension plans and the like
(v) Information about employee benefit programs such as the status of use of benefit services
(vi) Results of medical examination and other health information
(vii) Other information that the Nabtesco Group may acquire and retain for the management of personnel and management operations

Scope of those who may share personal data

Nabtesco Group companies within and outside Japan
（Group companies in Japan, Group companies outside Japan）

Purposes of shared use

The purposes described in Section 1 (Purposes of using personal information of NTS Group Members)

Administrator for shared use

Nabtesco Corporation

(2) Shared use of personal information at the Nabtesco Group’s construction sites

Items of personal data that may be shared

(i) Name, employee code or other identification number assigned on an individual basis, division or department, job position, e-mail address, date of birth and age, and other basic information about each NTS Group Member
(ii) Job type
(iii) Whether or not enrolled in medical insurance under the Health Insurance Act/National Health Insurance Act of Japan, pension under the National Pension Act/Employees’ Pension Insurance Act of Japan and employment insurance under the Employment Insurance Act of Japan
(iv) Whether the person is qualified for mutual aid under Article 2, Paragraph 7, of the Small and Medium-sized Enterprise Retirement Allowance Cooperative Act
(v) Details of education on health and safety, if the person has received such education
(vi) Qualifications related to knowledge and technique or skills for construction work
(vii) Other items that need to be entered in the work ledger, etc. pursuant to the Construction Business Act of Japan, etc.
(viii) Contact information, including the cell phone number of the person or his/her family member

Scope of those who may share personal data

Companies that placed an order for work, prime contractors that placed an order for work to Nabtesco Group companies, Nabtesco Group companies, and distributors, agents and partner companies that sell, construct, maintain or otherwise handle the Nabtesco Group’s products

Purposes of shared use

Creation and management of a work ledger, list of workers, etc. as required by the Construction Business Act of Japan and other laws and regulations Communication and information sharing for execution of construction work
On-site safety management

Administrator for shared use

Nabtesco Group companies that placed/received an order for work (excluding the types of work to which the Construction Business Act is not applied).

4. Provision of personal data for third parties

The Nabtesco Group will never disclose or provide any of NTS Group Members’ personal data without their consent, to or for any third parties other than the parties included by the Nabtesco Group in the scope of those who may share personal data, the Nabtesco Group’s outsourcing partners or those taking over a business from the Nabtesco Group, except when such disclosure is required by law or is justifiable on any other reasonable grounds.
*Specified personal information of NTS Group Members will not be provided to any third party, regardless of whether their consent has been obtained or not, except when such information is provided to an outsourcing partner of the Nabtesco Group within the scope of purposes of permissible use specified in this Policy or is provided under Article 19 of the Number Use Act or any other applicable law or regulation.

5. Miscellaneous provisions

Matters not specified in this Privacy Policy are governed by the Privacy Policy of the Nabtesco Group.

6. Inquiries

Any inquiries or questions regarding personal information of NTS Group Members can be directed to the following.
Human Resources Department, Nabtesco Corporation
General administration & human resources department of each Nabtesco Group company
Please note that this Privacy Policy may be revised without notice from time to time.

Revised on January 1, 2023