PERSONAL INFORMATION PROTECTION POLICY

1. Basic Policy

Kobelco Construction Machinery Co., Ltd. and its group companies (hereinafter collectively “Kobelco”) recognizes that all personal information provided by you, our customers and clients through their business with Kobelco must be handled and protected with the utmost care. Therefore, Kobelco will follow the basic policy stated below to fulfill its responsibility.

1. In handling any personal information, Kobelco pledges to fully comply with the Private Information Protection Law (hereinafter the “Law”), other relevant laws and regulations, and pursuant to practices in this respect that are generally accepted as fair and reasonable. Further, Kobelco will continuously endeavors to improve handlng such personal information.
2. Kobelco will continuously update and revise rules and management systems for handling and protection of personal information and ensure compliance by its employees with such rules and systems. Further, Kobelco will ensure to appropriately supervise their trustees if any.
3. Kobelco will use personal information only to the extent and for the purposes specified (hereinafter the “Purpose”), which will be announced or noticed to the persons to whom the information pertains.
4. Kobelco will take necessary measures to properly manage and protect personal information to prevent it from being leaked, lost, and falsified.
5. Kobelco through its specific office will faithfully make all efforts to promptly receive, correct, revise, delete or cease personal information in possession upon verification that the personal making the request is indeed the data subject.

2. Purposes of Use of Personal information

Kobelco may lawfully use personal information only as needed for its business performance according to its business purposes to the extent that it may require:

1. To inform and provide its products and services;
2. To develop its products and services;
3. To procure raw materials, goods and services; and
4. To respond to enquiries by the individual.

3. Use of Personal Information Within Kobelco Group Companies

Kobelco may share personal information, including personal name, address, telephone number, mail address, purchasing history of products, place of employment, job title, etc., with its group companies as listed herein for the Purpose. Kobelco will be solely responsible for such use. For any inquiries, complaints please refer to the contact address stated hereunder.

4. Disclosure to Third Party

Kobelco will not disclose personal information to any third party except for use of personal information within Kobelco group companies or to its trustees stated above and the following cases:

1. When person’s approval is granted beforehand;
2. When the disclosure is in a statistical form which does not identify person;
3. When the disclosure is required by applicable laws and ordinances. Also, we may disclose your personal information to respond to subpoenas, and court orders;
4. When the disclosure is necessary to protect human life, human body and personal property, while it is difficult to obtain person’s agreement to disclose his or her personal information; or
5. When the disclosure of personal information is necessary to support a public operation of the national government or the municipality that person’s refusal to allow the disclosure of personal information would limit the accomplishment of such operation.

5. Management on Website

Kobelco will protect personal information from being divulged or falsified, and take all the measures promptly in case of emergency.

1. Security
   Kobelco uses the SSL (Secure Sockets Layer) on its website as a measure to protect personal information. The SSL is a technology to encipher the information transmitted on the Internet and prevent the leakage of such information to the third party. The website pages handling personal information is supported by SSL. Please make certain that “http://” of the URL has been changed to “https://”.
2. Use of Cookies
   Cookies may be used to ensure safety and provide appropriate information to you. A Cookie is a piece of information transmitted from Kobelco’s web server to the web browser and may be stored on your computer hard disk or other memory device. A Cookie itself does not contain any information to help Kobelco identify an individual person. You can decide whether to accept or block Cookies by setting your web browser. However, if you choose not to accept Cookies, you may not be able to use the services provided on the website managed by Kobelco.
3. Browsing Records
   If you visit the website operated by Kobelco, information about your access to the website is stored on the web server. This information may not be used for any purpose other than taking statistics including the frequency of your access.

6. Disclosure

You may request to obtain confirmation concerning whether Kobelco is holding or processing personal data relating to you, and confirmation concerning the use of the personal information in possession of Kobelco. If such a request is made, Kobelco requires that your proof of identity should be provided. When Kobelco finds it necessary to disclose, Kobelco will disclose your personal information in possession of Kobelco to you to a reasonable extent and in a reasonable period of time.

7. Correction, Deletion, etc

You may request to correct, add or delete your personal information. If such a request is made, Kobelco requires that your proof of identity should be provided. When Kobelco finds it necessary to correct, add or delete, Kobelco will correct, add or delete your personal information in possession of Kobelco to a reasonable extent and in a reasonable period of time.

8. Suspension of Use and Elimination

You may request to cease the use or eliminate personal information. If such a request is made, Kobelco requires that your proof of identity should be provided. When Kobelco finds it necessary to cease the use or eliminate in accordance with the Section 27 of the Law, Kobelco will cease the use or eliminate your personal information in possession of Kobelco to a reasonable extent and in a reasonable period of time. Please note that if part or all of your personal information becomes unavailable to us, we may not be able to provide satisfying service. Your kind understanding and cooperation will be appreciated. (There may be cases that we are not able to answer your request to suspend our use of or to delete the personal information, if the personal information were managed in accordance with the related laws and regulations.)

9. Contacts

Inquiries in relation to any of your requirements mentioned in above Sections 6, 7 and 8 concerning your personal information handled by Kobelco as well as your inquiries related to other personal information is to be sent to the contact address stated below.

Contact for inquiries

Your inquires will be accepted by the contact for inquiries where you have been notified Kobelco at the time you provided your personal information, or by the person in charge if you have an account with Kobelco. You will be informed of details of the method of confirmation of your identity and the fee at the time you contact them. Please contact the following reference desk if you are uncertain about where to contact.

Reference for contact information:

Kobelco Construction Machinery Co., Ltd.

Administrative Department

Phone: (03) 5789-2111

Fax: (03) 5789-2131

E-mail: compliance@kobelconet.com

April 1, 2016

Kazuhide Naraki

Representative Director & President

Kobelco Construction Machinery Co., Ltd.

[Our Group Companies]

[1] Domestic companies

KOBELCO Construction Machinery Japan Co., Ltd.

KOBELCO Construction Machinery Engineering, Co., Ltd.

KOBELCO Construction Machinery International Trading, Co., Ltd.

KOBELCO Cranes Trading Co,. Ltd.

KOBELCO Training Services Co,. Ltd.

[2] Overseas companies

Kobelco Construction Machinery (China) Co., Ltd. (China)

Chengdu Kobelco Construction Machinery Financial Leasing Ltd. (China)

Hangzhou Kobelco Construction Machinery Co., Ltd. (China)

Kobelco Construction Machinery Southeast Asia Co., Ltd. (Thailand)

Kobelco International (S) Co., Pte. Ltd. (Singapore)

Ricon Private Ltd. (Singapore)

PT. Daya Kobelco Construction Machinery Indonesia (Indonesia)

Kobelco Construction Machinery Malaysia Sdn. Bhd. (Malaysia)

Kobelco Construction Equipment India Pvt. Ltd. (India)

Kobelco Construction Machinery Australia Pty. Ltd. (Australia)

Kobelco Construction Machinery Middle East & Africa Fzco. (U.A.E)

Kobelco Construction Machinery U.S.A. Inc. (U.S.A)

Kobelco Construction Machinery Europe B.V. (Netherlands)