GPSS Group (hereinafter referred to as “our Group”) will formulate and publish a privacy policy regarding the appropriate protection and use of personal information in accordance with the Act on the Protection of Personal Information, as follows.

The Privacy Policy will be reviewed as necessary to ensure the proper handling of customers’ personal information, and efforts will be made to make continuous improvements.

1．Policy on Personal Information

Each of our Group companies (GPSS Holdings Inc., GPSS Engineering Inc., Sustainable Society Investment Management Inc., KTM Infrastructure Corporation., Geothermal Development & Investment Inc., Japan Wind-power Service Inc., Japan Hydro-power Development Inc., Japan Bio Methane Inc., Mirai Society Inc., and CIS Japan Business Consulting Inc., GPSS Energy Product Inc., Geoscience Enterprise Inc. and GPSS Innovation Capital Inc.) shall, with regard to the proper handling of personal information, comply with the laws and regulations in Japan concerning the protection of personal information and other regulations, and shall endeavor to protect personal information by establishing our own procedures that comply with these laws and regulations.

2．Purpose of Use

Our Group will handle personal information within the scope necessary to achieve the purpose of use in relation to the following operations.

(1) Business description

① Formulation and management of the Group’s business strategies and the operations incidental thereto
② To fulfill our contractual responsibilities with customers and business partners
③ For the development of better products and services
④ Response to inquiries and requests from customers, suppliers, etc.
⑤ To provide useful information to customers, business partners, etc.
⑥ Execution of duties related to management of officers (including retirees) and employees (including retirees)
⑦ Implementation of other businesses incidental to ① through ⑥ above

(2) Purpose of use

① Intended use of personal information

Ⅰ. Personal information about customers

(Ⅰ) In order to respond to various inquiries and requests for documents from customers
(Ⅱ) To reflect the opinions and requests of customers in our service improvements, etc.
(Ⅲ) In order to conduct administrative work to comply with laws and regulations
(Ⅳ) In order to carry out other businesses incidental to the above

Ⅱ. Personal information concerning suppliers

(Ⅰ) In order to communicate business matters to suppliers
(Ⅱ) For fulfillment of various contracts with suppliers
(Ⅲ) For contacting suppliers for business discussions and meetings
(Ⅳ) For the management of information related to suppliers
(Ⅴ) In order to carry out other businesses incidental to the above

Ⅲ. Personal information concerning officers (including retirees) and employees (including retirees)

(Ⅰ) For the provision and employment of recruitment-related information
(Ⅱ) For the implementation of various personnel systems (including personnel evaluation), employment management (including loan and transfer), human resource development, and employment management
(Ⅲ) For work related to paying salaries
(Ⅳ) For services related to welfare, etc.
(Ⅴ)For the implementation of education and training
(Ⅵ) Duties related to service discipline management (including rewards and punishments)
(Ⅶ) For the purpose of investigating and examining improvements in working conditions
(Ⅷ) For various procedures at the time of joining and leaving the Company, as well as for procedures and communications required by laws and regulations
(Ⅸ) For other business-related procedures and communications

Ⅳ. Personal Information on Employment Applicants

(Ⅰ) To provide information to recruitment applicants (including internships and part-time applicants) and to perform duties related to recruitment activities
(Ⅱ) For managing job offers
(Ⅲ) For the dissemination of employment and other information

Ⅴ. Personal information concerning retirees and retirees

(Ⅰ) For retirement and post-retirement procedures

Ⅵ. Personal information of persons who have made inquiries to us

(Ⅰ) To respond to inquiries

② Purpose for using specific personal information

Specific personal information related to executives (including retirees), employees (including retirees) and their families shall be handled within the limits necessary to achieve the following purposes of use.

Ⅰ. For clerical work to prepare withholding records, etc. Ⅱ. For clerical work to prepare payment records, etc. Ⅲ. For notification work, etc. concerning individual resident tax Ⅳ. For notification of health insurance and welfare pension, etc. Ⅴ. For the notification business, etc. concerning employment insurance Ⅵ. For notification of in-house benefits for group insurance and corporate pension, etc. Ⅶ. For other affairs related to the above-mentioned affairs

③ Change of purpose of use of personal information

If our Group changes the purpose of use of personal information, it will not do so beyond the scope that is reasonably considered to be relevant to the purpose of use before the change, and will notify the individual or publicly announce the changed purpose of use. 

3．Joint/shared use of personal information

(1) Purpose of joint use

Our Group may share personal information (excluding specific personal information) as follows to the extent necessary to achieve the purpose of use of personal information.

① Personal Information Concerning Customers and Business Partners

② Personal Information Concerning Officers and Employees

(2) Inquiries about shared use

Please contact our contact point for inquiries about personal information of the Group. Our Group will not share Specific Personal Information with third parties unless the sharing of Specific Personal Information is permitted by law.

4．Ensuring the accuracy of personal information

We will endeavor to maintain personal information accurate and up to date within the scope necessary to achieve the purpose of use.

5．Safety Management Measures

We will implement reasonable technical measures to prevent unauthorized access to personal information, loss, alteration, and leakage of personal information.

6．Provision of Personal Information to a Third Party

Our Group will not provide personal information to a third party without obtaining the consent of the person except in the following cases.
If the information is provided to a third party, the contractual obligation shall be imposed unless there is a special reason to do so, in order to prevent the leakage or resupply of the information from the third party.

(1) Cases based on laws and regulations
(2) Cases in which the provision of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person
(3) Cases in which the provision of personal information is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children and in which it is difficult to obtain the consent of the person
(4) Cases in which it is necessary to cooperate with a state organ, a local government or a person commissioned thereby in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to hinder the execution of said affairs
(5) Cases where personal information is provided upon business succession due to merger or other reasons
(6) In the case where the provision of information is to be made to a third party in advance by notifying the person of the information that (1) the provision to a third party is the purpose of use, (2) the items of personal information to be provided to a third party, (3) the means or method of provision to a third party, or (4) the provision to a third party of personal information whose identity is to be identified is to be discontinued at the request of the person, or the provision to a third party is to be discontinued at the request of the person.

7．Entrustment of Personal Information

Our Group may outsource all or part of the operations to third parties.
In the event of commissioning, our Group will select a party that meets the sufficient standards for the protection of personal information, conclude a contact with the outsourced party that includes confidentiality, or require the party to agree to terms and conditions stipulated by our Group, and conduct necessary and appropriate supervision to ensure that the outsourced party manages personal information in a secure manner.

8．Procedures for Disclosure Requests, etc.

We will respond within a reasonable period to requests from customers for confirmation, correction, or deletion of retained personal data.
For inquiries, please contact the person in charge of our Group.

When we receive a request for disclosure, from a customer, we will respond to the customer’s request by providing electromagnetic records, by delivering documents, or by any other method we determine. However, if we deem it difficult to disclose by the method requested by the customer, we will inform the customer to that effect and the reason and may disclose by delivery of documents. 

Upon receiving a request for suspension, from a customer, we will investigate without delay to the extent necessary, and if we find reasonable grounds for the customer’s request under applicable laws and regulations, we will take measures such as suspension, etc. to the extent necessary. 

In addition, our Group may charge a fee as prescribed by our Group for the above procedures for disclosure, etc. or suspension, etc. For other details of the procedures for disclosure, etc. or suspension, etc., please contact the person in charge of our Group. 

9．Contact for inquiries regarding personal information

We accept inquiries and inquiries regarding personal information held by our Group.

[Contact Point for Inquiries on Personal Information of GPSS Group]   
Email: privacy@gpssgroup.jp

10．About privacy policy notation language

The current privacy policy is written in Japanese and English. In the event of any problems with the interpretation of the contents, the Japanese version shall take priority.

Effective November 1, 2019

Revised April 1, 2022