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Personal Information Protection Policy

Network Value Components Ltd. (“NVC” or “we”) recognizes and respects the importance of privacy and is committed to carefully handling personal information and to protecting privacy as part of the fundamental human rights under Article 13 of the Constitution of Japan. We set forth below our Personal Information Protection Policy and we will comply with this Policy in all of our business activities.

  1. NVC will appoint Data Management Officer who will be responsible for compliance with respect to protection of personal information (including Individual Numbers and Specific Personal Information). We will ensure that each officer and employee and other involved personnel of NVC understands and complies with this Policy, and that personal information will be duly protected.
  2. NVC will collect personal information in a legitimate and appropriate manner, based on consent of the data subject individual to the Processing and to the purpose of use, unless otherwise permitted by law. If we collect personal information through an intermediary, we will notify the purpose of use and provide other relevant information on our website.
    When we collect Individual Numbers, we will do so in accordance with the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure, and we will use them only for the purposes specified under the said Act.
  3. NVC will use personal information only within the purposes of use to which a consent is given or which is notified as described in the preceding section, with limited access given only to duly authorized personnel. NVC will not use personal information beyond such purposes of use, and we will take necessary measures to prevent improper use.

    NVC will take all necessary security measures with respect to collection, use, transfer, storage, deletion and disposal of personal information to prevent leakage, destruction, loss or tampering. If any incident occurs, NVC will promptly take remedial actions.
  4. NVC will take all necessary security measures with respect to collection, use, transfer, storage, deletion and disposal of personal information to prevent leakage, destruction, loss or tampering. If any incident occurs, NVC will promptly take remedial actions.
  5. NVC will not share personal information it collects with any third party without consent of the individual, other than with subcontractors or as otherwise permitted by law.
    NVC will provide Specific Personal Information to a third party, including a subcontractor, only for the purpose of conducting certain procedures stipulated under the relevant laws.
  6. When NVC outsources handling of personal information to a subcontractor, we will execute a necessary contract with each such subcontractor and will ensure that proper security supervision is exercised.
  7. NVC will respond to claims, inquiries, and requests regarding disclosure, correction, deletion, suspension of use, or other handling of personal information in accordance with the procedures separately set out by NVC.
  8. NVC will abide by all applicable laws, administrative rules, guidelines and ordinances with respect to the Processing of personal information, and we will continue to review, improve and enhance our personal information management system.

Adopted:February 1, 2010
Last amended:April 2, 2018

Takenori Otsubo, President
Network Value Components Ltd.


Inquiry Form
If you have any inquiries, requests or comments with regard to handling of personal information, please contact us via this inquiry form or write to us at:

Network Value Components Ltd.
2-16-2 Minamikamata, Ota-ku, Tokyo 144-0035, Japan
Attn.: Personal Information Manager, Administration Dept.


GDPR Privacy Notice

This GDPR Privacy Notice (“Notice”) applies to our collection, use, sharing and other processing (“Process” or “Processing”) of personal data of individuals located in the European Economic Area (“Personal Data”).

  1. Categories of Data We Process
    NVC Processes the following categories of data:
    Personal Data regarding the following categories of natural persons:
    - Personnel of our business partners, such as existing or prospective customers, service providers, and vendors,
    - Investors,

    Website visitors, and
    Personal Data transferred to us by Controllers for our Processing services on behalf of Controllers.
  2. Purposes and Legal Basis of Processing
    Data Subject Purpose and Legal Basis
    Personnel of our business partners Marketing of our products and services: NVC has a legitimate interest in following up with its prospective customers who have conferred their contact information to NVC and in updating them on new developments and events.
    Execution and performance of contracts: NVC has a legitimate interest in Processing Personal Data as necessary to negotiate terms of contracts with its business partners and to perform its obligations thereunder.
    Investors Communicating IR information: NVC Processes Personal Data of existing or prospective investors based on its legitimate interest to reach out to them.
    Website Visitors NVC uses cookies on its website for the purpose of web audience measurement and improvement, and for marketing of our services based on your consent. Information collected by cookies includes IP address, geolocation, browser type and language, pages visited and for how long, and other metrics. For more details, please see our Cookie Notice.
    General Information security and compliance: it is NVC’s legitimate interest to keep records of your access to our systems and facilities in order to maintain and improve our information security, and to ensure our compliance with applicable laws.
  3. Categories of Recipients
    NVC will disclose Personal Data to the following categories of recipients:
    - Subcontractors, service providers, and product vendors of NVC,
    - Customers to which services of NVC’s other business partners, such as third party service providers, are provided,
    - External advisors such as attorneys, accountants and tax advisors (“Advisors”) of NVC,
    - Affiliate companies of NVC and their advisors and subcontractors with whom NVC needs to share Personal Data for the purpose of Processing such data, and
    - Other business partners with whom NVC needs to share Personal Data for the purpose of Processing such data.

    Recipients of Personal Data may be located in countries and areas outside of the European Economic Area (“Third Countries”), where applicable laws may not offer the same level of data protection as the laws of the respective natural persons’ home country. In such case, NVC will transfer Personal Data only as permitted under the laws then applicable to it, such as, for example, upon obtaining your explicit consent, or upon its adoption of the Standard Data Protection Clauses/Standard Contractual Clauses approved by the EU Commission.
  4. Retention Period
    NVC will retain your Personal Data for as long as necessary for the purposes set out above, or for as long as it is so required by law. NVC will endeavor to erase Personal Data as soon as possible when such retention is no longer necessary for the purpose for which they were collected or otherwise Processed, provided that such retention is not required by applicable laws or regulations or for NVC’s exercise or defense of legal claims.
  5. Rights of the Data Subject
    Natural persons may:
    - request access to, correction and/or erasure of their Personal Data,
    - object to the Processing of their Personal Data,
    - restrict the Processing of their Personal Data, and
    - request a copy of their Personal Data, or have a copy thereof sent to another controller, in a structured, commonly used and machine-readable format under the right of data portability.

    Natural persons may object to the Processing of their Personal Data pursuant to NVC’s legitimate interest. In such case, NVC will stop Processing their Personal Data unless NVC is able to demonstrate appropriate overriding legitimate grounds for such Processing. Also, natural persons shall have the right to object at any time to the Processing of their Personal Data for direct marketing purposes, in which case their Personal Data shall not be used for those purposes.

    Where the Processing of data is based on consent, natural persons shall have the right to withdraw their consent at any time, without affecting the lawfulness of the Processing of data based on consent, carried out before its withdrawal.

    Natural persons shall have the right to lodge a complaint with a supervisory authority pursuant to Art. 57 (1) (f) GDPR.
  6. Chief Privacy Officer and Contact: NVC’s Chief Privacy Officer is Kentaro Terada.
    If you have any enquiries or concerns regarding the Processing of your Personal Data or if you wish to exercise any of the above rights, please contact us via the inquiry form above or email us at privacy@nvc.co.jp, or write to us at:

    Network Value Components Ltd.
    2-16-2 Minamikamata, Ota-ku, Tokyo 144-0035,Japan
    Attn.: Personal Information Manager, Administration Dept.

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