Act on Specified Commercial Transactions

Established: February 1, 2024

Last Amended: February 1, 2024

Mid Co., Ltd. (hereinafter referred to as "the Company") operates businesses in apparel, web production/operation, and temporary staffing services. We utilize personal information of customers and business partners to understand customer requests, propose plans, and support production and operations. We also use employee information and specific personal information for employee management. For the Company, the protection of personal information and specific personal information is a significant responsibility, and we recognize that thoroughly protecting personal information is a social responsibility of the company. Therefore, based on our privacy philosophy and self-determined code of conduct, we fully recognize our social mission and will comply with laws and regulations regarding the protection of personal rights and personal information.

Furthermore, we declare that we will establish a personal information protection management system to embody the policies stated below and, while constantly recognizing trends in the latest IT technology, changes in social demands, and fluctuations in the business environment, we will engage in its continuous improvement company-wide.

1. The Company will appropriately acquire, use, and provide personal information for the purpose of its business, and will not handle personal information beyond the scope necessary to achieve the specified purpose of use. We will also take measures to that end.

2. The Company will comply with laws and regulations concerning the handling of personal information, national guidelines, and other norms.

3. The Company will establish regulations and systems to prevent risks such as leakage, loss, or damage of personal information by taking reasonable security measures, and will continuously improve them. In the unlikely event of an incident, we will promptly take corrective actions.

4. The Company will respond promptly and sincerely to complaints and consultations regarding the handling of personal information.

5. The personal information protection management system will be reviewed and continuously improved in a timely and appropriate manner, taking into account changes in the environment surrounding the Company and actual conditions.

Masahiro Hirota, Representative Director, Mid Co., Ltd.

End

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[Contact for inquiries regarding the Personal Information Protection Policy and for complaints/consultations regarding personal information]

Assorti Shinjuku 5-chome Building 201, 5-11-25 Shinjuku, Shinjuku-ku, Tokyo 160-0022

Mid Co., Ltd. Personal Information Inquiry Desk

Email: team@mid-group.info

[Announcement of Purpose of Use of Personal Information]

• Mid Co., Ltd. (hereinafter referred to as "the Company") hereby announces that it will use personal information within the scope of the following purposes of use, in accordance with Article 21, Paragraph 1 of the Act on the Protection of Personal Information (Personal Information Protection Act) and JISQ15001:2017 Annex A.3.4.2.4.

Purposes of Use of Personal Information

(1) Purposes of use when acquiring personal information directly in writing (including through websites and emails, hereinafter referred to as "written documents") from the individual.

・Customer personal information is used for shipping products in the apparel business and web/graphic business, related after-sales service, and providing information on new products and services.
・Personal information of individuals making inquiries about our various businesses is used to respond to those inquiries.
・Personal information of our employees is used for human resources and labor management, business management, health management, security management, etc.
・Personal numbers of our employees and their dependents are used for purposes specified by law.
・Information of direct applicants to our company is used for recruitment activities.
・Information of applicants registered for our temporary staffing business is used for job placement.

(2) Purposes of use when acquiring personal information by methods other than direct written documents from the individual.
・In our apparel sales business, this is for product selection, shipping, and after-sales service.
・Information of job applicants from Hello Work and private job search sites is used for recruitment activities.

End

[Notice regarding Retained Personal Data and Records of Third-Party Provision]

• The Company will provide notification regarding the following matters concerning requests for disclosure of retained personal data (notification of purpose of use, disclosure, correction, addition or deletion of content, suspension of use, erasure, and suspension of provision to third parties) and requests for disclosure of records of third-party provision.

1. Name and Address of the Company, and Name of Representative
Name: Mid Co., Ltd.
Address: Assorti Shinjuku 5-chome Building 201, 5-11-25 Shinjuku, Shinjuku-ku, Tokyo 160-0022
Representative: Masahiro Hirota

2. Personal Information Protection Manager
Title: Representative Director and President
Contact: Email address team@mid-group.info

3. Purposes of Use of Retained Personal Data
・Customer personal information is used for shipping products in the apparel business and web/graphic business, related after-sales service, and providing information on new products and services.
・Personal information of individuals making inquiries about our various businesses is used to respond to those inquiries.
・Personal information of our employees is used for human resources and labor management, business management, health management, security management, etc.
・Personal numbers of our employees and their dependent spouses are used for purposes specified by law.
・Information of direct applicants to our company is used for recruitment activities.
・Information of applicants registered for our temporary staffing business is used for job placement.

4. Contact for Complaints Regarding Handling of Retained Personal Data
Inquiries regarding retained personal data are accepted at the following contact point.

Assorti Shinjuku 5-chome Building 201, 5-11-25 Shinjuku, Shinjuku-ku, Tokyo 160-0022
Mid Co., Ltd. Personal Information Inquiry Desk
Email: team@mid-group.info

5. Certified Personal Information Protection Organization Our Company Belongs To
Our company does not belong to any certified personal information protection organization.

6. Procedures for Disclosure, etc.
If you wish to request disclosure, etc., please contact the Personal Information Inquiry Desk above.
We will send you an explanation of the necessary procedures and required application forms.

7. Measures Taken for Secure Management of Retained Personal Data
The Company has established regulations concerning the handling of personal information and specific personal information, as well as regulations concerning safety measures, and has taken the following measures.

(1) Organizational Safety Management Measures
・We have established a policy regarding the handling of personal information and widely disseminated it within the company as a personal information protection policy, and also made it available to the general public on our website.

・We have established procedures for handling personal information at each stage of acquisition, use, storage, provision, deletion, and disposal, including handling methods, responsible persons/personnel, and their duties, compiled them into regulatory documents, and widely disseminated them within the company.

・We regularly conduct self-inspections of personal information handling status, and regularly conduct internal audits from an impartial standpoint by other departments or external parties.

・We restrict the employees who handle each piece of personal information.

(2) Human Safety Management Measures

・We conduct regular training for employees on points to note regarding the handling of personal information.

・We obtain pledges of confidentiality from employees.

(3) Physical Safety Management Measures, Technical Safety Measures

・We limit the areas where personal information is handled to prevent unauthorized viewing by employees other than those in charge or by those without proper authority.

・In areas where personal information is handled, we manage employee access and restrict equipment brought in.

・Personal information is stored in lockable cabinets or on servers with access restrictions.

・Firewalls and other measures are installed to prevent unauthorized external access to servers. We also take measures against computer viruses and other malicious software.

・The following measures are taken during the transfer of personal information:

‐When transferring media, we use methods that leave a delivery record or hand it over directly.

‐Electronic data communications are encrypted to prevent leakage.

(4) Understanding of External Environment

・We do not outsource the handling of personal information to overseas operators. For domestic operators, we ascertain the personal information protection system and confirm safe handling through agreements on personal information handling, checking the content of terms and conditions, and terms of use.

End

[Procedures for Disclosure, etc.]
For retained personal data, we will provide notification regarding the following matters concerning requests for notification of purpose of use, disclosure, correction, addition or deletion of content, suspension of use, erasure, and suspension of provision to third parties (Disclosure, etc.), as well as requests for disclosure of records of third-party provision.

The Company will respond to requests for disclosure, etc. of personal information according to the following procedures.

1. Acceptance of Requests for Disclosure, etc.
(1) Please contact us at the address below.
We will mail you the "prescribed form." Upon receipt, after agreeing to our "Handling of Personal Information," please attach the necessary documents and mail or bring them to the address below.

Assorti Shinjuku 5-chome Building 201, 5-11-25 Shinjuku, Shinjuku-ku, Tokyo 160-0022 Mid Co., Ltd.
Personal Information Inquiry Desk
Email: team@mid-group.info

(2) Method for verifying that the person making the request for disclosure, etc. is the individual themselves or their agent.
I. Verification that the person making the request for disclosure, etc. is the individual themselves will be carried out by the Complaint and Consultation Desk Manager using the identification documents specified below.

II. Verification that the person making the request for disclosure, etc. is an agent will be carried out by the Complaint and Consultation Desk Manager, in addition to the identification documents for the individual making the request for disclosure, etc., and separately for voluntary agents, legal agents (minor guardians, adult guardians, parental authority holders), using documents proving the relationship between the disclosed subject and the agent and identification documents for the agent themselves, as specified below.

III. For identification documents of the individual and the agent themselves, a copy of a photo ID issued by a public institution, as exemplified below, is required.

a. Driver's License
b. My Number Card (front side)
c. Other photo-bearing public identification documents
I. Documents proving the relationship between the disclosed subject and the agent are as follows:
a. In the case of a voluntary agent: A power of attorney stating "I delegate the authority to receive the results of disclosure, etc."
b. In the case of a minor guardian: A family register transcript or certificate of registered matters (both issued within 6 months)
c. In the case of an adult guardian: A certificate of registered matters (issued within 6 months)
d. In the case of a parental authority holder: A family register transcript or residence certificate (both issued within 6 months)
2. Fees for "Request for Disclosure, etc." and Collection Method
• Only for requests for notification of purpose of use or disclosure, and disclosure of third-party provision records, a fee of the following amount (including postage to be charged separately) will be charged per request. Please enclose postal stamps for the amount below when mailing the request documents.
・Fee amount: 1,000 yen
3. Notification of Review Results
The results of our internal review will be communicated without delay using the method requested by the applicant. In the unlikely event that your request cannot be met, we will inform you of the reason without delay using one of the following methods:
・Mail or hand delivery of a written document
• The destination for the document will be selected using one of the following appropriate methods:
・Mailing the response document to the registered address of the individual or legal agent
・Emailing the response document to the registered email address of the individual or legal agent