PRIVACY POLICY Handling Personal Information

1. Purpose of the present policy-Collection of certain Personal Data

We comply with all applicable regulations relating to personal data protection (“Applicable regulations”), and in particular all provisions defined in The Act on the Protection of Personal Information Act No. 57 of 2003 (the “APPI”) under Japanese law, as well as the provisions of the Vietnamese law n°13 of 2023, called “Nghị định 13/2023/NĐ-CP”. Any information relating to an identified or identifiable natural person constitutes “Personal Data” within the meaning of the APPI. An identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more elements specific to his or her physical, physiological, genetic, psychological, economic, cultural or social identity. We hereby wish to inform you how we process and protect your Personal Data collected and controlled by Yashima NBV Co., Ltd. on the Yashima NBV Co., Ltd. Platform, including Personal Data collected on the Maintenance Management Application and the Hub Application. It is specified that the terms “you”, “your” or “yours” as used in these terms refer to any natural person who is a Client of Yashima NBV Co., Ltd.. In the context of the execution of the contracts between Yashima NBV Co., Ltd. and its Clients, and in particular under the terms and conditions of the General Terms and Conditions of Use of the Maintenance Management Application (hereinafter the “General Terms of Use”), and of all other policies, conditions and agreements applicable according to the Services provided to the Client, the Client may also be responsible for the collection and processing of certain Personal Data of its Users. It is then incumbent on the Client to comply with the applicable legal and regulatory provisions, and in particular the regulations applicable to the protection of personal data, and to obtain any prior authorizations. The Client in this case must guarantee that it has all the rights necessary to collect and process the Personal Data of its Users and it is the Client's responsibility to inform and guarantee all the rights of its Users in application of the Applicable Regulations. For all purposes, it is recalled that the data controller is, in accordance with the applicable legislation, the entity that defines and limits the data to be collected and the purposes of processing. Yashima NBV Co., Ltd. may, depending on the case, act as a busprocessor of the Client, or as a separate data controller. This policy defines the nature, means and purposes of the processing of Personal Data of Clients and Users by Yashima NBV Co., Ltd. in its capacity as data controller. It does not apply to data that Yashima NBV Co., Ltd. processes on behalf of its Clients (the “Client Content” as defined in the General Terms of Use) in its capacity as a subprocessor.

2. General rules applicable to the collection and processing of personal data

It is reminded that in accordance with the Applicable Regulations, the Personal Data are:

a/ Treated in a lawful, fair and transparent manner with respect to the persons concerned;

b/ Collected for specified, explicit and legitimate purposes and not to be further processed in a manner incompatible with those purposes;

c/ Adequate, relevant and limited to what is necessary for the purposes for which they are processed;

d/ Accurate and, if necessary, kept up to date;

e/ Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which they are processed;

f/ Processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage by accident, by means of appropriate technical and organizational measures.

3. Identity and contact details of the data controller

The data controller within the scope of this policy is the company Yashima NBV Co., Ltd., a Company Limited operating under the laws of Vietnam, with a capital investment of 400,000 USD, having its registered office located 170 Street 5, Binh Tri Dong B Ward, Binh Tan District, Ho Chi Minh City, registered with the Agency for Business Registration under registration number 0314600752, and represented by its CEO, Mr. Tarui Kazuyuki. Personal Data collected from Clients through the forms available on the Yashima NBV Co., Ltd. Platform and intended for Yashima NBV Co., Ltd. are collected and processed, as the case may be, on the basis of a legal obligation, a legitimate interest of Yashima NBV Co., Ltd. and/or the consent of the person concerned.

4. What is the purpose of the processing of the Personal Data collected?

We use the information at our disposal (subject to the choices you make) in the manner defined below, in order to provide and to ensure the functioning of the Yashima NBV Co., Ltd. Services and related services.

We undertake to obtain the express consent of the persons concerned and to allow them to object to the use of their Personal Data for any other purpose, as soon as this is necessary. In all cases, Clients are informed of the purposes for which their Personal Data is collected via the online data collection form and via their actions on the Yashima NBV Co., Ltd. Platform. In any case, it is reminded that the Personal Data collected is necessary for the proper execution of the Services (as described below) and to enable us to comply with our legal obligations. Without it, we are not able to provide all the services offered on the Platform. The purpose of collecting, storing and processing this information and Personal Data is to:

4.1. Offer, personalize, and improve our Services.

We use the information at our disposal to ensure the provision and maintenance of our Services, in particular establishing of your rights depending on your profile, to personalize functionalities and content and to make suggestions. To create personalized Services which are both unique and relevant, we use your activities from the data we collect, information that you or third parties furnish and other information; we also use data relating to the way you use and interact with our Services; as well as data concerning people, location or elements with which or from which you have connected or that you have searched for on our Services.

• Information on all Yashima NBV Co., Ltd. Services: we link all information concerning your activity on the different Yashima NBV Co., Ltd. Services and devices in order to provide you with a more personal and consistent experience of all Yashima NBV Co., Ltd. Services you use, whichever medium you use. By way of example, we could suggest you request for assistance, to view or duplicate our Services or official services, to join a Yashima NBV Co., Ltd. group to which belong members of your Network, of your line of business or with which you communicate with through our integrated instant messaging service.
• Research and development of Services: we use all information at our disposal to develop, test and improve our Services, in particular through surveys and research, and by testing and correcting new Services and new functionalities.

4.2. Provide measures, analysis and other professional services.

We use the information at our disposal (in particular relating to your activity) to enhance decision-making, maintenance management, assist you, your management and your company, for example to plan schedules, to address difficulties you may encounter, to determine axes for improvement or to put in place preventive actions. We use such information to provide an analytics dashboard which allows for instance to follow in detail time spent per Equipment, per type of task, or associated costs.

4.3. Improve safety, integrity and security.

We use the information at our disposal to verify accounts and activities, to prevent dangerous or harmful behavior, to detect and prevent undesirable content and all other negative experiences, to preserve the integrity of our Services and to improve safety and security on the Yashima NBV Co., Ltd. Services. For example, we use data at our disposal to examine any suspicious activity or breach of our General Terms of Use and Privacy Policy.

4.4. Communicate with you.

We use the information at our disposal to send you commercial communications, inform you of our Services and of our different terms and conditions. We also use your information to address your enquiries when you contact us. The information also enables us to respond to Client and User requests and to facilitate the assistance services provided by the customer relations department.

4.5. Statistical Reporting and Analysis-Use of Anonymous and Aggregated Information

We may use certain Personal Data (such as the content and frequency of your tasks and activities) and other data about you to create de-personalized and aggregated information, including: de-personalized demographic information, de-personalized location information, information about the computer or device from which you access our services, or other analysis we create.

4.6.

To enable Yashima NBV Co., Ltd. to manage its business relations, if necessary, with its service providers and partners;

4.7.

To provide information to potential future acquirers/merger partners, if any, in connection with the outsourcing, sale or combination (including by acquisition) of part or all of Yashima NBV Co., Ltd.

5. How do we share information?

Your information is shared with others as follows:

5.1. Applications, websites and third-party services integrated to our Services or using our Services.

When you choose to use applications, websites or other third-party services which are integrated to Yashima NBV Co., Ltd., such applications, websites or third-party services can receive information relating to what you publish or share. If you activate Third-Party Software for use with any of our Services, you authorize us to allow the provider of such Third-Party Software to access your Data as required for the interoperability of such Third-Party Software with Yashima NBV Co., Ltd. Services. We are not responsible for any disclosure, modification or deletion of your Data resulting from access by this Third-Party Software.

a. Sharing with third-party partners.

We collaborate with third-party partners who assist us in furnishing and improving our Services or who use Yashima NBV Co., Ltd. to develop their activity. We do not sell any of your private information to these third parties. We equally impose strict limitations in relation to the way partners may use and disclose data we share with them.

b. Suppliers and service providers.

We provide information and content, including Personal Data, to our suppliers and service providers, who are located within and outside of the territory of Vietnam and/or Japan, and who support our business, including by offering services pertaining to technical infrastructure, providing Client service, and facilitating payment process or by allowing us to conduct surveys.

c. More generally, Personal Data may be shared with third party companies in the following cases:

• When you allow a third-party website to access your Personal Data;
• When the Platform uses service providers to provide Services or Client and user support, advertising and payment services. These service providers have limited access to the Clients's Personal Data, in the context of the performance of these services, and have a contractual obligation to use them in accordance with the provisions of the applicable regulations on the protection of Personal Data;
• If required by law, the Platform may carry out the transmission of data in order to follow up claims made against the Platform and to comply with administrative and legal procedures;
• If the Platform is involved in a merger, acquisition, disposal of assets or receivership proceedings, it may be required to sell or share all or part of its assets, including Personal Data. In this case, Clients will be informed before Personal Data is transferred to a third party.

5.2. Non-commercial use of Personal Data.

We undertake not to commercialize the Clients's Personal Data that we collect. We may aggregate the data communicated by / relating to Clients in order to provide reports containing aggregated and de-identified data resulting from our analysis of the information communicated by the Client if this data consists of a generic report relating in particular to company-affiliated details, and if no link can be established between this data and the Personal Data collected.

6. Duration of Personal Data conservation

We retain your Personal Data for the strict duration required in light of the pursued objectives, and in particular the proper functioning of the Application and the Services, and the management of Clients, in accordance with legal and regulatory requirements. After this period, we will delete or anonymize your data or, if this is not possible, store your data securely and isolate it from further use until deletion is possible. In any case, we anonymize any Personal Data at first request. It is reminded that when the Client acts as data controller and Yashima NBV Co., Ltd. as a subprocessor, it is up to the Client regarding the processing of the corresponding Personal Data. The Client shall inform and guarantee all his/her rights under the Applicable Regulations and Yashima NBV Co., Ltd. shall assist the Client in exercising these rights. When the Client submits data via form and/or telephone, Yashima NBV Co., Ltd. will store Client data, including the Client's log data, in accordance with the Client's instructions and as required by applicable law. The maximum retention period shall not exceed 10 years. We then act as subprocessors on behalf of the Client and provide this service in accordance with the Client's data processing instructions. Deletion of Client data and any other use of the Services by Client may result in the deletion and/or anonymization of certain other related information. For further information, please contact Yashima NBV Co., Ltd. at the contact details provided herein or contact the Client. Yashima NBV Co., Ltd. may retain Personal Data about you for as long as necessary for the purposes described in this Privacy Policy. This may include retaining your Personal Data even after you deactivate your account for the time necessary for Yashima NBV Co., Ltd. to defend its legitimate business interests, conduct audits, comply (and demonstrate compliance) with legal obligations, resolve disputes, and enforce our agreements.

7. Under which legal grounds do we process data?

We collect, use and share data in our possession if this treatment meets at least one of the following criteria:

• In accordance with Yashima NBV Co., Ltd.'s General Terms of Use and Privacy Policy, all other applicable policies, conditions and agreements accepted by the Client for the Services provided to the Client, as well as, as the case may be, in accordance with the contract(s) entered into with the Client;
• Under your consent, which can be revoked at any time through your profile settings on Yashima NBV Co., Ltd. You are reminded that we are not a party to the relationship between the Client, and that it is up to the Client to define the Personal Data transmitted at the request and/or under the direction and responsibility of the Client.
• In compliance with our legal obligations;
• For the purposes of our (or others's including our clients) legitimate interests, in particular our interests in providing an innovative, personalized, secure and profitable Service for our Users and partners and when we act as a subprocessor on behalf of our Clients, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data.

8. How can you exercise your rights under the General Data Protection Regulation?

In accordance with the General Data Protection Regulation, you have the following rights:

• Right to access, and notably the right to obtain copy of all your Personal Data, as well as all essential information regarding the way such Personal Data is used;
• Right to have rectified Personal Data, in prompt delays, and the right to have completed all incomplete, incorrect, ambiguous or obsolete information;
• Right to erasure of your Personal Data, if their processing is no longer necessary, or if you have withdrawn your consent or objected to their processing; or if their collection, use, disclosure or retention is prohibited;
• Right to portability of Personal Data; and the
• Right to object to their treatment.

The Client consequently guarantees the same rights to its Users with regard to the processing of Personal Data collected, processed and transmitted by the Client or by the User at the request and/or under the authority and responsibility of the Client. In any case, if you wish to oppose the processing of your Personal Data or wish to delete your information, you may address your request by registered letter with acknowledgment of receipt to: Yashima NBV Co., Ltd., 170 Street 5, Binh Tri Dong B Ward, Binh Tan District, Ho Chi Minh City, or by email at tarui@yashima-vn.com, and we shall delete all your Personal Data within a period of 30 days. For all other queries pertaining to Yashima NBV Co., Ltd.'s use of your Personal Data, or for all requests for rectification, for the restriction on processing, or for the copy of your Personal Data, please address your request by registered letter with acknowledgment of receipt or by email respectively at the above-mentioned addresses. We shall treat your request within a period of 30 days. Finally, you may also make any inquiry or request before the control authorities.

Contact Us

For inquiries regarding this policy, please contact to following address.

Address: B, LOT K 1-2-5, LE MINH XUAN IP, BINH CHANH DIST., HCMC, VIETNAM
Company Name: YASHIMA NBV CO.,LTD.
Email Address: tarui@yashima-vn.com
TEL: +84-28-36207325