PRIVACY POLICY

The Reazon Group uses personal information obtained from Applicants in connection with Recruitment-Related Activities to the extent necessary for the following purposes:

• To provide information on open positions

• To accept applications or registrations for Recruitment-Related Activities

• To conduct Recruitment-Related Activities

• To confirm Applicants' skills and work experience and assess their suitability for the position applied for

• To handle administrative matters, such as communications, relating to Recruitment-Related Activities

• To improve the operation and management of Recruitment-Related Activities

• To provide information on onboarding procedures and related matters

• To manage employment following commencement of employment

• To assist with obtaining necessary entry visas, work permits, and similar authorizations

• To assess suitability for work within the Reazon Group (including placement and related matters) and for health management purposes

• To provide information on, and accept applications or registrations for, seminars and other events

• Where requested by the Applicant, to provide information on future recruitment events, recruitment information, company information, and other recruitment-related matters

• To conduct checks when an Applicant reapplies and to consider the Applicant for other positions or future employment opportunities

• For other activities related or incidental to Recruitment-Related Activities

The Reazon Group may use generative AI and other AI services to process personal information for transcription, summarization, organization, translation, drafting, analysis, and other tasks in support of the operations described above. Such processing will be carried out in accordance with Section 3, “Entrustment of Personal Information to Third Parties.”

[Information Collected]

The Reazon Group obtains Applicants' personal information, including the following, from Applicants or third parties such as service providers, to achieve the purposes set forth in "1. Purposes of Use of Personal Information":

• Name, age, address, gender, date of birth, phone number, email address, educational background, employment history, qualifications held, current annual compensation, desired annual compensation, and related information

• All information provided to the Reazon Group by an Applicant for the purpose of applying for or participating in Recruitment-Related Activities, regardless of format, including resumes, application forms, and questionnaires

•All content of communications in any form between the Reazon Group and an Applicant, such as conversations, correspondence, and phone calls, including but not limited to communications during interviews

• Information used for recruitment screening

• Application and participation history for Recruitment-Related Activities, and the results of recruitment screening

The Reazon Group may collect and use information regarding health status, disabilities, and other sensitive personal information in cases provided for under the APPI, or when necessary to assist with obtaining required entry visas, work permits, or similar authorizations; assess suitability for work (including placement and related matters); manage health; or for similar purposes.

[Methods of Collection]

In connection with Recruitment-Related Activities, and to the extent necessary to achieve the purposes set forth in "1. Purposes of Use of Personal Information," the Reazon Group primarily obtains Applicants' personal information by the following means. The Reazon Group collects personal information by lawful and fair means and does not obtain it through deception or other improper means.

• Through information provided by Applicants in documents or other materials submitted to apply for or participate in Recruitment-Related Activities, including resumes, application forms, and questionnaires

• Through communications in any form between the Reazon Group and Applicants, such as conversations, correspondence, and phone calls, including communications during interviews

• From third parties such as service providers engaged to conduct reference checks, employment verification, academic credential verification, and similar checks for recruitment screening

The Reazon Group may entrust all or part of the handling of personal information obtained in recruitment-related activities to contractors within the scope necessary to achieve the purposes set forth in Section 1, “Purposes of Use of Personal Information.” In doing so, we will carefully assess whether each contractor meets the selection criteria established by the Reazon Group and ensure, through the agreement with the contractor, that the personal information is properly managed.

In addition, the Company may use various cloud services—including generative AI and other AI services and cloud storage—provided by entities located outside Japan, including in the United States, and entrust the processing of personal information to those entities. In accordance with the Act on the Protection of Personal Information and related guidelines, we select service providers that have established a system ensuring the continuous implementation of measures equivalent to those required under that Act (a “system meeting the prescribed standards”). We oversee these service providers through measures such as entering into agreements, verifying certifications corresponding to the applicable statutory standards, and conducting periodic supervision to ensure that such equivalent measures are continuously implemented.

In addition to transfers based on a system meeting the prescribed standards described above, we may provide personal data to an entity located outside Japan based on the individual’s consent. In such cases, before obtaining consent to the transfer, we provide the information required by law, including information on the country in which the recipient is located, that country’s legal framework for the protection of personal information, and the measures taken by the recipient to protect personal information.

To the extent necessary to assist with the operations described in Section 1, “Purposes of Use of Personal Information,” personal information contained in application documents, records of interviews and other interactions, communications, and evaluation comments may be input into and processed by AI services. To the extent necessary for recruitment-related activities, the information to be processed may include the names, affiliations, remarks, and evaluation comments of interviewers and other officers and employees of the Reazon Group.

For transfers of personal information to AI service providers located outside Japan based on consent, we will obtain the individual’s consent after providing the details set out in Exhibit 1, “AI Services Used Based on Consent,” including the recipient, the purpose of the transfer, and the categories of personal information to be provided.

For information regarding legal frameworks for the protection of personal information in countries outside Japan, including the United States, please refer to the following website of the Personal Information Protection Commission:

https://www.ppc.go.jp/enforcement/infoprovision/laws/

For details of our protective measures for transfers outside Japan based on a system meeting the prescribed standards, please contact the office listed in Section 11, “Contact for Inquiries Regarding Personal Information in Recruitment-Related Activities.”

Except as permitted by law, the Reazon Group will not provide personal data to third parties without the Applicant's prior consent.

For purposes of this section, "third parties" means parties that meet the standards prescribed by the Reazon Group, including compliance with the APPI and other applicable laws and regulations and the establishment of appropriate information-security arrangements.

The Reazon Group jointly uses personal information to the extent necessary to achieve the purposes set forth in "1. Purposes of Use of Personal Information."

(1) Information Subject to Joint Use

Personal information obtained through the methods described in "2. Personal Information We Collect"

(2) Parties Jointly Using the Information

The Reazon Group

For information on the companies comprising the Reazon Group, please refer to the following page:

https://reazon.jp/company/

(3) Purposes of Use by Joint Users

To achieve the purposes set forth in "1. Purposes of Use of Personal Information"

(4) Party Responsible for Management of Joint Use

Reazon Holdings, Inc.

For the address, representative, and other corporate information of Reazon Holdings, Inc., please refer to the following page:

https://reazon.jp/company/

The Reazon Group takes necessary and appropriate measures to prevent the leakage, loss, or damage of personal information it handles and to otherwise ensure its secure management. For details of the security control measures implemented by Reazon Holdings, Inc., please contact us as described in "11. Contact for Inquiries Regarding Personal Information in Recruitment-Related Activities."

To understand usage of recruitment websites and similar sites and to operate and improve those sites, the Reazon Group may collect cookies, mobile advertising identifiers, website browsing history, and other information relating to Applicants ("Personally Referable Information").

The Reazon Group does not use such Personally Referable Information by linking it to Applicants' names, contact details, or other personal information managed by the Reazon Group. If, in the future, the Reazon Group uses such information in connection with Recruitment-Related Activities by linking it to Applicants' personal information, it will take the measures required under the APPI and other applicable laws.

The handling of Personally Referable Information in connection with other services provided or activities conducted by the Reazon Group is governed by the privacy policies and other rules applicable to those services or activities.

Even if an Applicant is unsuccessful or declines an offer of employment, the Reazon Group may use the personal information obtained, to the extent necessary, to conduct checks upon reapplication; consider the Applicant for other positions or future employment opportunities; analyze and improve Recruitment-Related Activities and recruitment screening processes; respond to inquiries concerning recruitment screening; and take other actions required by law or for business purposes.

Where an Applicant has requested information on future recruitment or employment opportunities, the Reazon Group may also use the information for that purpose.

The Reazon Group retains such personal information for as long as necessary for these purposes and, when it is no longer necessary to use the information, takes appropriate measures such as deleting, disposing of, or anonymizing it, in accordance with applicable laws and the Reazon Group's internal rules.

As set forth below, the Reazon Group responds to requests from Applicants themselves or their representatives for disclosure or other handling (meaning requests for disclosure of personal information or a record of provision to a third party; correction, addition, or deletion; cessation of use; or cessation of provision to third parties).

(1) Disclosure of Personal Information or a Record of Provision to a Third Party

Applicants may request that the Reazon Group disclose their personal information or a record of provision to a third party, to the extent permitted under the APPI and in accordance with procedures separately prescribed by the Reazon Group. However, the Reazon Group will not disclose information concerning recruitment screening, such as the screening process or reasons for screening decisions, and may also decline disclosure in any of the following cases:

• Where disclosure could harm the life, physical well-being, property, or other rights or interests of the Applicant or a third party

• Where disclosure could materially interfere with the proper conduct of the Reazon Group's business

• Where disclosure would violate other laws or regulations

• Where the Reazon Group cannot verify that the disclosure request was made by the Applicant or an authorized representative

The Reazon Group may charge a fee for a request to disclose personal information or a record of provision to a third party, in accordance with procedures separately prescribed by the Reazon Group.

(2) Correction, Addition, or Deletion

Applicants may request correction, addition, or deletion of their personal information in accordance with procedures separately prescribed by the Reazon Group. In such cases, the Reazon Group will promptly investigate to the extent necessary to achieve the relevant purpose of use and, based on the results, correct, add to, or delete the personal information to the extent permitted under the APPI.

(3) Ceasing Use or Provision to Third Parties

Applicants may request that the Reazon Group cease using their personal information or cease providing it to third parties in accordance with procedures separately prescribed by the Reazon Group. In such cases, Reazon Holdings, Inc. will cease using the personal information or cease providing it to third parties to the extent permitted under the APPI.

(4) Procedures

Where an Applicant or the Applicant's representative submits a request for disclosure or other handling of personal information, the Reazon Group will respond after verifying the Applicant's identity or the representative's authority in accordance with its separately prescribed procedures. For details on how to submit a request, please contact the office specified in "11. Contact for Inquiries Regarding Personal Information in Recruitment-Related Activities."

Reazon Holdings, Inc. will work to improve this Policy as appropriate. The Reazon Group may amend this Policy without prior notice to Applicants. Unless otherwise specified by the Reazon Group, any amended Policy will take effect when posted on this website.

Recruitment Strategy Department, Reazon Holdings, Inc.

YOTSUYA TOWER, 1-6-1 Yotsuya, Shinjuku-ku, Tokyo 160-0004, Japan

hr@reazon.jp