Nabelin Co.,Ltd. recognizes that it is its social responsibility to protect personal information obtained through its business activities, complies with the Act on the Protection of Personal Information and related laws, and strives to protect personal information based on the following policies.

1.  Acquisition of Personal Information
   We will obtain personal information through legal and fair means.
2.  Use of Personal Information
   （１）Personal information will be used within the scope of the specified purpose of use.
   （２）In cases where personal information is shared or the acquisition and use of personal information is outsourced, a strict investigation shall be conducted on the parties to which the personal information is shared or outsourced, and appropriate supervision shall be conducted to ensure confidentiality.
3.  Provision of Personal Information to Third Parties
   （１）Personal information will not be provided to third parties without prior consent of the individual, except as provided by laws and regulations.
   （２）Notwithstanding (1), in accordance with the provisions of laws and regulations, with the primary purpose of proper distribution of ethical drugs, etc., personal data held by the Company may be provided to third parties in order to collect and provide information in accordance with pharmaceutical laws and regulations or to provide information on products handled.
4. Managing Personal Information
   （１）We will maintain the accuracy of personal information and manage it safely.
   （２） In order to prevent loss, destruction, falsification and leakage of personal information, appropriate information security measures against unauthorized access, computer viruses, etc., shall be taken.
   （３）Personal information will not be leaked by taking it out and sending it outside.
5. Disclosure, Correction, and Suspension of Use of Personal Information
   Regarding retained personal data that can identify the individual, if the individual (or his/her agent) requests disclosure, correction, suspension of use, etc., we will respond appropriately and promptly.
6. Organization and System
   （１）The Company appoints a Chief Compliance Officer to properly manage personal information.
   （２）We will make all members aware of the protection of personal information and proper management methods, and ensure proper handling of personal information in daily operations.
7. Formulation, Implementation, Maintenance and Improvement of Rules and Standards for the Management of Personal Information and Specific Personal Information
   In order to implement this policy, the Company has formulated the Personal Information and Specific Personal Information Management Rules, procedures, etc., and will implement, maintain, and continuously improve these rules and procedures by thoroughly informing employees and their related parties.

April 1, 2023

Nabelin Co., Ltd.
President　Hiroyuki Shima

Handling of Personal Information

Nabelin Co.,Ltd. (hereinafter called our company) shall, in compliance with the “Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”)” and related laws and regulations, properly manage the personal information provided and handle it as follows.

Purpose of Use of Personal Information

Our company will use all or part of the personal information you provide for the purpose of carrying out all business and operations in and outside Japan related to each of the following (Name, company/organization name, affiliation, title, address, telephone/fax number, e-mail address, etc. written or displayed on business card or e-mail).

1. 1. Sale and trade of goods traded in our company.
   2. Development, design, manufacturing, processing, repair, installation of machinery and equipment, collection and transportation of industrial waste related to the preceding item.
   3. Processing and provision of various kinds of information and sale and purchase of computer hardware software.
   4. Acceptance of contracts for accounting, general administration, logistics, and all other operations, and management guidance.
   5. In-Home Long-Term Care Support Business and In-Home Service under the Long-Term Care Insurance Act.
   6. All business related to our company shareholders.
   7. All our company hiring operations.
   8. All operations involving our company members.
   9. Other operations for businesses prescribed by our company Articles of Incorporation.

Restriction on Provision of Personal Information to Third Parties

1. The provision of personal information to a third party without obtaining the consent of the person in advance is prohibited except for the following cases.
   (1) In accordance with laws and regulations.
   (2) Cases where it is necessary for the protection of a person’s life, body, or property and where it is difficult to obtain the consent of the person.
   (3) Cases where it is particularly necessary for the improvement of public health or the promotion of sound upbringing of children, and where it is difficult to obtain the consent of the person.
   (4) Cases where a person cooperates in the execution of affairs prescribed by laws and regulations by a national organ, a local government, or a person entrusted thereby, and there is a risk that the execution of said affairs may be hindered by obtaining the consent of the person concerned.
2. Notwithstanding the preceding paragraph, in accordance with the provisions of the Act on the Protection of Personal Information, the main purpose of personal information is the proper distribution of prescription drugs, etc., and in order to collect and provide information in accordance with pharmaceutical laws and regulations or to provide information on the products handled, the personal data held may be provided to the third party listed below.
   (1) Suppliers
   ・Public office
   ・Pharmaceutical manufacturers and medical device manufacturers that our company does business with.
   (2) Items of retained personal data to be provided
   ・Name, age, date of birth, business information (name, address, contact information), e-mail address, telephone number, medical subject, specialty, department, title, position, graduate school, graduation year, membership association, and other information on prescription and research of drugs.
   (3) Means or method of provision
   ・Oral, written, or electromagnetic means.
   (4) Suspension of third-party provision
   ・At the request of the individual, we will stop providing the personal data that identifies the individual to third parties.
3. In the event that the matters listed in Paragraph 2 are changed, the change shall be notified to the person in advance or shall be made readily known to the person.

Entrustment of Personal Information

Our company may entrust personal information to you in order to perform the business specified in the Purpose of Use. In such cases, we will select outsourcees that provide a sufficient level of information protection by establishing selection criteria, clarify their duties and responsibilities and measures to be taken to protect personal information in contracts, and appropriately supervise the outsourcees so that personal information can be safely managed.

Handling of Personal Information Associated with External Links

Websites operated by our company may contain external links. our company is not responsible for how personal information is handled, managed, or posted on external sites. Please contact the link site directly.

Response to Disclosure of Personal Information, Correction, Suspension of Use, etc

If a person (or his/her agent) makes a request for disclosure, correction, suspension of use, etc. of our company’s retained personal data pursuant to the Personal Information Protection Act, please send an application form and the following attached materials to the following person in charge. As soon as we receive the documents, we will confirm the identity of the person (or his/her agent), confirm the personal information to be requested, and review the contents of the request. We will respond to your request as soon as possible.

Attachments

(1) Identification card (Driver’s license, passport, copy of family register, etc.) Copy ・・・ 1
(2) A copy of the agent’s (1) material ・・・, if the agent is acting
(3) Documents proving the authority of representation (power of attorney, etc.) ・・・ 1

Also, please attach any documents that can identify the personal information pertaining to the request.

〈 Delivery address of materials 〉

General Affairs Group Compliance Office, Nabelin Co.,Ltd. 8- 10 Futaba, Matsumoto, Nagano, 390 -8722

* When sending to our company, please use registered mail or other appropriate means to avoid the risk of loss.
Also, the shipping cost will be borne by the person who will be charged.

■ We also accept inquiries about personal information by phone, fax and e-mail.
General Affairs Group Compliance Office in charge of “General Consultation Desk for Personal Information”
TEL：(+81)263-27-6545
FAX：(+81)263-27-6570
E-mail:k_komatsu@nabelin.co.jp

Application Form Based on the Act on the Protection of Personal Information