TESS Engineering Co., Ltd. Privacy Policy

1．Basic Policy

TESS Engineering Co., Ltd. (the “Company”) believes that a corporation has an important social obligation to handle Personal Information (defined in Paragraph 2) appropriately in compliance with the Act on the Protection of Personal Information.
The Company has established the following Privacy Policy (the “Policy”) to ensure appropriate handling and management of Personal Information.

2．Definition of Personal Information

For the purposes of this Policy, Personal Information refers to information related to a living individual that falls under any of the below:

• (1) Information which allows identification of a specific individual by the included name, birth date, and other descriptions (including information that could easily be reconciled with other information to identify a specific person); and
• (2) Information that includes Individual Identification Code.

3．Acquisition and Use of Personal Information

When acquiring Personal Information, the Company will disclose or notify its purpose of use (through this Policy or otherwise) and employ lawful and fair means of acquisition. No Personal Information will be acquired by the Company unless permitted by the person to which the information relates, or by deception or other wrongful means. The Company will use Personal Information appropriately and to the extent necessary for achieving its purpose of use.

4．Purposes of Use of Personal Information

The Company will use and keep Personal Information for the following purposes. No Personal Information will be used or provided by the Company for any other purposes than those listed below without prior consent of the person to which the information relates.

(Personal Information of customers)

• ・To provide information about us.
• ・To maintain, manage, protect and improve the services and solutions provided by the Company and develop additional services and solutions (such as offering new rate plans or new systems in our electricity retail business.)
• ・To respond to inquiries of customers.
• ・To conduct any other activities related to the foregoing or otherwise achieve the purposes of use specified at the time of acquiring Personal Information.

(Personal Information of business partners)

• ・For communication necessary in business, performance of agreement or duties (e.g. safety and health control at a construction site), business negotiation, etc.
• ・To provide information to and communicate with business partners.
• ・To manage information about business partners.
• ・To conduct any other activities related to the foregoing or otherwise achieve the purposes of use specified at the time of acquiring Personal Information.

(Personal Information of employees, officers and other members of us)

• ・For business communication.
• ・For the payment of compensation (salary, bonus, allowances and other benefits), performance of HR and labor management, and provision of welfare benefits.
• ・To perform safety and health control for our members.
• ・To manage HR affairs for our members.
• ・To conduct any other activities related to the foregoing or otherwise achieve the purposes of use specified at the time of acquiring Personal Information.

(Personal Information relating to recruitment activity and to applicants)

• ・To contact or provide information for recruitment activity and to applicants.
• ・To perform any other duties connected to our recruitment activity, as well as HR and safety control and other related activities in the post-employment phase.

5．No Disclosure or Providing of Personal Information to Third Parties

Except as provided in the preceding section or unless required by law or regulation, the Company will not disclose Personal Information to any third parties.

6．Management of Personal Information

The Company will take the security measures listed below against any risk of unauthorized access to, or loss, destruction, falsification, leakage, etc., of Personal Information. In addition, the Personal Information held by the Company will be kept accurate and up to date to the extent necessary to achieve their purposes of use and deleted without delay when such use is not necessary anymore.

• (Formulation of basic policy)
  Establishing a basic policy (that is, this Policy) under which the proper handling of Personal Information or personal data shall be ensured, and measures prescribed by laws, regulations, or guidelines shall be taken.
• (Development of disciplines on the handling of personal data)
  Establishing the "Basic Rules on the Protection of Personal Information" specifying the conditions under which acquisition, use, saving, providing, deletion, or disposal of Personal Information shall be conducted and the persons responsible for these actions and their respective roles.
• (Organizational Security Control Measures)
  Appointing persons responsible, specifying employees authorized to handle Personal Information and scope of Personal Information handled, developing a reporting system to be used when any fact or sign of breach is detected, and conducting regular internal audits and other controls on the handling status of Personal Information.
• (Human Security Control Measures)
  Organizing regular employee training on the points to note about the handling of Personal Information and setting out non-disclosure provisions in our Work Rules.
• (Physical Security Control Measures)
  Measures against any access to personal data by a person who is not authorized to do so and measures to prevent any theft or loss of device, electronic media, document, etc.
• (Technical Security Control Measures)
  Conducting access control by limiting persons in charge of handling Personal Information and scope of Personal Information database handled and structuring the protection of information system against any unauthorized access from outside or illicit software.

7．Contact regarding Personal Information

For inquiries, correction, suspension of use, etc., of Personal Information, or to consult or make claims regarding the handling of Personal Information, please contact the following and we will promptly respond to the extent reasonable.

＜Personal Information Contact Information＞
TESS Holdings Co., Ltd.
Public Relations & Investor Relations Team
Corporate Management Unit, Administration Department
TEL: +81-6-6308-2794 FAX: +81-6-6308-2749

8．Handling of Non-personally Identifiable Information and Anonymized Information

When creating or using non-personally identifiable information or anonymized information, the Company will establish necessary processing standards and take security control measures in compliance with the Act on the Protection of Personal Information and other applicable laws and regulations and use such Personal Information within its purpose of use.

9．Consignment of Personal Information

The Company may consign or provide acquisition or management of Personal Information to a third party within the scope of use of Personal Information. In such a case, the Company will manage that the party to whom the Personal Information is consigned or provided will satisfy sufficient level of protection of Personal Information.

10．Shared Use

(1) Provisions applicable within our group

The Company may share the use of Personal Information it acquires under the following conditions:

• 1) Type of Personal Information subject to shared use:
  All Personal Information held by the Company, unless otherwise requested by the person to whom the information relates.
• 2) Scope of co-users:
  ・TESS Holdings Co., Ltd.
  ・Kyoritsu Engineering Co., Ltd.
  ・Kumamoto Nishiki Green Power LLC
  ・Any other companies of our group
• 3) Purposes of use by co-users:
  The same as those provided in Section 4 (Purposes of Use of Personal Information)
• 4) Name of the person or entity responsible for managing such personal data:
  TESS Holdings Co., Ltd.
  6-1-1 Nishinakajima, Yodogawa-ku, Osaka-shi, Osaka
  Hideo Ishiwaki, President

(2) Provisions relating to electricity retail business

In operating its electricity retail business, the Company may share the use of its customers' Personal Information with electricity retailers, general power transmission and distribution operators, the Organization for Cross-regional Coordination of Transmission Operators, Japan, and demand-control contractors. The Company complies with the "Privacy Policy on the Shared Use of Personal Information in Electricity Retail Business" set forth below in such shared use of information.

Privacy Policy on the Shared Use of Personal Information
in Electricity Retail Business

・Scope of Joint Users

We may jointly use personal information with the following parties^*1

• ・Electricity retailers^*2
• ・General electricity transmission and distribution utilities^*3
• ・Organization for Cross-regional Coordination of Transmission Operators, JAPAN
• ・Demand control contracting parties^*4

・Purposes of Joint Use

• (1) To conclude, revise or terminate wheeling service contracts and electric power quantity adjustment service contracts (hereinafter, “Contracts for Wheeling Services, etc.”)
• (2) To provide an intermediary service for the termination of contracts for retail supply^*5 (including contracts in relation to isolated island and last resort supply services) and contracts for receiving electricity (hereinafter, “Contracts for Retail Supply, etc.”)
• (3) To confirm information about service (power receiving) points
• (4) For the execution of work by general electricity transmission and distribution utilities based on Contracts for Wheeling Services, etc. such as: electricity meter reading; the maintenance, inspection and replacement of facilities; and the inspection of facilities during electricity outages and disasters, etc.
• (5) For the execution of work in relation to negawatt transactions

・ Items of Information to be Jointly Used

• (1) Basic information: Name, address, telephone number and contract number of the Contract for Retail Supply, etc.
• (2) Information about service (power receiving) points: Service areas of general electricity transmission and distribution utilities who conclude Contracts for Wheeling Services, etc., targets covered by the general provisions for isolated island services, service (power receiving) point identification number, information on the contract amount of wheeling contracts, electrical current upper limit value, electricity connecting transmission service menus, power factor, supply format, methods of decision-making under wheeling service contracts, meter information, lead-in pole number, availability of grid interconnection facilities, dates of changes made to wheeling contracts, meter reading date, contract status, and measures and methods of abolition
• (3) Information about negawatt transactions: Power sales volume, demand procurement volume, demand control volume, baseline

・Persons Responsible for the Management of Joint Use

• (1) Basic information: Electricity retailers who have concluded Contracts for Retail Supply, etc.
  (However, in the case of basic information on consumers receiving isolated island and last resort supply services, this refers to general electricity transmission and distribution utilities).
• (2) Information about service (power receiving) points: General electricity transmission and distribution utilities whose service area covers the supply (power receiving) site
• (3) Information about negawatt transactions: Demand control contracting parties.

• *1. We jointly use personal information only within the scope necessary for the purposes of joint use. We do not necessarily use personal information jointly with all electricity retailers, general electricity transmission and distribution utilities and demand control contracting parties.
• *2. Electricity retailers refer to business operators to which none of the grounds for refusal of registration under paragraph 1 of Article 2-5 of the Electricity Business Act (Act No. 170 of July 11, 1964) applies, and who are registered as electricity retailers by the Minister of Economy, Trade and Industry (including business operators deemed to be registered as electricity retailers pursuant to the Supplementary Provisions of the Act for Partial Revision of the Electricity Business Act, etc. (Act No. 72 of 2014)). (Please refer to the Agency for Natural Resources and Energy website（http://www.enecho.meti.go.jp/category/electricity_and_gas/electric/summary/retailers_list/） for the names, addresses and other information on these businesses.)
• *3. General electricity transmission and distribution utilities refer to Hokkaido Electric Power Network, Inc.; Tohoku Electric Power Network Co., Inc.; TEPCO Power Grid, Inc.; Chubu Electric Power Grid Co., Inc.; Hokuriku Electric Power Transmission & Distribution Company; Kansai Transmission and Distribution, Inc.; Chugoku Electric Power Transmission & Distribution Company, Incorporated; Shikoku Electric Power Transmission & Distribution Company, Incorporated; Kyushu Electric Power Transmission and Distribution Co., Inc.; and The Okinawa Electric Power Company, Incorporated.
• *4. Demand control contracting parties refer to business operations who have concluded demand control quantity adjustment service contracts with general electricity transmission and distribution utilities (including business operators who have acquired a business code prior to concluding a contract). (Please refer to the Organization for Cross-regional Coordination of Transmission Operators, JAPAN website（https://www.occto.or.jp/privacy/negawatt-jigyousya.html） for the names, addresses and other information on these businesses.)
• *5. “Intermediary service to terminate contracts for retail supply, etc.” is when an electricity retailer who has received an application for the conclusion of a new contract for retail supply, etc. from a customer requests to terminate the existing contract for retail supply, etc. entered into by and between the customer and their previous electricity retailer on behalf of the customer.

11. Compliance with Laws and Regulations

The Company will comply with all laws and regulations applicable with respect to Personal Information and the guideline of the Personal Information Protection Commission, and improve the actions set forth in the preceding sections as appropriate.

12．Other

The Company may change or revise the Policy without notice in accordance with the change in laws and regulations or change, etc., in our methods regarding protection of Personal Information.

Revised April 1, 2022