Privacy and Cookie Policy

1.Purpose of Use of Personal Information

ESTOH will obtain Personal Information through legal and fair means and use it only to the extent necessary to achieve the purposes of use described in the attachment. If ESTOH intends to use Personal Information for purposes other than those for which notice has been given, it will give prior notice to the user concerned in an appropriate manner and obtain their consent before doing so.

2.Protection of Personal Information

ESTOH will take necessary and appropriate measures to prevent unauthorized access to, loss, destruction, alteration, or leakage of Personal Information provided by users. In taking the above measures, ESTOH will comply with relevant laws, regulations, guidelines, etc., and implement "human and organizational safeguards" and "physical and technological safeguards" as follows.

Human and organizational safeguards

In addition to appointing a designated officer responsible for the management of Personal Information, ESTOH has established internal rules for safety management and has drawn up safety management policies to be followed by its employees. In addition, each department periodically conducts an inventory of all Personal Information in its possession and checks the status of its handling. Employees are regularly trained in the handling of confidential information, including Personal Information.

Physical and technological safeguards

ESTOH places restrictions on the persons authorized to access Personal Information (such as measures to immediately disable the accounts of employees who have transferred or retired), monitors access to Personal Information (such as through long-term storage of access logs), and controls access to and from rooms. In addition, ESTOH implements timely and appropriate measures to restrict the means by which Personal Information is taken off its premises (such as by limiting the use of USB devices and limitation of personnel who handle personal information, etc.) and to prevent unauthorized external access to Personal Information.

Assessment of the external environment

When storing Personal Information on the cloud or servers located overseas, ESTOH implements security control measures after assessing the systems in place for the protection of Personal Information in each country.

3.Contracting Partners

In order to ensure the proper execution of ESTOH's business activities, some or all of its operations are contracted to third parties. Personal Information may be provided to these third parties to the extent necessary to achieve the purpose of its use. In such cases, ESTOH will exercise necessary and appropriate supervision over the contractor to ensure that the Personal Information, etc. provided to the contractor is managed in a secure manner.

4.Joint Use of Personal Information

ESTOH may engage in joint use of Personal Information such as name, address, contact information (telephone number, e-mail address, etc.), place of employment, and opinions and questions submitted by users with overseas group companies^*, NOK, distributors, etc. to the extent necessary to achieve the purpose of use for which notice has been given to the user concerned. In the case of joint use of Personal Information with parties other than NOK's domestic group companies, overseas group companies, or distributors, ESTOH will first give notice of or publicly announce the items of Personal Information to be shared, the parties with whom the Personal Information will be shared, the purpose of use, and any other necessary details. Responsibility for the management of Personal Information during its joint use shall lie with ESTOH.

Regarding the provision of Personal Information to overseas group companies

Please refer to the website of the Personal Information Protection Commission (Japanese only) for information on the personal information protection systems of the countries where the overseas group companies are located. Each company manages Personal Information in accordance with the laws and regulations concerning Personal Information protection in their respective countries. In some cases, ESTOH may engage in joint use of Personal Information with group companies located in third countries that do not have a Personal Information protection system of a level equivalent to that of Japan. In such cases, ESTOH will request the group companies concerned to manage Personal Information appropriately and ensure that this is done.

5.Disclosure or Provision to Third Parties

Other than contractors and parties with which ESTOH engages in joint use of Personal Information, ESTOH will not disclose or provide Personal Information to third parties without the consent of the user concerned. However, in the following situations, Personal Information may be disclosed or provided without the consent of the user concerned.

1. When required by laws and regulations
2. When necessary for the protection of an individual's life, well-being, or property and it is difficult to obtain the consent of the user concerned
3. When specifically required for improving public health or ensuring the healthy development of children and it is difficult to obtain the consent of the user concerned
4. When necessary for cooperating with the police, courts, or other public agencies in the performance of the duties prescribed by laws and regulations, and obtaining the consent of the user concerned is likely to impede the performance of such duties
5. When Personal Information is provided as a result of succession of business through a merger, etc.
6. When otherwise required for reasons permitted under the relevant laws and regulations

6.Requests for Disclosure, etc.

When ESTOH receives a request for disclosure, notice of purpose of use, addition, correction, deletion, suspension of use, erasure, suspension of provision to a third party, etc. regarding Personal Information held by ESTOH, it will respond appropriately in accordance with the law after confirming that the person making the request is the user in question (or their representative). To make any type of request, please follow the procedure below.

7.Personal Information on Linked Sites

The ESTOH website may contain links to websites operated by other companies. Please refer to the privacy policies, etc. of the linked sites regarding their handling of Personal Information.

8.Inquiries

If you have any questions or complaints regarding this Privacy Policy or the handling of Personal Information, please contact ESTOH from here.