BREXA Group Privacy Policy

To safeguard its mutual trust with its employees, clients, business partners, job applicants and their affiliates, BREXA Group acknowledges the importance of protecting personal information of these parties. In line with this acknowledgement, BREXA Group is committed to appropriate protection of personal information in accordance with the Privacy Policy outlined below (hereinafter “this Policy”).
In this Policy, the term “BREXA Group” collectively refers to BREXA Holdings Inc. (hereinafter, “the Company”) and its affiliates in which the Company directly or indirectly holds a majority of outstanding stocks, carrying voting rights (hereinafter, “Group Companies”).
Other terms mentioned in this Policy are used as defined in the applicable laws governing matters related to the protection of personal information (hereinafter “Personal Information Protection Law”).

1. Appropriate Protection of Personal Information

BREXA Group shall establish an organizational structure to ensure secure and appropriate management of acquired personal information and to prevent its unauthorized use or external access, loss, damage, alteration, or leakage.

2. Appropriate Acquisition, Use, and Provision of Personal Information

When acquiring personal information, the purpose of its use must be clarified based on the nature of the relevant business operations, and the information must be acquired, used, or provided within the scope necessary for the fulfillment of the purpose. All employees and other individuals, regardless of their titles or employment statuses (including, but not limited to, representative directors, directors, auditors, operating officers, advisors, board members, employees, contract or part-time employees; hereinafter collectively referred to as “applicable individuals”) shall properly understand the intended purpose of the use of personal information, and they must not use such information exceeding the extent consistent with the purpose.
Additionally, appropriate measures shall be implemented to prevent the use of acquired personal
information for any inappropriate or unintended purposes.

3. Compliance with Laws, Regulations, National Policies, and Other Guidelines on the Protection of Personal Information

Applicable individuals shall properly understand the laws, regulations, national policies, and guidelines on the protection of personal information pertinent to their business. In the event of establishment, revision, or abolition of such regulatory frameworks, BREXA Group’s Management Systems for the Protection of Personal Information shall be updated swiftly to accommodate such changes.

4. Management of External Parties

BREXA Group may disclose personal data and information acquired pursuant to the preceding paragraph to external parties entrusted with its business. In such cases, BREXA Group shall conclude a non-disclosure agreement with the applicable parties and provide necessary guidance and supervision to ensure appropriate handling and protection of personal information.

5. Measures against Risks to Personal Information and Adjustments Thereof

Acknowledging the risks of leakage, accidental disclosure, loss, or damage of personal information, BREXA Group shall implement reasonable security measures to protect such information from physical, human, technical, and operational security perspectives. In addition, BREXA Group shall regularly assess the risks associated with personal information and maintain the effectiveness of the security measures by making necessary improvements.

6. Handling Complaints and Consultations on Personal Information

To handle individuals’ complaints or consultation regarding the handling of their personal information or operation of the Management System for the Protection of Personal Information, help desk(s) shall be established and authorized to take swift and appropriate actions.

7. Continuous Improvements to Organizational Framework for the Protection of Personal Information

To maintain appropriate protection of personal information, BREXA Group shall establish and operate its internal regulations aligned with this Policy and continuously improve their effectiveness by monitoring their contents regularly.

Please note that this Policy may be amended without prior announcement. In such cases, the revised Privacy Policy will be notified on BREXA Group’s webpage.

Point of Contact

For questions regarding the Privacy Policy, please contact:
BREXA Holdings Inc.
Personal Information Management Office(Compliance Management Department, Information Security Section).
1-8-3 Marunouchi, Chiyoda-ku, Tokyo
Postal Code: 100-0005
E-mail：information-security@brexa.com
TEL：03-3286-4888
FAX：03-3286-4999

American Engineering Corporation Privacy Policy

1. Purposes of Use of Personal Information

The Company shall use the obtained Personal Information (excluding Specific Personal Information, which refers to Individual Numbers and other information which contain such numbers) for the following purposes. Special Care‐Required Personal Information shall not be obtained without the consent of the Concerned Individual, excluding the cases prescribed by the laws and ordinances as exceptions to this provision. If purposes of the use of Personal Information are stated clearly and exclusively to the Concerned Individual at the time of its acquisition, Personal Information shall be used specifically for such purposes.

Information concerning the Employees and Executives of Business Partners	Announcement of the services provided by the Company, and related information; Request for questionnaires, surveys, etc. pertaining to the services provided by the Company, and related information; Receiving and handling applications for various seminars; Managing information concerning Business Partners; Business Communication and Performance of Contracts; Handling inquiries, etc.
Information concerning Job Applicants	Communicating and providing information on recruitment, selection, and other recruitment activities
Information concerning the Employees and Executives of the Company	Human Resources and employment management; Administration of Employment Insurance, Social Insurance, and Taxes; Management of Safety and Health; Provision of Welfare Services; Education, Training, and Staff Development; Procedures for Personnel Evaluation, Commendation, Disciplinary Actions, etc.; Procedures for Hiring, Cease of Employment, and Transfer; Management of Payroll, Bonus, Retirement Allowance, Corporate Pension, etc.; Proposing, information sharing, counselling, various procedures related to Labor Dispatchment; Business‐related communication and management of facilities and equipment; Management of Employee Housing and searches for employees’ accommodations; Emergency communication in disasters (including emergency drills); Planning, developing and improving business, as well as conducting research and analysis, and gathering statistics for these objectives; Announcing, proposing and conducting campaigns, events and projects; Handling inquiries, etc.

*Note: Regardless of whether the consent is obtained from the Concerned Individual, Specific Personal Information may only be used within the scope of purposes listed below, which are permitted under the “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures” (hereinafter shall be referred to as “My Number Act”).

Administrative works related to notification etc. of Employment Insurance
Administrative works related to notification etc. of Health Insurance and Pension Plans.
Administrative works related to notification etc. of Category III Insured Persons in National Pension Plans
Creation, submission, etc. of Withholding Records, and other administrative works related to Income Withholding
Administrative works related to the creation of declaration forms, notification forms, and application forms for Workers’ Property Accumulation Savings and Workers’ Property Accumulation Pension Savings
Administrative works related to the creation and submission of payment reports on salaries, fees, contract expenses and rewards
Administrative works related to the creation and submission of payment reports on stocks or shares, etc.
Administrative works related to the creation and submission of payment reports on Real Estate expenses and payment records of equivalent values (“considerations”) for Real Estate transfers
Administrative works related to each of the above

2. Joint Use

The Company may jointly use the obtained Personal Information (excluding Specific Personal Information) in accordance with the following criteria. Provided, however, that the joint use shall not be conducted exceeding the scope necessary to fulfill its purposes.

Personal Information to be Jointly Used
Identity‐related Information such as Home Address, Name, Telephone Number, Age, Gender, Email Address and the contents of the obtained information and inquiries etc.

Scope of Joint Users
AEC’s Group Companies in Japan

Purposes of Joint Use
Purposes for the joint use of Personal Information shall be as specified in Article 2, “Purposes of Use of Personal Information” of this Policy.

Responsible Party in Administration
BREXA Holdings Inc.

3. Management of Personal Information

In compliance to the “Regulations on Personal Information Management”, the Company shall handle the obtained Personal Information properly and rigorously. Upon its use, the Company shall promptly delete and dispose of any Personal Information which is no longer necessary, in accordance with the prescribed procedures of the Company.

4. The Provision of Personal Information to Third Parties

The Company shall not provide obtained Personal Information (excluding Specific Personal Information) to third parties, excluding the company’s entrusted contractors, without consent of the Concerned Individual. However, this provision shall not apply to cases where there are justifiable reasons for such provision (e.g. when disclosure is required under the laws and ordinances).

*Regardless of whether consent is given by the Concerned Individual, Specific Personal Information shall not be provided to third parties, except in the case of outsourcing the handling of such information, or cases when the provision is required under Article 19 of the My Number Act and other laws and ordinances.

5. Disclosure, Correction etc., and Suspension of Use etc. of Personal Information

Request for disclosure, correction etc. (correction, addition or deletion) or Suspension of use etc. (suspension of use, deletion or suspension of third‐party provision) concerning the Retained Personal Data shall be made by the Concerned Individual by contacting the “Point of Contact”, provided at the end of this Policy. The Company shall promptly handle the request within the reasonable scope, upon verification of the identity of the Concerned Individual.

Provided, however, that this provision shall not apply if acceptance of such request may infringe on the rights of third parties, impede the proper operation of the Company’s business, or violate the laws and ordinances.

6. Compliance with Laws, Ordinances and Regulations

The Company shall comply with the relevant laws and ordinances related to Personal Information as well as other regulations.

7. Continuous Improvement of the Personal Information Protection System

With the aim to properly maintain protection of Personal Information, the Company shall strive for continuous improvement of its supporting frameworks by setting, operating and regularly monitoring the content of the regulations etc. based on this Policy.

8. Point of Contact

For any inquiries concerning Personal Information, please contact the following:

【Point of Contact】
Method of Contact and Contact Information

Form:	https://www.aec-japan.co.jp/en/contact/
Telephone:	Operating Hours = 8:00‐12:00, 13:00‐17:00 (Business days of the Company) ・For Business Partners: 098‐897‐6781 (Main) ・For Retired Executives and Employees: 098‐897‐6781 (Main) ・For Job Applicants: 098‐897‐6783 (Direct)
Postal Mail:	American Engineering Corporation General Affairs Department 7-11-47 Oyama, Ginowan-shi, Okinawa, JAPAN, 901‐2223

Last revised on July 1, 2025