Enacted on May 25^th 2018

Last Revised on July 1^st 2022

NTT Communications Corporation,
with registered office and business address
at OTEMACHI PLACE WEST TOWER 2-3-1 Otemachi, Chiyoda-ku, Tokyo, Japan

Katsushige Kojima
President & CEO
Representative Member of the Board of the Company

Where NTT Communications Corporation (the "Company","we" or "us") processes personal data of an individual located in the EEA (European Economic Area: Member States of the European Union, Iceland, Norway, and Lichtenstein) ("you") this Privacy Policy will apply. Our Chief Security Officer (“CSO") will be responsible for managing your Personal Data and can be contacted as set out in Section 7. For the purpose of this Privacy Policy, "Personal Data" means any information related to a living individual as further described in the EU General Data Protection Regulation.

1. General
   

   The Company will comply with laws and standards concerning the protection of Personal Data, and take all necessary measures to protect your Personal Data.

2. Categories of Personal Data Collected and Sources
   

   We may collect or otherwise obtain access to your Personal Data as follows:

   • if we are engaged to provide our services to a corporate client that you work for (or are being considered as a potential service provider), your employer may provide your business contact information to us for the purposes of managing our service agreement ("Business Contact").

   If we process your Personal Data as a Business Contact then the categories of Personal Data that we collect and process are your name, business email address and phone number, job title and function. We use this information for our legitimate business interests for purpose of managing our contractual relationship with your employer in accordance with the terms of that engagement, including for the purpose of:

   • notifying any changes in charges and services;
   • managing the contract and providing our services in accordance with the applicable engagement terms or service agreement;
   • responding to proposals and provide consultation services;
   • providing promotional materials or gifts and conduct sales promotions in relation to corporate services;
   • conducting customer satisfaction surveys;
   • improving Company's services and for developing new services; and
   • answering any questions or provide consultation as may be requested.

   In addition to the purposes set out above, we may from time to time specify other purposes as part of the ongoing services or a customer satisfaction survey but in such case, we will clearly notify you of this in the relevant communication

   Please note that where we process your Personal Data as a Business Contact, we may need to retain your Personal Data even if your employment ceases or our contract with your employer is terminated or expires. We will retain and process your Personal Data in these circumstances for the purpose of compliance with applicable laws and regulations such as our corporate income tax laws and regulations and potential legal claims and it will be destroyed or deleted once it is no longer required.

3. Data Security
   

   We will protect Personal Data that you provide, or your employer provides on your behalf through continuous efforts to:

   1) maintain internal regulations and internal management system to protect Personal Data,

   2) provide employee training, and

   3) take appropriate measures against illegal access, loss, destruction, falsification, and disclosure of Personal Data.

4. Disclosure and Provision of Personal Data
   

   1) We may disclose and provide your Personal Data to our subcontractors and its group companies, including any subsidiary or holding company (each a "Group Company"), to the extent reasonably necessary to achieve the purposes as identified in Section 2 of this Privacy Policy.

   2) In respect of sub-section 1 above, subject to compliance with applicable laws and regulations, we will verify that each subcontractor and/or Group Company to which Personal Data is to be disclosed by us has implemented the measures necessary to protect Personal Data, and take all appropriate and necessary actions including but not limited to entering into appropriate agreements (or internal arrangements as appropriate) with such subcontractors and/or Group Company to protect Personal Data.

   4) Notwithstanding anything to the contrary stated above, we may disclose and provide Personal Data to government authorities, including but not limited to any court or police if required or requested properly pursuant to any applicable law or order.

5. Transfers outside the EEA
   

   If your Personal Data is transferred to any jurisdiction outside the EEA,we will ensure that such transfer is relied on the adequacy decision by the EU, or governed by data transfer agreements or mechanisms designed to ensure that your Personal Data is protected (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission).

6. Retention
   

   Except as set out in the final paragraph of Section 2, we will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.

7. Contact Point for Rights of Personal Data
   

   If you have any questions or comments in relation to your Personal Data, please contact to the following contact point. Company will respond to your requests in a timely manner.

   <Contact Point for Rights and Inquiries for Personal Data>

   NTT Communications Corporation

   OTEMACHI PLACE WEST TOWER 2-3-1 Otemachi, Chiyoda-ku, Tokyo, Japan

   

   
   

   EU Data Protection Representative: NTT Netherlands B.V.

   Veemweg 23-25,3771 MT Barneveld, the Netherlands

   

   
   

   You may have a right of access to the Personal Data that we hold about you and you may also require any inaccurate information to be corrected and/or deleted. You may also have the right to object to our use of your Personal Data for our legitimate business purposes in some situations. If you wish to exercise any of these rights, please contact us at the details set out above.

8. Changes to this Privacy Policy
   

   We may revise this Privacy Policy from time to time and any such updates will be announced and made available on our official website or you can contact us at the details set out in Section 7 and we will provide you with a copy.