Handling of Personal Information (Notice on Retained Personal Data and Third-Party Provision Records)

Recho, Inc.

Hanzomon PREX North 4F, WeWork, 2-3-2 Kojimachi, Chiyoda-ku, Tokyo 102-0083

Representative Director: William Qiu

• Personal Information Protection Manager: Makito Nakashima
• Deputy: Contact Desk
• Contact: 03-4550-0966 (Weekdays 10:00–19:00 JST)

(1) Purposes for personal information of customers and external individuals

• Business communications regarding contracts, invoicing, and payment
• Responding to inquiries, complaints, and consultations
• Providing information and after-sales notices related to our Voice AI Agent development business

(2) Purposes for personal information of job applicants

• Providing information about recruitment events, selection administration, and related communications

(3) Purposes for personal information of employees (including retirees, spouses, and dependents)

• Employment, labor, and human-resources administration
• Procedures required by law

(4) Purposes for personal information of requesters in disclosure procedures

• Investigating, answering, and communicating with requesters

(5) Purposes for personal information of inquirers (including general complaints and consultations received by phone/email)

• Responding to complaints and consultations

(6) Purposes for personal information of secondees and dispatched staff from external agencies

• Business communications and HR/labor administration

(7) Purposes for personal information provided via recruiting sites

• Sending materials at the individual's request, and related communications
• Providing information on our products and services

(8) Purposes of use of Individual Numbers and personal information containing them (Specific Personal Information)

① Specific Personal Information of employees, their spouses, and dependents

• Employment insurance and workers' accident compensation filings
• Health insurance and employees' pension filings
• Withholding-tax filings
• Preparation of withholding tax slips

② Specific Personal Information of individuals other than employees

• Preparation of payment records (支払調書)

(9) Purposes for personal information entrusted to us by external operators

• Conducting our Voice AI Agent development business as a service

The Company implements necessary and appropriate safety management measures to prevent leakage, loss, or damage of customer information, and oversees employees and contractors who handle personal information.

(1) Establishment of rules for handling personal information

A personal information protection policy and related regulations are established in accordance with the Act on the Protection of Personal Information and related laws.

(2) Organizational safety management measures

A Personal Information Protection Manager and operations supervisors are appointed; safety management frameworks are also maintained at contractors and subcontractors.

(3) Human safety management measures

Employees receive periodic training and internal audits are conducted.

(4) Physical safety management measures

Only authorized personnel may enter areas handling personal information; entry/exit logs and viewing restrictions are in place.

(5) Technical safety management measures

Information systems are protected from external unauthorized access and malicious software.

(6) Awareness of the external environment

When handling personal information in a foreign country, the Company identifies the relevant protection regime and takes the measures required.

(1) Where to submit a request

Mailing address: Recho, Inc. — Disclosure Requests Desk, Hanzomon PREX North 4F, WeWork, 2-3-2 Kojimachi, Chiyoda-ku, Tokyo 102-0083, Japan

Please send by registered mail or parcel delivery with tracking.

(2) Documents required

Complete the prescribed "Personal Information Disclosure Request Form" and enclose identity-verification documents.

One of the following as identity verification:

• Driver's license (copy; include the back if there are entries)
• Certificate of residence (issued within the last 6 months; copy acceptable)
• Health insurance certificate (copy; include the back if there are entries; mask the registered domicile)

(3) Requests through an agent

If a request is made through an agent, please enclose the following:

① Identity-verification documents of the agent (one of the following)

• Driver's license (copy; include the back if there are entries)
• Certificate of residence (issued within the last 6 months; copy acceptable)
• Health insurance certificate (copy; include the back if there are entries; mask the registered domicile)

② Power of attorney

Sealed by the principal, enclosed with the principal's seal-registration certificate (issued within the last 6 months; copy acceptable). For a statutory agent such as a parental authority, a family register extract or certificate of residence (issued within the last 6 months; copy acceptable) is also acceptable.

(4) Fees for disclosure and purpose-of-use notification

A fee of JPY 1,000 (tax inclusive) is required per request. Please enclose JPY 1,000 worth of postage stamps. Postage to the Company is borne by the requester. If the fee is insufficient, the request will be deemed not made.

(5) Method of response

We will reply in writing to the address on the request form within 14 business days. If we cannot meet this deadline for unavoidable reasons, we will notify the requester.

(6) Dismissal of a request

If the application documents are incomplete or the fee is insufficient, we will contact the requester. If there is no response within one month thereafter, the request will be deemed not made.

(7) Grounds for non-disclosure

We cannot respond to disclosure in the following cases. When a non-disclosure decision is made, we will notify the requester stating the reason. A fee is still required in cases of non-disclosure or non-notification:

• Where identity cannot be verified (e.g. the address on the request does not match the identity documents or our records)
• Where the agent's authority cannot be verified for an agent-submitted request
• Where the personal information held by the Company cannot be specified from the contents of the request
• Where the subject of the request does not fall within the scope of personal information subject to disclosure
• Where there is a risk of harming the life, body, property, or other rights and interests of the individual or a third party
• Where there is a risk of significantly impairing the proper execution of our business
• Where the request would violate laws and regulations

Recho, Inc. — Contact Desk

Address: Hanzomon PREX North 4F, WeWork, 2-3-2 Kojimachi, Chiyoda-ku, Tokyo 102-0083, Japan

TEL: 03-4550-0966 (Weekdays 10:00–19:00 JST)

* Inquiries received on Saturdays, Sundays, national holidays, Golden Week, summer holidays, the company's anniversary period, and the year-end/new-year period will be handled on the next business day.