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Protection Policy Regarding Specific Personal Information etc. of Shareholders

Nippon Telegraph and Telephone Corporation (NTT)

NTT will handle the individual numbers and specific personal information of Shareholders (specific personal information of Shareholders is hereinafter referred to as “Specific Personal Information of Shareholders”, and Specific Personal Information of Shareholders and the individual numbers of Shareholders are hereinafter collectively referred to as, “Specific Personal Information etc. of Shareholders”) in accordance with the following policy, on the basis of the “NTT Group Information Security Policy”. In this policy, “Shareholder” means a shareholder or registered pledgee of shares (touroku kabushiki shichikensha), or a statutory agent of them, who are listed or recorded in the shareholders’ register as an individual, rather than legal entity.

  • 1. Handling of Specific Personal Information etc. of Shareholders

    • (1) The Purposes of Use of Specific Personal Information etc. of Shareholders

      The purposes of use of Specific Personal Information etc. of Shareholders retained by NTT are as follows.

      • A. Preparation of payment records for dividends, distributions of surplus, or interest on funds, or completing procedures related thereto.
      • B. Preparation of payment records for consideration of the transfer of shares etc. or completing procedures related thereto.
      • C. Preparation of payment records for amounts deemed to be dividends etc. or completing procedures related thereto.
      • D. Preparation of payment records for money granted etc. or completing procedures related thereto.
      • E. Preparation of records for consideration of the transfer of shares etc. received by a registered shareholder or completing procedures related thereto.
      • F. Preparation of records concerning the granting of specific share subscription rights etc. and specific foreign share subscription rights etc., or completing procedures related thereto.
      • G. Preparations of records concerning the exercise of share subscription rights or completing procedures related thereto.
      • H. Preparations of records concerning allotments of shares without contribution or completing procedures related thereto.
      • I. Preparations of notices concerning payment of dividends concerning listed share etc. or completing procedures related thereto.
      • J. Preparation of payment notices concerning amounts deemed to be dividends etc. or completing procedures related thereto.

      Further, when collecting Specific Personal Information etc. of Shareholders stated in a written document directly from Shareholders, NTT will explicitly indicate the purposes of use to such Shareholders unless it falls under any of the items of Article 18, Paragraph 4 of the Act on the Protection of Personal Information; provided, however, that in the cases falling under Article 16, Paragraph 3, Item (1) or (2) of the Act on the Protection of Personal Information, terms of which are partially replaced in accordance with Article 30, Paragraph 3 of the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, NTT may handle Specific Personal Information etc. of Shareholders beyond the extent necessary to achieve the abovementioned purposes of use.

    • (2) Provision of Specific Personal Information of Shareholders to Third Parties

      NTT will not provide Specific Personal Information etc. of Shareholders to any third parties; Provided, however, that in the cases where any of the items of Article 19 of the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures applies, NTT may, without obtaining prior consent of the relevant shareholder(s), provide necessary specific personal information to a related third party or may receive necessary specific personal information from a related third party.

    • (3) Joint Use of Specific Personal Information of Shareholders

      NTT will not jointly use Specific Personal Information of Shareholders with any third parties.

    • (4) Disclosure and other Procedures in Regard to Specific Personal Information etc. of Shareholders Retained by NTT

      NTT will respond to your requests for disclosure, correction etc., or suspension of usage etc. in regard to Specific Personal Information etc. of Shareholders retained by NTT.

    • (5) Point of Contact for Consultation Regarding Specific Personal Information etc. of Shareholders

      The point of contact for consultation regarding the handling of Specific Personal Information etc. of Shareholders can be reached by mail or e-mail at the address/e-mail address as stated below. We are afraid that we are unable to accommodate in-person inquiries. Thank you for your understanding.

      Nippon Telegraph and Telephone Corporation, Point of Contact for Shareholder Personal Information
      5-1, Otemachi 1-Chome
      Chiyoda-ku, Tokyo100-8116, Japan.

      Email: kabunusisama-info-ml@hco.ntt.co.jp

  • 2. Compliance with Laws

    When handling Specific Personal Information etc. of Shareholders, NTT will comply with the “Act on the Protection of Personal Information” and relevant laws and regulations, and applicable guidelines published by competent ministries and industry associations.

  • 3. Security Control Measures

    When handling Specific Personal Information etc. of Shareholders, NTT will take appropriate organizational security control measures, personnel-related security control measures, physical security control measures, and technological security control measures.

    • (1) Organizational Security Control Measures

      NTT (a) constructs committees, appoints managers of each organization, and constructs other organizational management systems, (b) establishes internal rules, (c) prepares statements including management ledgers and process management tables, and (d) improves the foregoing continuously.

    • (2) Personnel-Related Security Control Measures

      NTT (a) informs and educates all employees who handle Specific Personal Information etc. of Shareholders as to the significance of the protection of Specific Personal Information etc. of Shareholders, regardless of whether such employees are officers, full-time employees, or dispatched employees, (b) enters into non-disclosure agreements with such employees, and (c) conducts necessary oversight and supervision, in order to ensure effectiveness of personnel-related security control measures.

    • (3) Physical Security Control Measures

      NTT takes physical security control measures such as (a) access controls and theft preventions etc. for buildings and floors where Specific Personal Information etc. of Shareholders is handled, (b) measures against damage to Specific Personal Information etc. of Shareholders caused by fire, lightning, etc. and (c) locking management when removing, transferring or storing systems and documents.

    • (4) Technological Security Control Measures

      NTT takes technological security control measures such as (a) access controls, including authentication, authority management, controls and record-keeping when accessing personal data, (b) measures to be taken for systems against unauthorized software and virus, (c) protection measures during transfer, transmission and receipt by means of encryption, clarification of responsibilities or the like and (d) monitoring of information systems.

  • 4. Continuous Improvement of Management Systems

    NTT will be proactive in the protection of Specific Personal Information etc. of Shareholders by regularly, continuously and flexibly reviewing management systems and rules, and making constant improvements to ensure timely and appropriate management systems aligning with changing technologies and legal systems.

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