Personal Information Protection Policy

KELK Ltd. makes efforts below based on the belief that the proper protection of personal information is a corporate social responsibility.

• KELK Ltd. shall only process personal information provided by its customers within a scope to achieve the following purposes and legal basis:
  1. (1) When we have obtained customers' prior unambiguous consent
  2. (2) To execute contracts with customers
  3. (3) To comply with its legal or regulatory obligations
  4. (4) To protect its legitimate interests

  Its legitimate interests referred to above include:
   • To develop and provide better products and services
   • To provide information to customers about the products and services handled by KELK Ltd.

• KELK Ltd. does not disclose or provide personal information about customers to third parties except in any of the following cases:
  1. when the customer gives prior consent,
  2. when designated to do so by laws or ordinances,
  3. when the provision of personal information is necessary to protect life, physical injury, or the assets of a person, and when when consent from the customer is difficult to acquire, and
  4. when prescribed to do so such as in a notification or directive from a government agency
• KELK Ltd. will continually improve its personal information management system, including this policy, through employee education, appointment of information management supervisors as well as the execution of audits, while complying with the Personal Information Protection Act and other relevant laws and regulations. KELK Ltd. has developed and disclosed "Komatsu’s Worldwide Code of Business Conduct" to ensure all employees of the Komatsu Group adhere to this Code. Therein, KELK Ltd. has clarified proper handling of information and rules all employees must follow in an effort to enhance compliance.
• KELK Ltd. stores personal information for the period necessary to achieve the purpose of obtaining the personal information. However, if the laws require differently, such a period will be set in accordance with the laws.
• KELK Ltd. will implement appropriate safety measures, as it strives to build a management system and implement reasonable technological and other initiatives to protect the personal information of customers from illegal access, revision, destruction, leaks, loss or any other misconduct.
• KELK Ltd. handling customers' personal information in foreign countries, we will take appropriate measures for safety management based on the laws and regulations concerning the protection of personal information in each country and region.
• KELK Ltd. responds, in compliance with the laws and regulations, to customer's requests to confirm or revise his or her personal information or withdraw consent or to others. Please make any requests to the contact below.

[Processing personal information of European Union (EU) residents]
Personal data of EU residents may be transferred to countries not recognized by the EU Commission as a country having an adequate level of protection; however, in such a case, KELK Ltd. and companies to which personal information is transferred appropriately handle such personal data of EU residents in accordance with the appropriate safeguards set forth by the EU Commission. (e.g., upon conclusion of Standard Contractual Clauses, and sufficient safety control measures). Furthermore, data subjects residing in the EU can lodge complaints to the supervisory authority with regard to the processing of personal data by KELK Ltd.

Tsutomu Ohuchi, President, KELK Ltd.
Created: April 2019
Revised: April 2022

KELK Ltd. obtains personal information necessary to engage in sales, service and rental of construction and mining equipment as well as industrial machines, and said personal information is jointly used by KELK Ltd., and Komatsu Group and other companies, as indicated below to promote smooth operations.
KELK Ltd. is going to put in place reasonable safety management measures among companies to properly protect personal information that is jointly used.

• Personal information to be used jointly
  1. Personal information to be used jointly includes the customer name, address, telephone number, product purchase history, service history such as inspections and repairs, renting/leasing history, and operation history of machines
• Companies that jointly use personal information
  1. Komatsu Group companies, and outsourcing and tie-up companies that engage in operations such as sales, service and rental
• Purposes for joint use of personal information
  1. To execute contracts with customers
  2. To develop and provide better products and services
  3. To smoothly execute sales, service and rental operations of products handled by KELK Ltd., and
  4. To provide information to customers about the products and services handled by KELK Ltd.

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