Last amended on April 1, 2022

This Privacy Policy is the policy regarding the handling of personal information by Recruit Holdings Co., Ltd. The privacy policy of each Group Company will apply to the handling of personal information at each Group Company.

Personal Information Protection Policy

Recruit Holdings Co., Ltd. ("Recruit Holdings") has established this Policy and a personal information management system based on its Code of Ethics, through which Recruit Holdings, as a company, is committed to realizing the responsible treatment of personal information.

Policy 1.

Recruit Holdings will, to the extent possible, specify the purposes of use of the personal information, and will properly handle the personal information within the scope necessary to achieve such purposes. Recruit Holdings will take measures to ensure the prevention of any use of the personal information other than for the intended purposes of use.

Policy 2.

Recruit Holdings will obtain personal information only through legitimate and appropriate means.

Policy 3.

Recruit Holdings will not provide any third party with the personal information of any individual without the consent of such individual.

Policy 4.

In managing personal information, Recruit Holdings will make efforts to take all necessary and appropriate measures to ensure the prevention and correction of any leakage, loss or damage of the personal information, as well as the otherwise secure management of the personal information.

Policy 5.

In handling personal information, Recruit Holdings will make efforts to ensure that the individual who has provided the information may properly be involved in the handling process, and make efforts to keep the personal information accurate and updated to the extent possible.

Policy 6.

Recruit Holdings will comply with laws and regulations pertaining to the protection of personal information, and establish, continuously review and comply with its internal rules pertaining to the protection of personal information.

Policy 7.

Recruit Holdings will have a section for responding to complaints and consultations concerning the protection of personal information and make efforts to properly respond to such complaints and consultations.

President, CEO, and Representative Director of the Board, Recruit Holdings Co., Ltd.

Hisayuki "Deko" Idekoba

(Supplementary Provisions) Established and implemented on April 17, 2002 Revised on April 2, 2003 Revised on April 1, 2004 Revised on December 15, 2005 Revised on June 6, 2007 Revised on March 5, 2008 Revised on April 1, 2018

Regarding the handling of personal information

Recruit Holdings Co., Ltd. ("Recruit Holdings") shall post this privacy policy and comply with it when handling personal information handled by Recruit Holdings, while taking the utmost care in the management thereof.

1. Acquisition of personal information

Recruit Holdings acquires personal information by the following methods:

• Receiving personal information directly from you;
• Automatically recording personal information when you use the site of Recruit Holdings;
• Receiving your personal information indirectly from third parties; or
• Acquiring personal information publicized in publications or on the Internet.

2. Purpose of use of personal information

Recruit Holdings shall use personal information only for the following purposes:

(1) Provision of information to shareholders, investors, or various affiliates, etc.

Examples of use include the following:

• Notice of campaigns held by Recruit Holdings and Group Companies; and
• Conducting various interviews and communications to provide better information.

(2) Performance of PR and IR activities of Group Companies

Examples of use include the following:

• Selecting by lottery the winners of SNS campaigns conducted by Recruit Holdings and delivery of prizes of rewards; and
• Writing articles regarding interviews and campaigns held by Recruit Holdings to be posted on the website of Recruit Holdings or published in press releases of Recruit Holdings.

(3) Responding to inquiries to Recruit Holdings

Examples of use include the following:

• Checking the details of opinions, inquiries, or posted comments of SNS sites, and responding to those.

(4) Improvement of communications, PR, and IR activities of Recruit Holdings in each item above

Examples of use include the following:

• Improvement of the site of Recruit Holdings based on results of analysis of usage of the website and SNS of Recruit Holdings;
• Improvement of quality of responses to inquiries; and
• Improvement of communications with shareholders and investors.

(5) Performance of rights and obligations based on the Companies Act and other laws and regulations

Examples of use include the following:

• Creating and managing data of shareholders and investors based on laws and regulations; and
• Providing various benefits to the legal status of shareholders.

(6) Countermeasures against fraudulent acts necessary for safe operation of the website, etc. of Recruit Holdings

Examples of use include the following:

• Conducting personal authentication and identification of the users of the website, etc.; and
• Investigation of applications for purposes prohibited by Recruit Holdings, transfer of rights or obligations, registration of false information, fraud, fraudulent access, and other fraudulent acts.

(7) Distribution of notices and announcements relating to recruitment and hiring by Recruit Holdings and Group Companies and consideration of whether to hire

Examples of use include the following:

• Considering and deciding employment requirements, considering and deciding whether to hire, confirmation of application histories, investigation of applicants' work experience and backgrounds, and performing other procedures necessary for hiring and screening activities;
• Providing information on necessary matters concerning joining Recruit Holdings and Group Companies after hiring and performing other procedures necessary therefor; and
• Personal labor management after joining Recruit Holdings and Group Companies.

(8) Various surveys and analyses necessary for each of the purposes of use above

Examples of use include the following:

• Conducting questionnaire surveys and monitoring surveys.

3. Provision of personal information to third parties

Recruit Holdings, as a general rule, does not provide any third party with your personal information without your consent. Recruit Holdings provides third parties with your personal information only after presenting this Privacy Policy or the individual purpose of use, and has obtained your consent thereto. However, Recruit Holdings may provide personal information without your consent within the scope not conflicting with related laws and regulations, where any of the following applies:

1. A.Providing such personal information is necessary for the protection of a human life, body, or fortune, and obtaining consent therefor from you is difficult;
2. B.Providing such personal information is specifically necessary for the improvement of public health or the sound growth of children, and obtaining consent therefor from you is difficult;
3. C.It is necessary to cooperate with a governmental organization or a local government, or a person designated by the same in the performance of administrative work prescribed by laws or regulations, and obtaining your consent thereto will likely hinder the performance of such administrative work;
4. D.The disclosure of the personal information is required by a court, public prosecutor's office, police or any other organization having similar authority through appropriate procedures;
5. E.The third party recipient is an academic research institution, etc. (a university or other institution or organization whose purpose is academic research, or a person belonging thereto), and that third party has a need to handle the provided personal information for academic research purposes (including where a part of the purpose is an academic research purpose; excluding where there is a risk that an individual’s rights and interests will be unjustly infringed);
6. F.You have expressly requested that your personal information be disclosed or provided to third parties;
7. G.It is permitted by law or regulations to disclose or provide the personal information; or
8. H.The personal information is provided in connection with a business succession due to merger or otherwise, to the extent that the personal information is handled within the scope of the purposes of use applicable prior to such succession.

4. Joint Use of personal information with Group Companies

Recruit Holdings may jointly use personal information with Group Companies ("Group Companies" means the group companies of Recruit Holdings within Japan set forth in our global network of companies) in accordance with the following:

• Personal information to be jointly used
  (1) Personal information such as e-mail addresses input by you in inquiry forms and personal information included in the contents of messages
  (2) Personal information submitted in relation to recruitment and hiring
• Purpose of use
  As for (1), to Respond to inquiries, etc.
  As for (2), to send notices and announcements relating to recruitment and hiring by Recruit Holdings and Group Companies and to consider whether to hire
• Scope of companies to jointly use personal information
  Group Companies

Entity responsible for the management of personal information

Recruit Holdings Co., Ltd.

The company profile is here.

5. Outsourcing of personal information handling

Recruit Holdings may outsource personal information handling operations in part or in whole. In such case, Recruit Holdings will provide necessary and proper direction to the party to whom such operations are outsourced.

6. Provision of personal information to third parties in foreign countries

Recruit Holdings may provide personal information to third parties in foreign countries (meaning countries or areas outside Japan, but excluding the countries listed here: only available in Japanese) in the following cases.

[If Recruit Holdings provides personal information to third parties] If Recruit Holdings provides personal information to third parties in foreign countries, Recruit Holdings will use personal information within the scope provided under "3. Provision of personal information to third parties"

[If Recruit Holdings outsources personal information handling operations] Some of the contractors to which Recruit Holdings outsources all or part of personal information handling operations are contractors in foreign countries. In such case, Recruit Holdings will provide necessary and proper direction to such contractor.

[If Recruit Holdings provides personal information due to succession of business by merger or other events] A successor to a business due to merger or other reasons may be an entity in a foreign country. In such case, such successor will handle personal information within the scope of purpose of use before succession of such business.

7. Request of disclosure, etc. of personal information

Recruit Holdings will store and use personal information within the scope and for the period necessary to comply with laws and regulations or to achieve the purposes of use, but the requester or agent thereof may, in accordance with the procedures prescribed by Recruit Holdings, request Recruit Holdings to disclose, correct, add, or delete content, discontinue utilizing, erase, notify the purpose of use of, provide information on security management measures, or disclose third party provision records (if applicable), etc. for the personal information that can be used to identify the requester to the extent permitted by laws and regulations. For details on how to make such requests, please contact Recruit Holdings as set forth in "8. Contact details regarding personal information". Furthermore, in order to prevent false requests due to identity theft, etc., Recruit Holdings will conduct identification by using reasonable methods such as requesting submission of identification documents at the time of a request. If all items necessary for identification prescribed by Recruit Holdings are fulfilled, Recruit Holdings will consider such request is from the requester itself and respond to the request, but even if such request is from third parties other than such requester who obtained personal information or identification documents of the requester, Recruit Holdings will not be responsible for damages incurred by the requester due to responding to such request unless Recruit Holdings is intentionally grossly negligent or in violation of the Consumer Contract Act by Recruit Holdings. Please be careful in handling your personal information.

8. Contact details regarding personal information

For inquiries regarding personal information, please fill out the inquiries form.

9. Use of special care-required personal information

If Recruit Holdings receives provision of special care-required personal information, Recruit Holdings will handle such special care-required personal information in accordance with this Privacy Policy. However, Recruit Holdings will use special care-required personal information only in the purpose that you have requested to use.

10. Use of Google Analytics

Recruit Holdings may use Google Analytics, which is provided by Google LLC, on Recruit Holdings’ official website to improve Recruit Holdings’ communications, public relations, and IR activities. In such case, Recruit Holdings will use only statistical information.

For explanations of Google Analytics Terms of Service and Privacy Policy, please see the following websites.

Google Analytics Terms of Service:
https://policies.google.com/terms?hl=en

Google Privacy Policy:
https://policies.google.com/privacy?hl=en

If you do not want Google to acquire log data such as IP addresses, please use the Google Analytics Opt-out Browser Add-on that is provided by Google.

Google Analytics Opt-out Browser Add-on:
https://tools.google.com/dlpage/gaoptout?hl=en

Please refer to the Privacy Policy of Recruit's Two Galleries regarding the operation of Recruit's Two Galleries.