■ Concerning the Handling of Private Information

Privacy Policy

Clover Trading Co., Ltd. (hereinafter, “COMPANY”) institutes this Privacy Policy regarding the handling of private information and hereby declares that, along with abiding by this Privacy Policy, it shall securely and appropriately handle all private information including first and foremost that of our customers.
This Privacy Policy applies to all private information collected and used by COMPANY and constitutes COMPANY’s fundamental policy on private information.

1. 1. Compliance with Laws and Regulations Regarding the Protection of Private Information

   COMPANY shall comply with laws and other regulations regarding the protection of private information and shall handle any private information appropriately.

2. 2. Acquisition of Private Information

   When acquiring private information, COMPANY shall work to make the purpose of using such private information transparent. COMPANY shall also acquire private information through fair and lawful means.

3. 3. Use of Private Information

   COMPANY shall use private information it has obtained only for the purposes indicated upon acquisition thereof or to an extent reasonably relevant thereto, only when required for the conducting of COMPANY’s operations. When using private information jointly with a third party or delegating the handling of private information to a third party, COMPANY shall oversee the other party jointly using the information or any third parties to ensure the appropriate usage of private information.

4. 4. Provision of Private Information to Third Parties

   Unless otherwise stipulated by law, COMPANY shall not provide private information to any third party without the prior consent of the owner thereof.

5. 5. Management of Private Information

   Along with managing private information securely, COMPANY shall maintain the accuracy and recency of private information and take necessary and appropriate information security safeguards to prevent the loss, tampering, divulgence, or otherwise thereof.

6. 6. Disclosure, Correction, Suspension of Use, and Deletion of Private Information

   COMPANY acknowledges that the owner of private information bears the right to demand the disclosure, correction, suspension of use, deletion, or otherwise thereof, and COMPANY shall institute a Private Information Service Desk and respond promptly pursuant to the law when such requests are made.

7. 7. Organization & Framework

   In addition to administering appropriate management with respect to private information used for business purposes, COMPANY shall also build a framework for achieving the appropriate handling of private information for business.

8. 8. Development and Administration of a Compliance Program for the Protection of Private Information

   In order to enforce this Privacy Policy, COMPANY shall institute a compliance program for the protection of private information and shall constantly maintain the program in an optimal state by making continuous improvements as well as by familiarizing all employees with the program through workshops and training.

Clover Trading Co., Ltd.