1. Effective date: April 24, 2026

2. Overview 

This Employee and Contractor Privacy Policy (the “Privacy Policy”) contains the policies and procedures to be followed by Toho International, Inc., including its present or future affiliates and subsidiaries (“Toho,” the “Company,” “we,” “us,” or “our”) related to the collection and use of personal information of an applicant, an employee, a Company officer or director, or a contractor¹ (collectively referred to this in Privacy Policy as the “Personnel,” “you,” or “your”).   

Toho wants you to understand how and why we collect “Personal Information,” which includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.  Personnel should have no expectation of privacy when using technology provided by Toho or whenever accessing Toho technology resources or information. 

Toho is committed to protecting the privacy of all of our Personnel, and we take administrative, technical, and physical safeguards to protect your Personal Information from unauthorized access, misuse, accidental loss, or alteration. 

If you are a resident of California, please see the attached California Privacy Notice Addendum for a full list of the disclosures and rights available to you under California law.  If you a resident of the United Kingdom, Europe, or the EEA, please see our attached GDPR Privacy Notice Addendum.  These notices supplement this Privacy Policy.  

3. What Information Do We Collect? 

The following chart identifies the categories of Personal Information that we may collect or process and the specific reasons for which we process each category of Personal Information.  For more detailed information regarding why we process each category of Personal Information, please see the Purposes of Collection section, below.  

Please note that we may not collect all categories of Personal Information about each individual.  For example, if the collection of Personal Information relates to a specific benefit that is not generally available, we would only collect that Personal Information from the Personnel who are eligible for and enroll in the benefit.  Additionally, when we collect a category of Personal Information, we may not collect each specific example listed.  

Categories	Examples	Reasons for Collection
Identifiers and Categories listed under the California Customer Records Statute.	Name, postal address, internet protocol address or related unique identifiers, account name, email address, telephone number, social security number, driver’s license or state ID number, passport number, or other similar identifiers.	Administer the Employee Relationship; Comply with Legal Obligations; Facilitate Communications and Efficiency; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, Property, and Systems
Protected classification characteristics	Age (over 40), gender, ethnicity, race, sexual orientation, religious or philosophical beliefs.	Administer the Employee Relationship; Comply with Legal Obligations Facilitate Communications and Efficiency; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, Property, and Systems
Internet or other similar network activity.	Browsing history, search history, information on your interaction with a website, application, advertisement, or while otherwise using Toho systems.	Facilitate Communications and Efficiency; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, Property, and Systems
Geolocation data.	Physical location or movements.	Facilitate Communications and Efficiency; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, Property, and Systems
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information such as security camera footage.	Administer the Employee Relationship; Comply with Legal Obligations Facilitate Communications and Efficiency; Provide Benefits;  Ensure the Safety of Employees, Contractors, Facilities, Property, and Systems
Professional or employment-related information.	Current or past job history, resume information, current employment information, performance evaluations, wage and benefit information.	Administer the Employee Relationship; Comply with Legal Obligations; Ensure the Safety of Employees, Contractors, Facilities, Property, and Systems
Non-public education information	School records or transcripts	Administer employee/contractor relationship Comply with legal obligations Provide benefits Ensure the Safety of Employees, Contractors, Facilities, Property, and Systems
Sensitive Personal Information	Social Security, driver’s license, state identification card, or passport number; Account information sufficient to manage your internal account or submit payments to you, including account log-in, financial account, debit card, or credit card number in combination with any required security or access credentials.  Precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; or the contents of mail, email, and text messages where Toho is not the intended recipient of the communication.	Administer the Employee Relationship; Provide Benefits;  Ensure the Safety of Employees, Contractors, Facilities, Property, and Systems

The specific pieces of information that we collect about you may vary due to the nature of your position, role, and benefits. Service providers, such as recruiting firms, application processors, and background check providers, may collect information on our behalf to facilitate the employment relationship.

4. Purposes of Collection

1. (a) Administering the Employment/Contractor Relationship 

We keep and process Personal Information for traditional employment and contractor engagement purposes.  We use this information for management and administrative uses and only disclose it with others who have a need-to-know such information.  We keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, during the recruitment process, while you are working for us, and after your employment or contract has ended.  This includes using Personal Information to enable us to comply with any legal requirements associated with an employee or contractor relationship, to administer payroll, to provide you with benefits, ensure your safety, comply with an employment or service contract, and to demonstrate our commitment to equal employment opportunity and fair employment practices.   

2. (b) Compliance with Legal Obligations 

In certain situations, we may need to collect and process your Personal Information to comply with our legal obligations.  This may include: 

• Tracking demographic information to confirm compliance with equal opportunity and non-discrimination policies and requirements; 

• Processing information relating to your health, which could include reasons for absence and doctor’s reports and notes, in order to comply with our obligations under applicable employment and safety and health laws;  

• Verification of employment; 

• Maintenance of tax records and unemployment or disability insurance coverage; 

• Processing information regarding certifications and qualifications for your role or position; 

• Processing information regarding participation in employment related activities about which we are required to retain a record; and/or 

• Processing information relevant to any alleged violations of the law or Toho internal standards or in compliance with a subpoena or other valid legal or regulatory request.  

3. (c) Facilitate Communications and Efficiency  

Toho uses various tools and platforms that enable you to more easily communicate with other Personnel and to more efficiently access and disclose various types of work product.  Some tools may also allow Personnel to disclose information via social media or other channels, including information relating to job opportunities. 

These tools and platforms may collect and disclose contact information and company profile pictures; log certain preferences and actions; collect your geolocation; and create user profiles that allow Personnel and Toho to track their efficiency and performance.  We may also have access to communications sent using Toho systems and devices.  

4. (d) Provide Benefits  

We may offer a variety of benefits depending on your relationship with us. We, or our service providers, collect any information necessary to provide these benefits, as described in the chart above.  If Employees take advantage of other benefits, such as fitness-related benefits, we may also collect additional biometric and sensory information relating to these activities, as would be required to effectuate these benefits.  When you participate in certain benefits programs, we may also generate a log of your activity, track internet and other network activity, and develop a user profile to provide those programs to you in a manner tailored to your preferences.   

All benefits may not be available to all Personnel, and the Company will only collect Personal Information to provide a benefit if you are eligible for and enrolled in that benefit.  You should take care to read the specific terms applicable to any particular mobile application or benefits program to understand the specific pieces of information collected. 

5. (e) Ensure the Safety of Employees, Contractors, Facilities, Property, and Systems 

We collect various categories of Personal Information to ensure the safety of Personnel, facilities, property, and systems.  This information helps verify the identity of Personnel in specific facilities and ensure the security of facilities and Company property. This may include the collection of certain health, vaccination, or screening information when individuals enter our facilities.  

Additionally, we may process certain categories of Personal Information to ensure the safety and security of our electronic systems and devices.  This may include the automated monitoring of our systems for suspicious or fraudulent activity and other forms of illegal conduct.  It may also involve the automated or manual review of conduct that may be deemed suspicious or otherwise in violation of Toho policies or procedures. This monitoring is to ensure the safety and security of our systems and the confidential information that is entrusted to us.  

5. Updates to the Privacy Policy  

This Privacy Policy is subject to occasional revision, and if we make any material changes in the categories of information we collect or the reasons we collect that information, we will notify you by sending you an e-mail and/or by prominently posting notice of the changes.  This Privacy Policy will also be posted where TOHO houses other similar policies.  If you have questions regarding this Privacy Policy, please contact us by email: [email protected]. You can review or consult the Privacy Policy at any time.    

The Company may be subject to certain laws and regulations relating to privacy and information security in more than one jurisdiction in which Personnel reside.  If any term, covenant, condition, or provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid, void, or unenforceable, it is the intent of this Privacy Policy that the scope of the rights and obligations of the Privacy Policy be reduced only for the affected jurisdiction and only to the extent deemed necessary under the laws of the local jurisdiction to render the provision reasonable and enforceable and the remainder of the provisions of the Privacy Policy statement will in no way be affected, impaired, or invalidated as a result. 

6. Individual Rights Requests

If you are a resident of a jurisdiction that provides you with individual rights regarding your Personal Information, such as Canada, you may exercise those rights as described in this Policy and its relevant Addenda or by contacting us as described in Section 8, below.   

7. Information Stored in the United States

Please note Toho operates out of the United States and Japan. As such, any information provided to the Company may be transferred to and stored in the United States or Japan.  By providing your Personal Information to us, you consent to such transfers of your Personal Information.  

8. Contact Us with Questions 

If you have questions regarding this Privacy Policy, please contact us by email [email protected].