Company ○○○○ (the “Company”) shall observe the applicable laws, ordinances, and other regulations relating to the protection of personal information in order to properly manage the personal information furnished to it by its customers. The Company shall also establish voluntary management rules and systems, and define its personal information protection policy as follows, which it shall adhere to consistently.

1. Collection of personal information

The Company shall collect personal information by fair and lawful means. While it shall never obtain personal information by unauthorized means, it shall ensure that it obtains the consent of the principal who is the source of personal information (the “Principal”) for the purpose of use of the personal information, etc. and announces necessary information on the Company’s Web page or through direct mail, leaflets, advertisements, or similar means (“Media for Announcements”). If it collects personal information of customers who are 15 or younger, it shall obtain their parental consent.

2. Use of personal information

The Company shall only use personal information after obtaining the consent of the Principal or within the purpose of collecting the personal information, as expressly specified in the Media for Announcements and to the extent necessary for the conduct of its business operations solely by the persons who are authorized to carry out specific operations. When it carries out statistical analysis of personal information, it shall exclude the personal identifying information (name, address, telephone number, etc.) to process the personal information.

3. The Company shall not disclose or provide the personal information obtained by it to any third party, except in the following cases:

  1. The Principal has consented to the disclosure or provision of his or her personal information.
  2. It is a requirement of laws or an order, etc. of a competent public authority to disclose or provide the personal information.
  3. It is determined by the Company that disclosure or provision is necessary for the prevention of the occurrence of material damage to the human life, body, health, property, etc. of the Principal or the public.
  4. The Company entrusts the handling of personal information to a subcontractor, who has concluded a confidentiality agreement relating to non-disclosure of personal information with the Company, to the extent necessary for achieving the entrusted operations.
  5. The Company discloses or provides the personal information to its agents, corporate lawyers, certified public accountants or audit corporations.
  6. The Company discloses or provides the personal information to its agents, corporate lawyers, certified public accountants or audit corporations.

4. Safety management of personal information

The Company shall strictly manage personal information furnished to it according to the management rules prescribed by it and shall take action to prevent the loss, destruction, unauthorized modification, leakage, etc. of personal information. The Company shall apply encryption using the Secure Socket Layer (SSL) protocol or similar security techniques to prepare for illegal access by third parties to ensure safety.

5. Request relating to personal information

If the Principal requests disclosure, modification, deletion, termination of use, etc. of his or her own personal information (“Disclosure, etc.”), the Company shall, within a reasonable period of time, comply in accordance with the relevant laws and regulations and the Company’s management rules upon confirmation of the identity of the Principal making the request. Please note that deletion, termination of use, etc. of personal information as requested may result in limited use of services or loss of membership qualification with respect to services. Fees will be charged to process a request for Disclosure, etc.

6. Contact Information for inquiries about personal information

Please contact directly the person in charge as specified in the Media for Announcements for any request or inquiry about the handling of personal information. If the person in charge is not known, you may also contact the Customer Service Center described below, in which case please note that it will take longer to process your request because you will be referred to the person in charge or your request will be transferred to the person in charge.

7. Personal information on the Internet

The Company’s website may contain links to the websites of other companies with which the Company does not share any personal information. Please note that the Company shall take no responsibility for the protection of personal information on such websites.

8. Continuous improvement of the Company’s compliance program

The Company shall improve its compliance program through implementation of regular internal audits to maintain its compliance status in good standing.

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