Policy on protection of personal information

[1] Purpose of utilization and scope of collection

When we ask customers to provide personal information such as a name, an address, a telephone number, and an e-mail address, we will inform customers of the purpose of utilization, contact details for Inquiries, etc., in advance. We will collect customers’ personal information with appropriate and fair means within an appropriate scope.

[2] Acquisition of personal information

Upon acquiring personal information, we will officially announce the purpose of utilization in advance except the cases below.
<<1>> In the case where by notifying and officially announcing the purpose of utilization, the life, body, properties, and other rights of customers themselves or the third person may be harmed.
<<2>> In the case where by notifying and officially announcing the purpose of utilization, significant impact may be imposed on our rights, benefits, or business performance.
<<3>> In the case where cooperation is required for the business performance by a governmental institution, local government, and their delegates as specified by law, and by notifying and officially announcing the purpose of utilization, business performance may be obstructed.

[3] Utilization of personal information

<<1>> We will properly treat personal information collected from customers mainly within the scope of purposes below. We will sometimes use personal information beyond the scope of these purposes upon officially announcing the purpose of utilization:
 (1) correspondence to inquiries from customers;
 (2) Sending of merchandises, awards, and guidance (mail magazine and so on) related to a variety of services administrated by us.
 (3) A survey on utilization situation of a variety of services administrated by us.
 (4) Confirmation and checking operations of achievement (application, membership registration and so on) information performed among us, advertising companies, and advertising providers in order to distribute specific benefit (point and so on) to users regarding a variety of services administrated by us.

<<2>> However, we utilize personal information without the consent of customers in advance for purposes beyond the scope in the case where:
 (1) the information is necessary for protecting the life, body, properties, and other rights of people and to obtain agreement of the customers is difficult;
 (2) the information is necessary for improving public health or promoting healthy growth of pupils and to obtain agreement of the customers is difficult;
 (3) cooperation is required for the business performance of state institution, local government, and those commissioned by them specified by the law, and by waiting for the consent of customers, business performance may be obstructed; and
 (4) by obtaining the consent of customers, significant impact may be imposed on our rights, benefits, or business performance.

[4] Prohibition of provision and disclosure to the third person

<<1>> We will neither provide nor disclose personal information of customers to the third person without customers’ consent through terms of service separately specified for each service administrated by us. However, this shall not apply to the case where:
 (1) the information is necessary for protecting the life, body, properties, and other rights of people and to obtain agreement of the customers is difficult;
 (2) the information is necessary for improving public health and promoting healthy growth of pupils and to obtain agreement of the customers is difficult;
 (3) cooperation is required for the business performance of national institution, local government, and those commissioned by them specified by the law, and by waiting for the consent of customers, business performance may be obstructed;
 (4) by obtaining the consent of customers, significant impact may be imposed on our rights, benefits, or business performance;
 (5) it is notified or officially announced in advance that the purpose of utilization includes provision to the third person, and data item offered to the third person and means or method for offering to the third person will be stopped according to requests by customers; and
 (6) any other cases as specified by laws and regulations.

<<2>> However, the cases as follows are not applicable to the “third person” specified in the above:
 (1) a subcontractor to whom we entrust all or part of handling of personal information within a scope necessary for achieving the purpose of utilization;
 (2) to whom personal information is provided in association with continuation of business such as merger and transfer of operations; and
 (3) a particular person with whom personal information is shared. In this case, we will notify customers in advance on items to be shared: the purpose of sharing; items of sharing; an extent of the sharing user; the purpose of utilization of the user; and the name of a management representative of the personal information. Alternatively, we will place customers under a state where they can easily know the above.

[5] Supervision of subcontractors

In order to achieve the purpose of utilization consented by customers, we sometimes commission external enterprises to perform the task. Then, we require the subcontractor of the task to strictly manage personal information in the same level as ours when disclosing personal information of customers to execute upon concluding a non-disclosure agreement. We appropriately supervise them.

[6] To secure and improve information security

In order to appropriately treat personal information of customers, we will continuously secure and improve information security by preparing company rules and regulations and in-house management system, training employees, and taking appropriate measures related to prevention of an unauthorized access to personal information, loss, destruction, falsification, and leakage of personal information.

[7] Cookie

In our website, a page utilizing a technique called “Cookie” or similar technique is sometimes used. Cookie denotes a mechanism to store data to be transmitted from a web server to customers’ web browser. Basically Cookie information is not considered to be personal information because it cannot identify a particular individual alone. When Cookie information and personal information are used integrally, Cookie information is regarded as personal information as well and treated according to the personal information protection policy.

[8] Education and enlightenment

We educate and enlighten all executives and employees so that they understand importance of personal information protection and appropriately treat personal information of customers.

[9] Correspondence to disclosure and correction of personal information

<<1>> When customers desire to disclose, correct, suspend, and delete their own personal information, upon confirming that the customer contacted us is the person himself or herself to the best of the system’s ability, we will go through the procedure within a rational time period and scope. However, when we offer a system service in which customers can change, delete personal information by himself or by herself, we sometimes only inform how to go through arrangement and ask customers to perform arrangement for themselves.

<<2>> Despite the above prescriptions, when the following items hold, all of or part of the private information is not sometimes disclosed.
 (1) In the case where the life, body, properties, and other rights of people may be harmed.
 (2) Significant impact may be imposed on our appropriate business performance.
 (3) Laws are violated, and so on.

[10] General rule for using Personal Information Protection Law

In our company, only those authorized can fundamentally utilize the personal information within the scope of the purpose of duty.

[11] Items to be handled according to Personal Information Protection Law

We will take measures against leakage of personal information such as to take out or send out personal information from a predetermined utilization location in consideration of safety. We will make our employees observe the duty of confidentiality in work and after retirement.

[12] Continuous revision and improvement

We will observe laws and regulations on personal information protection to continuously review and improve how to approach personal information protection according to changes in social environment.

[13] Exemption

We are not liable to the policy of personal information protection and the standard and content of handling of personal information in the website of other companies and the like linked from the website administrated by us.

[14] Governing law

The policy of personal information protection is interpreted and applied according to Japanese laws.

[15] Jurisdiction

With regard to dispute on the policy of personal information protection, the Tokyo District Court is a court of jurisdiction of a first trial.

[16] Changes in policy of personal information protection and notification

Our policy of personal information protection is subject to change without notice in advance. In that case, we will notify the change on the page of our website. Changes come into effect at the time of being carried on the website.

[17] For inquiries on personal information

We will receive inquiries on personal information at the following:

10-11 Yayoicho, Itabashi-ku, Tokyo 173-0021 JAPAN
Telephone number: +81 3-3974-4601
Office for Inquiries

Established in April 1, 2012