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Privacy Handling

October 15, 2012
Norihisa Katayama, Senior Vice President
Chief Information Security Officer
Net One Systems Co., Ltd.

1. Acquisition of Personal Information and Purposesof Utilization

We obtainand utilize personal information in compliance with the Personal Information Protection Act, theJapanese Industrial Standard“Personal informationprotection management systems -Requirements (JIS Q15001:2006),”and other applicable rules,and by employing appropriate means. The purposes of utilization of the personal information that we obtain and retain are as described below.

(1) Purposes of utilization of personal information obtainedin writing directly from the personidentifiable by such information

On each occasion, we clearly indicate certain matters such as thepurposes of utilization, in writing (including by using electronic or magnetic records)and in advance,to the person identifiable by the relevant personal information (hereinafter “you,” “your,” etc. as appropriate), except in cases falling under any of the following items:

  1. cases where your personal information is urgently required in order to protect the life, body, or property of an individual, orwhere theinformation is required on the same groundsand it is difficult to obtain your consent;
  2. cases where there is a possibilityof harmtoyour or a third party’s life, body, property, or other rights or interests;
  3. cases where there is a possibility of harmto our rights or legitimate interests;
  4. cases where there is a need to cooperate with anational government organizationor local government in its execution ofaffairs prescribed by laws and regulations, and there is a possibility that informing you of, or disclosing to you, the purposes of utilization, or obtaining your consent, would interfere with the execution of those affairs;
  5. cases where it can be recognized, judging from the circumstances surrounding the acquisition of personal information, that the purposesof utilization are clear;
  6. cases based on laws and regulations; or
  7. cases where your personal information is especially required for enhancement of public health or promotion of the sound fostering of children, and it is difficult to obtain your consent.

(2) The purposes of utilization of personal information obtained directly from youby means other than in writing or indirectlyfrom publicly available information,third parties, etc., and the purposesof utilization of personal information retained by us, are as follows.

  1. Customers’personal information:
    • Offering, sale, or provision of products, services, or support
    • Provision of information onourandour group companies’products, services, etc.
    • Provision of information on events, etc.(various seminars, exhibitions, etc.) held (hosted, co-hosted, or co-sponsored) by us or our group companies
    • User registration relating toservices, etc. provided by us or our group companies
    • Forcontact, business talks, meetings, etc. with the customer, and fortheperformance ofany contractexecuted with the customer
    • Handling of inquiries and requests from the customer
    • Operational management of training programs
    • Implementation of various questionnaire surveys
    ※For details on our group companies, visit(List of Net One Group Companies).
  2. Business partners’personal information:
    • For contact, business talks, and meetings with the business partner, and fortheperformance ofany contractexecuted with the business partner
    • Handling of inquiries and requestsfrom the business partner
  3. Shareholders’personal information:
    • Exercise of rights and performanceof obligations underthe Companies Act, etc.
    • Provision of various benefits
    • Implementation of various measures for shareholders with the aim of facilitatinga smooth relationship between them and the company
    • Management of shareholders in accordance withapplicablelaws and regulations
  4. Personal information of those who wish to join or have left the company:
    • Provision of information and noticesto job applicants, and for contact with them
    • Recruitment screening procedure
    • Statutory personnel and labor affairs (including those relating to benefit packages) concerningretirees
    • Provision of company informationto retirees,communication ofother necessary information such as that on social gatherings,and other forms of retiree management
  5. Other
    • Personal information obtained from publicly availableinformation (official gazettes, websites, commercially availablepublications and directories, etc.) orfrom third parties:
      Fortheprovision of information and implementation of various questionnaire surveys in relation to our andour group companies’products, services, events (various seminars, exhibitions, and other occasions), etc.
    • Personal information whose handling has been entrusted to us along with commissioned business operations:
      Fortheperformance ofany contractexecuted with the commissioning partyforcommissionedbusiness operations such as system development, consulting service, system support, and education and training
    • Recorded telephone conversations
      For ensuring the accuracy of the details of recorded telephone conversations, and for appropriate responses
    • Records of entrance to and exit from the facilities of our company, and recorded videos thereof
      For security management with the aim of preventing crimes, disasters, etc.
    • Purposes of utilization that you have been informed of and have agreed to in advance

Our businesspursuitfor which personal information is utilized is mainly as follows:

Network integration business (network-relatedconsulting service, network design and management, installation of and construction workfor network facilities, network equipment sale, network computing service, operation support service, and education service)
In the event where it is necessary for us to utilize your personal information beyond the purpose of utilization that you have been informed ofbeforehand, we will again seek your consent to the extendedpurpose of utilization and other relevant matters, except in cases that may be treated as exceptions pursuant to the Personal Information Protection Act, etc.
In addition, if personal information is provided to us by a minor under the age of 16 or by a person who is not capable of appreciating his/hersituation, the consent of that minor’s/person’s statutory agent, etc. is required.

2. Entrustment of Handling of Personal Information and Its Joint Utilization

(1) Entrustment of handling

We may outsource all or part of our business operations to a contractor and entrust our handling of personal information to the same contractorto the extent necessary for accomplishing the intended purpose of utilization of theinformation. In such case, we select a contractor that meets the criteria setout by us, and conclude a contract concerning the handling of personal information and exercise appropriate control and supervision in order to ensure that personal information is safely managed.

(2) Joint utilization

We may utilize the personal information of customers, etc. (such as name, company name, department name, telephone number, fax number, and email address) jointly with any of our groupcompanies, if the information is required for our joint implementation of a business activity with the group company. In such case, the customers, etc. concerned will be notified of the purpose of utilization of theinformation in advance. Furthermore,we will properly managesuch informationin accordance with an agreement executed between us and the relevant group company in relation to joint utilization of personal information in order to ensure safemanagement.

3. Provision and Disclosure of Personal Information to Third Parties

In principle, without obtaining your consent, we will not provide or disclose to any third party your personal information that we have obtained, except in cases falling under any of the items below; and whenwe provide or disclose your personal informationto a third party upon having obtained your consent, we will implement appropriate measures for protection of theinformation in relationto the party to which the information is provided or disclosed:

  1. cases based on laws and regulations;
  2. cases where the provisionor disclosure is required in order to protect the life, body, or property of an individual, and it is difficult to obtain your consent;
  3. cases where the provision or disclosure is especially required for enhancement of public health or promotion of the sound fostering of children, and it is difficult to obtain your consent;
  4. cases where there is a need to cooperate with a national government organizationor local government, or a party entrustedthereby, in its execution ofaffairs prescribed by laws and regulations, and there is a possibility that obtaining your consent would interfere with the execution of those affairs;
  5. cases where the personal information concerned is obtained from a providing party that has already obtained your consent to the party’s provision of the information as well as to the party’s re-provision of theinformation; or
  6. cases where you have been notified in advance, through public information availabletoofficers and shareholders,aboutcertain matters includingpotentialprovision of personal information to third parties.

Procedure for accepting your request for disclosure, etc. of personal information

  1. Where to submit a requestfor disclosure, etc.
    The contact point for receiving requests is the Personal Information Contact Desk, which receives a “Request Form for Disclosure, etc.”from you.
  2. <Personal Information Contact Desk>
    Personal Information Contact Desk,Net One Systems Co., Ltd.
    Tennoz First Tower, 2-2-4 Higashi Shinagawa, Shinagawa-ku, Tokyo, 140-8621,Japan
  3. Format of the document to be submitted when requesting disclosure, etc.
    Please fill out a “Request Form for Disclosure, etc.”and send it to the Personal Information Contact Deskby mail.
    Please bear in mind that, after receiving a request, we may collect a fee from you depending on the details of your request.
  4. After confirming that the person requesting disclosure, etc. is you or your agent, we proceed with the disclosure procedure and subsequently contact you.

4. Cookies and Web Beacons onOur Websites

  1. Although we may use cookies and web beacons to enhance the functionality of our websites and to improve our services and operations,suchcookies and web beacons do not have a function to identify specific individuals.
  2. For the purpose of analyzingtrends in access to our websites or resolvingany problems withour websitesif they occur, we may record the IP address and domain information of each user accessing our websites. However, no individual canbe identified from these types of data.
  • A cookie is a function to store the user’s information within the browser used so as to save the user from having to input data and to display optimized content for the user.
    By changing the settings of your browser, you can refuse to accepta cookie or can display a warning when it is accepted. However, refusal to accept a cookiemay result in some limitations; for instance, all or part of the services on the website may not be availablefor use.
  • web beacon is a technique used to monitorthe access ofeach user’scomputer and obtain such statistical data asthe usagerate of a specific web page. It is sometimes called a clear GIF.

5. The name of the “accredited personal information protection organization”ofwhich we are a member, and the contact point for complaint resolutionrequest

【※The contact point below is not for inquiries regarding our products or services.]】

Organization name: JIPDEC
Submit arequestto: Personal Information Protection Complaint Consultation Office
Address: Roppongi First Building, 1-9-9 Roppongi, Minato-ku Tokyo, 106-0032, Japan
Tel.: 03-5860-7565, 0120-700-779
Opening hours: 9:30-12:00 and13:00-16:30on weekdays

PrivacyMark System

We have been certified by JIPDEC as a “PrivacyMark Entity”handlingpersonal informationappropriately.

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