PRIVACY
POLICY

The Company hereby establishes the following basic policy regarding the protection of personal information:

• (1)The Company shall appropriately acquire, use and provide personal information within the scope necessary for the performance of its business operations, and shall not handle personal information beyond the scope necessary to achieve the specific purposes of use. The Company shall take appropriate measures to ensure that personal information is not used for purposes other than those specified.
• (2)The Company shall comply with laws and regulations relating to the handling of personal information, including the Act on the Protection of Personal Information, as well as governmental guidelines and other applicable standards.
• (3)The Company shall take necessary measures to prevent unauthorized access, loss, or damage of personal information and shall implement appropriate corrective actions when an incident occurs.
• (4)The Company shall respond promptly and sincerely to complaints and inquiries regarding the handling of personal information.
• (5)The Company shall continuously review and improve its personal information protection management system to ensure the appropriate handling of personal information.

In the Privacy Policy, personal information shall mean “personal information” defined in paragraph 1 of Article 2 of the Act, i.e. the information regarding a living individual which can identify a specific individual by name, date of birth or other description contained in such information (including information which may be easily referred to other information and will thereby enable identification of a specific individual).

The Company shall use customers’ personal information for the following purposes:

• (1)provision and announcement with respect to the Company’s services;
• (2)responses to customer inquiries;
• (3)investigation and analysis with respect to the utilization status of the services, etc.;
• (4)improvement of the services and development of new functions and services, etc.;
• (5)operation and management of seminars and events, etc.;
• (6)recruitment for persons who apply to the Company’s recruitment process; or
• (7)other purposes related to the above purposes.

The Company may change the purpose of use of personal information to the extent that the purpose of use after the change is reasonably deemed duly related to the original purpose of use. When the purpose of use has been changed, the Company shall notify the customer of, or publicly announce the purpose of use after the change.

The Company shall not use personal information, without the consent of the relevant customers, beyond the scope necessary for the achievement of the purpose of use, unless permitted by the Act or other laws or regulations; provided, however, that this provision shall not apply if:

• (1)the use of personal information is based on laws and regulations;
• (2)the use of personal information is necessary for the protection of the life, body or property of an individual and it is difficult to obtain the consent of the relevant customers;
• (3)the use of personal information is specially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the relevant customers; or
• (4)the use of personal information is necessary to cooperate with a national or local government authority, or a party entrusted by either of them, in performing duties prescribed by laws and regulations, and obtaining the consent of the relevant customers is likely to impede the performance of such duties.

The Company shall acquire personal information by a proper means, and shall not acquire it by a deception or other wrongful means.

The Company shall sufficiently and appropriately supervise the Company’s employee to ensure the security control of personal information against the risk of loss, destruction, alteration or leakage. When the Company entrusts a third party with the handling of personal information in whole or in part, the Company shall sufficiently and appropriately supervise the third party to ensure the security control of personal information.

The Company shall not provide personal information to a third party without the prior consent of the relevant customers, unless the disclosure is permitted by the Act or other laws or regulations; provided, however, that the following cases shall not be regarded as the provision to a third party:

• (1)Cases where the Company entrusts a third party with the handling of personal information within the scope necessary for the achievement of the purpose of use;
• (2)Cases where personal information is provided as a result of the succession of business in a merger or otherwise; or
• (3)Cases where personal information is used jointly with others in accordance with the provisions of the Act.

In cases where the Company is requested by a customer to disclose the personal information under the Act, the Company shall, after confirming that the request is made by the principal, disclose the personal information to the customer without delay (in cases where the Company does not have such personal information, the Company shall notify the customer to that effect); provided, however, that this provision shall not apply to cases where the Company is not obliged to disclose such personal information under the Act or other laws or regulations.

If a customer requests the correction, addition, or deletion of personal information (hereinafter referred to as “correction, etc.”) on the grounds that the personal information is inaccurate, the Company shall, after confirming that the request is made by the customer, conduct the necessary investigation without delay within the scope necessary to achieve the purposes of use. Based on the results of the investigation, the Company shall make the necessary correction, etc., to the personal information and notify the customer of the outcome. (If the Company decides not to make any correction, etc., it shall notify the customer accordingly.) However, this shall not apply in cases where the Company is not obliged to make such corrections, etc., under the Act on the Protection of Personal Information or other applicable laws and regulations.

In cases where the Company is (i) requested by a customer to discontinue using or to erase the personal information under the Act on the ground that such personal information is being handled beyond the purpose of use publicly announced in advance or has been acquired by a deception or other wrongful means, or (ii) requested by a customer to discontinue providing the personal information under the Act on the ground that such personal information is provided to a third party without the customer’s consent, and where it is found that the request has a reason, the Company shall, after confirming that the request is made by the principal, discontinue the use of or erase the personal information, or discontinue the provision of the personal information, without delay and shall notify the customer to that effect; provided, however, that this provision shall not apply to cases in which the Company is not obliged to make such discontinuance of use or erasure, or discontinuance of provision, under the Act or other laws or regulations.

Cookies or similar technologies may be used in the Company’s service. Such technologies help the Company to recognize the status of use of the Company’s service, etc. and contribute improvement of the service. When a user intends to disable cookies, the user may disable cookies by changing the web browser’s settings. Please note that when cookies are disabled, a part of the service may be unavailable.

With respect to requests for disclosure, etc., comments, questions, complaints and other inquiries regarding the handling of personal information, please contact the following.

4F, Imon Kudankita Building,
1-12-3 Kudankita, Chiyoda-ku,
Tokyo 102-0073, Japan
Jorte Inc.
Administration Department, Legal Affairs
E-mail: privacy@jorte.com
(Office hours: 10:00 a.m. to 6:00 p.m., Monday through Friday, excluding national holidays.)

The Company shall endeavor to review timely the status of the operation regarding handling of personal information and to improve such operation continuously. The Company may amend this Privacy Policy as necessary.

Please refer to our web page for the name of the third party to whom the information is sent and the purpose of use of the information at the destination.
■External Services and Third Party Data Sharing
https://www.jorte.com/etc/ext_service/
■Jorte Terms of Service
https://www.jorte.com/etc/kiyaku/?select=en