Personal Information Protection Policy

Nippon Information and Communication Corporation (hereinafter referred to as “NI+C”) believes that protection of customers’ personal information is the basis for NI+C’s work and a social responsibility, and we stipulate a personal information protection policy as stated below and will strive to make the policy known and thoroughly complied with by each of our board members and employees.

1. Collection, use, provision, and deposit of personal information
   1. In the event that NI+C will directly collect personal information, it will clarify the purposes of use for the customer and collect the information after obtaining agreement from the customer. Personal information that is collected will be limited to the scope of use and handled appropriately.
   2. In the event that personal information that is collected will be provided to a third party within a scope that is in accordance with the purposes, the purposes of use will be clarified, and appropriate handling will be conducted after obtaining clear agreement from the customer.
   3. In the event that personal information that is collected will be given (deposited) to a third party for a reason such as smooth promotion of work, NI+C will select a party that has sufficient personal information protection standards, strive to ensure compliance with protection standards by concluding an agreement, and conduct appropriate handling.
2. Prevention of risks for personal information, and correction
   NI+C will strictly manage customers’ personal information and conduct the necessary and appropriate prevention and corrective measures against risks such as unauthorized access, loss, destruction, manipulation, and leaks.
3. Compliance with laws and ordinances related to personal information and other standards
   For handling personal information, NI+C will comply with laws related to protection of personal information, the Telecommunications Business Act, other laws and ordinances related to protection of personal information, and guidelines, and will strive to protect personal information.
4. System for protection and management of personal information, and continuous improvement of mechanisms
   At NI+C, we will conduct continuous improvement for systems and mechanisms for management related to personal information protection.

Established on April 1, 2005
Nippon Information and Communication Corporation
Yujiro Hirose, President and CEO

About Handling of Customers’ Personal Information

In relation to handling of customers’ personal information (hereinafter referred to as “Customers’ Personal Information”), NI+C will conduct handling under the policy below, based on the “Personal Information Protection Policy.”

1. Methods of obtaining Customers’ Personal Information
   NI+C will appropriately obtain customers’ personal information by word of mouth, documents, electromagnetic records, and electromagnetic records as entered into e-mail or a Web screen, recordings, videos, or other methods (in addition to direct acquisition from customers, including cases in which NI+C indirectly obtains information from a party other than a customer).
   Please note that when NI+C conduct handling by a telephone call with a customer, we may record the conversation in order to accurately ascertain the content of the order, opinion, or request and to improve future services.


2. About handling of Customers’ Personal Information
   1. Purposes of use of Customers’ Personal Information at NI+C
      The purposes of use of Customers’ Personal Information that is possessed by NI+C are as stated below.
      1. For sending products and various documents such as invoices, conducting related after-sales services, and providing information related to new products and services in provision of telecommunications services, selling computers and software, developing various solutions and systems, and providing system operation services
      2. For purchasing goods, consignment of work, and conducting transactions based on contract relationships for financial transactions for conducting ordinary company operation
      3. For delivering e-mail magazines, providing guidance about seminars and forums, and making information publicly available through things such as handling press coverage
      4. For managing visitors and the purposes of those visits, people who accessed NI+C’s servers, and the purposes of such access, in order to ensure security
      Whenever NI+C receive a Customer’s Personal Information that is stated in a document directly from a customer, we will clearly indicate the purposes of use.
      In addition, this will not apply in cases that fall under Article 16.3 of the Act on the Protection of Personal Information.
      　
   2. About provision of Customers’ Personal Information to third parties
      NI+C will not, without obtaining the customer’s agreement, provide to third parties the Customer’s Personal Information that NI+C receives from the customer, except in cases based on Article 23.1 or Article 23.5 of the Act on the Protection of Personal Information.
      　
   3. About joint use of Customers’ Personal Information
      There is a possibility that NI+C will jointly use Customers’ Personal Information with a third party, based on Article 23.5.3 of the Act on the Protection of Personal Information. In such a case, NI+C will publicly announce in advance, on the homepage, the matters below.
      
      (1)The fact that joint use will be conducted
      (2)The matters of personal data that will be jointly used
      (3)The scope of the parties that will conduct joint use
      (4) The purposes of use of the parties that will conduct joint use
      (5)The names or appellations of the parties that have responsibility for managing the relevant personal data 　
   　　　　　　　　
   4. In the event that, after making a public announcement on the homepage under section III, item (4) or item (5) of section III will be changed, NI+C will make that fact public on the homepage in advance.
   
   
   5. About procedures for disclosure of possessed Customers’ Personal Information Excluding some things, NI+C will respond to requests for disclosure, correction, or suspension of use of Customers’ Personal Information that NI+C receives.
      1. Documents that are necessary for requesting disclosure
         If you wish to request disclosure, please contact the Office for Handling Customers’ Personal Information by telephone or e-mail. After that, NI+C will send you the necessary form, so please attach the necessary document and then submit the form by sending it by postal mail to the Office for Handling Customers’ Personal Information.
         • 　“Written Request for Disclosure of Personal Information”
           　*A service charge of JPY 1,000 (including consumption tax) will be charged separately.
         • 　“Written Request for Correction of Personal Information”
         • 　“Written Request for Suspension of Use or Elimination of Personal Information”
         • 　“Written Request for Suspension of Provision of Personal Information to Third Parties”
         • 　Attached document: “Public Certificate by Which the Individual can be Identified”
      2. Place to send requests
         Office for Handling Customers’ Personal Information
         Nippon Information and Communication Corporation
         15F, St. Luke’s Garden Tower, 8-1 Akashi-cho, Chuo-ku, Tokyo, 104-0044
         

         Telephone number：	03-6278-1115
         Hours for accepting requests：	Monday–Friday,9:00-17:30 (excluding end-of-year and New Year holidays, public holidays, and holidays separately stipulated by the Company)
         E-mail：	voice@NiandC.co.jp

         *About handling of Customers’ Personal Information that is obtained in relation to a request for disclosure
         The purposes of use of Customers’ Personal Information that NI+C receives through a request for disclosure will be handled only within the scope that is necessary for the request for disclosure.
      
      
   6. NI+C’s office for consultations related to Customers’ Personal Information
      For consultations related to NI+C’s handling of Customers’ Personal Information, please make a proposal by telephone, letter, or e-mail to the Office for Handling Customers’ Personal Information in item (ii) of section V above. Please understand that we cannot accept proposals made by visits to NI+C.
3. About compliance with laws
   When handling Customers’ Personal Information, NI+C will comply with the “Act on the Protection of Personal Information” and related laws and ordinances and obey guidelines by supervising ministries and industry guidelines.
   　
4. About safety management measures
   For handling of Customers’ Personal Information, NI+C will appropriately take organizational safety management measures, human safety management measures, physical safety management measures, and technical safety management measures.
   1. Organizational safety management measures
      NI+C are building a management system for things such as the people responsible for management in committees and each organization, preparing internal provisions, creating statements such as management ledgers and process management tables, and building an organizational management system for further continuous improvement.
      　
   2. Human safety management measures
      NI+C will make all employees who handle Customers’ Personal Information, irrespective of whether they are board members, employees, or partner employees, thoroughly knowledgeable and aware of the importance of protecting Customers’ Personal Information, conclude nondisclosure agreements, and conduct the necessary audits and supervision and ensure their effectiveness.
      　
   3. Physical safety management measures
      NI+C will manage entry and exit to and from buildings and floors where Customers’ Personal Information is handled, prevent theft, take measures against damage of Customers’ Personal Information due to fire or lightning strikes, and take various measures such as locks when systems or documents are taken outside, transferred, or stored.
      　
   4. Technical safety management measures
      NI+C will conduct access management such as authentication, authority management, control, and records when personal data is accessed, take measures against fraudulent software and measures against viruses for systems, take measures through things such as encryption and clarification of responsibility at times of transfer, transmission, and receipt, and take technical management measures such as monitoring of information systems.
   
   
5. About continuous improvement of the management system
   NI+C will regularly, continuously, and flexibly reconsider the management system and provisions, constantly improve the management system so that it will be timely and appropriate in accordance with changes of technology and the legal system, and actively take initiatives to protect Customers’ Personal Information.


6. About anonymous processed information
   There is a possibility that NI+C will create anonymous processed information based on Customers’ Personal Information and provide it to third parties. In such a case, NI+C will publicly announce in advance, on the homepage, the matters below.
   
   (1) The matters of information related to individuals that will be included in the anonymous processed information created by NI+C
   (2) Matters of information related to individuals that will be included in the anonymous processed information that will be provided to third parties
   (3) The method of providing anonymous processed information to third parties
   (4) The content of the safety management measures that are being taken
   
   NI+C will take the safety management measures of number 4 above for handling of anonymous processed information. In addition, NI+C will conduct the necessary and appropriate supervision for employees and consigned parties (including re-consigned parties) that handle anonymous processed information.

Protection Policy for Specific Personal Information

NI+C will formulate this policy in order to take initiatives as an organization concerning appropriate handling of specific personal information.

1. Name of the company
   Nippon Information and Communication Corporation


2. Compliance with related laws, ordinances, and guidelines
   NI+C will comply with related laws and ordinances concerning handling of specific personal information, guidelines stipulated by the national government, and other standards, and will appropriately handle specific personal information.


3. Matters related to safety management measures
   NI+C will establish an optimal system in order to conduct appropriate management for specific personal information, comply with the prescribed regulations for use, storage, provision, and deletion or disposal of specific personal information, and take safety management measures in order to conduct appropriate handling.


4. Office for questions
   Please contact the office stated below with questions or complaints related to the handling of specific personal information at NI+C.
   
   Office for Handling Customers’ Personal Information
   15F, St. Luke’s Garden Tower, 8-1 Akashi-cho, Chuo-ku, Tokyo, 104-0044
   

   Telephone number：	03-6278-1115
   Hours for accepting questions：	Monday–Friday,9:00–17:30 (excluding end-of-year and New Year holidays, public holidays, and holidays separately stipulated by NI+C)
   E-mail：	voice@NiandC.co.jp




Established on October 15, 2015
Nippon Information and Communication Corporation
Yujiro Hirose, President and CEO

About Handling of Clients’ Specific Personal Information

In relation to handling of clients’ personal numbers and specific personal information (hereinafter, clients’ specific personal information is referred to as “Clients’ Specific Personal Information,” and that information and clients’ personal numbers are collectively referred to as “Clients’ Specific Personal Information, etc.”) NI+C will conduct handling according to the policy below, based on the “Protection Policy for Specific Personal Information.”

1. About handling of Clients’ Specific Personal Information, etc.
   1. Purposes of use of Clients’ Specific Personal Information, etc. at NI+C
      The purposes of use of Clients’ Specific Personal Information, etc. that NI+C possesses are as stated in the scope of the clerical work below.
      1. Preparation of payment records for compensation, fees, contract fees, and cash prizes, or completing procedures related thereto
      2. Preparation of payment records for real estate rental fees etc., or completing procedures related thereto
      3. Preparation of payment records for consideration of the transfer of real estate etc., or completing procedures related thereto
      4. Preparation of payment records for brokerage fees for selling, buying, or renting real estate etc., or completing procedures related thereto
      Whenever NI+C will receive Clients’ Specific Personal Information, etc. that is stated in a document directly from a client, except in cases that fall under one of the items of Article 18.4 of the Act on the Protection of Personal Information, we will clearly indicate the purposes of use.
      Provided, however, that this will not apply in cases that fall under Article 16.3.1 or Article 16.3.2 of the Act on the Protection of Personal Information, which will be replaced under Article 30.3 of the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter referred to as the “Numbers Act”).
   2. About provision of Clients’ Specific Personal Information to third parties
      NI+C will not provide Clients’ Specific Personal Information to third parties.
      Provided, however, that in a case stipulated in one of the items of Article 19 of the Numbers Act, NI+C may provide the necessary specific personal information to a related third party or receive provision of the necessary specific personal information from a related third party, without obtaining the relevant person’s agreement in advance.
   3. About clients’ personal information related to joint use
      NI+C will not jointly use with a specific party the Clients’ Specific Personal Information that has been received from clients.
   4. About procedures for disclosure of possessed Clients’ Specific Personal Information, etc.
      We will respond to requests for disclosure, correction, or suspension of use of Clients’ Specific Personal Information, etc. that NI+C received.
      1. Documents that are necessary for requesting disclosure
         If you request disclosure, please contact the Office for Handling Customers’ Personal Information by telephone or e-mail.
         After that, NI+C will send you the necessary form, so please attach the necessary document and then submit the form by sending it by postal mail to the Office for Handling Customers’ Personal Information.
         • 　“Written Request for Disclosure of Specific Personal Information”
           　*A service charge of JPY 1,000 (including consumption tax) will be charged separately.In a case of sending it by postal mail, please send it by registered mail.
         • 　“Written Request for Correction of Specific Personal Information”
         • 　“Written Request for Suspension of Use or Elimination of Specific Personal Information”
         • 　“Written Request for Suspension of Provision of Specific Personal Information to Third Parties”
         • 　Exhibit: “About a Public Certificate by Which the Individual can be Identified”
      2. Place to send requests
         Office for Handling Customers’ Personal Information
         Nippon Information and Communication Corporation
         15F, St. Luke’s Garden Tower, 8-1 Akashi-cho, Chuo-ku, Tokyo, 104-0044
         

         Telephone number：	03-6278-1115
         Hours for accepting requests：	Monday–Friday,9:00–17:30 (excluding end-of-year and New Year holidays, public holidays, and holidays separately stipulated by NI+C)
         E-mail：	voice@NiandC.co.jp

         *About handling of Customers’ Personal Information that is obtained in relation to a request for disclosure
         The purposes of use of Customers’ Personal Information that NI+C receives through a request for disclosure will be handled only within the scope that is necessary for the request for disclosure.
      
      
   5. For consultations related to NI+C’s handling of Clients’ Specific Personal Information, etc., please make a proposal by telephone, letter, or e-mail to the Office for Handling Customers’ Personal Information in item (ii) of section IV above.
      Please understand that we cannot accept proposals made by visits to NI+C.
2. About compliance with laws
   For handling of Clients’ Specific Personal Information, etc., NI+C will comply with the “Act on the Protection of Personal Information,” the “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures,” and related laws and ordinances, and obey guidelines by supervising ministries and industry guidelines.
   　
3. About safety management measures
   For handling of Clients’ Specific Personal Information, etc., NI+C will conduct appropriate organizational safety management measures, human safety management measures, physical safety management measures, and technical safety management measures.
   1. Organizational safety management measures
      NI+C are building a management system for things such as the people responsible for management in committees and each organization, preparing internal provisions, creating statements such as management ledgers and process management tables, and building an organizational management system for further continuous improvement.
      　
   2. Human safety management measures
      NI+C will make all employees who handle Clients’ Specific Personal Information, etc., irrespective of whether they are board members, employees, or temporary employees, thoroughly knowledgeable and aware of the importance of protecting Clients’ Specific Personal Information, etc., conclude nondisclosure agreements, and conduct the necessary audits and supervision and ensure their effectiveness.
      　
   3. Physical safety management measures
      NI+C will manage entry and exit to and from buildings and floors where Clients’ Specific Personal Information, etc. is handled, prevent theft, take measures against damage of Clients’ Specific Personal Information, etc. due to fire or lightning strikes, and take various measures such as locks when systems or documents are taken outside, transferred, or stored.
      　
   4. Technical safety management measures
      NI+C will conduct access management such as authentication, authority management, control, and records when personal data will be accessed, take measures against fraudulent software and measures against viruses for systems, take measures through things such as encryption and clarification of responsibility at times of transfer, transmission, and receipt, and take technical management measures such as monitoring of information systems.
   
   
4. About continuous improvement of the management system
   NI+C will regularly, continuously, and flexibly reconsider the management system and provisions, constantly improve the management system so that it will be timely and appropriate in accordance with changes of technology and the legal system, and actively take initiatives to protect Clients’ Specific Personal Information, etc.