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Personal Information Protection Policy
 
SAXA Holdings, Inc. (hereafter "the Company"), endeavors to contribute to the development of society through the development of IT network equipment and systems, as well as appropriate business administration of its subsidiaries, which are mainly engaged in the manufacture and sales of such products.
1. Under the recognition that the information that can identify a living individual (hereafter "Personal information"), especially customers' private information, must be properly protected as an important social corporate responsibility in executing our business, the Company pays detailed attention to, and expends the utmost effort on, protecting and managing such personal information.
The Company observes the stipulations of the Personal Information Protection Law and relevant guidelines, and addresses educational activities to stimulate all the officers and employees (including part-time workers and temporary dispatched workers) to understand the importance and master the proper handling of such personal information.
2. The Company prepares and follows the Compliance Program for managing personal information protection and establishes a dedicated management system. At the same time, the Company places persons responsible for handling customers' personal information in each relevant department and strives to ensure the appropriate handling of personal information.
3. The Company uses personal information only to achieve the purposes that will be detailed for each customer when such personal information is collected. When personal information is entrusted by any other entities such as another company, the Company will properly handle the personal information within the scope of an agreement in accordance with the contractual provisions concluded with said entrusting entities.
4. If the Company requests that customers supply personal information, it informs them of the purpose for the use of such information, the scope of third parties to whom the Company intends to supply such information and the consultation desk of the Company in charge of the subject, in principle.
5. To ensure the correctness and safety of personal information, the Company strives to prevent any problems related to personal information, such as incorrect access to its Website and the loss, destruction, falsification or leakage of information by implementing effective technical measures.
6. The Company will never provide customer personal information to a third party without first obtaining consent from the customer, except when required by law with a reasonable cause.
7. In case of the supply or entrusting of customer information to a third party, except under special circumstances, the Company strives to prevent leakage or redistribution from such third party by entering into a stringent, compulsory agreement with said third party.
8. When a customer makes a request to refer to, correct or delete his or her own personal information, or seeks to prevent the use or provision of such information, the Company responds to such requests within a reasonable period of time. In such a case, please consult with the staff in charge of the Personal Information Protection Consultation Desk or a Company salesperson near you.
9. The Company endeavors to continuously review, evaluate and improve its entire compliance program including the Personal Information Protection Policy.
Compliance Program:
Overall management system that includes policies, organizations, plans, execution, audits and review thereof concerning the protection of personal information.
 
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Publication under the Personal Information Protection Law
 
The Company publishes the following guidelines in compliance with the Law Concerning Protection of Personal Information (hereafter "the Personal Information Protection Law").

Publication of the Purpose for Use about Personal Information
The Company at each use shall clarify the purpose for use of the collected personal information when using said information to achieve the following objectives.
(1) To send materials to persons who have requested documents, etc., on products and services of the Company;
(2) To send products to customers who have implemented the Company's products;
(3) To supply the Company's service to customers who utilize the service;
(4) To verify billing and payment to customers who have used any of the Company's products or services;
(5) To send notices and/or guides related to the maintenance service of the Company's products and/or services to customers who are using them;
(6) To verify applications for events/seminars related to the Company's products and send tickets;
(7) To contact the persons who have applied for or visited events/seminars related to the Company's products, such as product information;
(8) To send a reward to customers who have cooperated in responding to a questionnaire, etc.;
(9) To perform duties entrusted by any other entities;
(10) To send necessary materials to and make contact with job candidates who apply for a job with the Company;
(11) To use in the management of workers who engage in the Company's operations and make various communications incidental to such personnel management.
"Personal Information Possessed by the Company" to Be Kept in a "Manner Easily Accessible by the Subjected Individual"
Personal information possessed by the Company and the purpose for its use thereof is as follows:
Category of the personal information in our possession Outline of the personal information in our possession Purpose for use
Customer information regarding the Company's products and/or services Personal information such as name, address, phone number, etc., supplied by customers regarding the use of the Company's products/services, as well as information regarding the product/service being used Sending of the Company's products and/or materials
Supply of the Company's services
Verification of billing and/or payment
Communications regarding the supply of maintenance service
Communication of information on the Company's products or other
Information regarding workers who are engaged in the Company's operations Attribute information on workers for the Company's operations such as name, date of birth, gender, address and contact, as well as other information necessary for personnel management Management of workers for the Company's operations
Communications incidental to the personnel management of workers for the Company's operations
Personal information other than the above categories will not be possessed by the Company for more than six months and will not be treated as "personal information possessed by the Company."
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Procedures for Handling a "Request for Disclosure, etc." If an individual or his/her proxy wishes to refer to the personal information in our possession or to correct or delete such information, the Company handles such requests through the procedures described below.
 
1.  Where to Submit an Application for a "Request for Disclosure, etc."
For a request for disclosure, etc., please send the prescribed application to the address below, together with the necessary documents.
Please note "Documents for Request for Disclosure, etc., Herein" on the envelope in red ink.
Personal Information Protection Consultation Desk,

SAXA Holdings, Inc.
2-3, Shimomeguro 2-chome, Meguro-ku, Tokyo 153-8923
Phone: 03-3493-5113
 
2.  Document (Formats) to Be Submitted with a "Request for Disclosure, etc."
Please download the "Personal Information Inquiry Sheet." Enter all the necessary columns and mail together with the documents for identifying the individual.
"Personal Information Inquiry Sheet" (Click and download)
Evidence of identification documents
[If the "Request for Disclosure, etc.," in question is for personal information used in an individual's business]
A document proving that the individual belongs to said corporation (e.g., enrollment certificate)
[If the "Request for Disclosure, etc.," in question is for private information such as a home address]
Any one of the following documents can verify an individual:
  1) One photocopy of a valid driver's license
  2) One photocopy of a valid passport
  3) One photocopy of the Basic Register of Resident Card
  4) One photocopy of the Health Insurance ID Card
  5) A duplicate of the family register or of an abstract of the family register (certified original within three months from the date of execution by the municipal government )
  6) A copy of a resident register (certified original within three months from the date of execution by the municipal government)
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3.  "Request for Disclosure, etc.," Submitted by Proxies
If an individual who makes a "Request for Disclosure, etc.," is a legal guardian of a minor or of a ward who is of age or a proxy regarding the submission of the "Request for Disclosure, etc.," please mail the following documents or come to the Company directly with them, in addition to providing the documents listed in the preceding paragraph.
[For persons with parental authority]
  (1) Application prescribed by the Company
  (2) A photocopy of the family register or of the Health Insurance ID Card in which dependent family members are entered
[For legal guardians other than those with parental authority]
  (1) Application prescribed by the Company
  (2) A public certificate that indicates the relationship proving the legal guardian is entitled to represent the individual
  (3) A document to verify the identity of the legal guardian
(One photocopy of a valid driver's license or a valid passport)
[For proxies entrusted by individuals]
  (1) Power of attorney prescribed by the Company
  (2) A certificate of seal impression of the individual
 
4.  Fee for and Collection thereof regarding a "Request for Disclosure, etc."
[Request for disclosure of personal information possessed by the Company]
¥540 per application
Please enclose postal stamps with a value of ¥540 in your envelope for application documents.

The Company will inform you if the fee enclosed with your request is insufficient or if such fee has not been enclosed with your request.
If the required fee is not paid within a specified period of time, the Company will consider the request withdrawn.

[Request for correction, addition or deletion of personal information possessed by the Company, or for prevention of the use or provision of such information to third parties]
No fee required.
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5.  The Company's Response Method to a "Request for Disclosure, etc."
The Company will send an answer in writing to the address stated on the application submitted by the applicant.
 
6.  Purpose for Use of the Personal Information Obtained by the Company according to a "Request for Disclosure, etc."
The personal information obtained by the Company according to a "Request for Disclosure, etc.," shall be handled only to the extent necessary for such request. The submitted documents will be stored for the period of the relevant personal information in our possession plus five years thereafter (five years after the date of the Company's response if no such relevant personal information in possession exists), and destroyed thereafter.
 
7.  Causes for Non-disclosure of Personal Information Possessed by the Company
The Company may decline to disclose personal information in the following cases. The Company will send a notice with the justifying reason therefore to the applicant.
The prescribed fee will be billed even in case of such a non-disclosure.
  (1) The individual's identity cannot be verified because the address in the application, that in the document proving the individual and the registered one do not correspond with each other;
  (2) The power of attorney cannot be verified if the application is submitted by a proxy;
  (3) Some entries in the prescribed application documents proved erroneous or improper;
  (4) The Company deems disclosure could damage any lives, bodies or properties or any other rights and/or interest of the individual himself/herself or any third party;
  (5) The Company deems disclosure could have a significantly negative impact on its appropriate execution of business operations;
  (6) The Company deems disclosure could be in violation of any other laws or ordinances.
Consultation Desk for Customers' "Complaints" Complaints or Questions Regarding Personal Information

The following organization is responsible for handling personal information. Complaints or questions regarding personal information of the Company should be addressed to:
Personal Information Protection Consultation Desk,

SAXA Holdings, Inc.
2-2-3, Shimomeguro, Meguro-ku, Tokyo 153-8923
Phone: 03-3493-5113
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