Basic Policy on the Appropriate Handling and Protection of Personal Information

INO Consulting Co., Ltd., (the “Company”) with respect to the handling of personal information connected to the services it provides to clients, recognizes the importance of the protection of personal information pertaining to each and every individual, and in the interest of developing a deeper level of trust with its clients, hereby sets forth its basic policy (the “Policy”) related to the appropriate handling of personal information
　　
1.Management and Protection of Personal Information
The Company shall keep accurate and up to date personal information and in order to prevent the unauthorized access to, loss, corruption, alteration or leakage of personal information, shall maintain secure systems, establish organizational controls, provide proper employee training and take other necessary measures to strictly safeguard personal information. In the event of a problem, the Company shall promptly take corrective measures to prevent future re-occurrences.

2.Usage and Provision of Personal Information
The Company shall acquire personal information only after providing a clear description of the purpose of use and shall only use personal information within the scope of that purpose. The Company shall establish internal controls and take appropriate safety measures to prevent usages of personal information that exceeds the scope of the purpose.

1. Provision and description of Company services
2. Distribution and sending of Company newsletters
3. Inquiry handling
4. Employment related HR and labour management
5. Reporting based on government requests
6. Other purposes incidental to the above

3.Non-Disclosure of Personal Information to Third-Parties
The Company shall take proper measures to manage Personal Information it has received from its clients, and except in the following cases, shall not disclose Personal Information to any third party.

1. Has obtained the approval of the client company or the individual concerned;
2. When the Company is required to disclose Personal Information to a business it has outsourced services which the client company has requested the Company to perform;
3. When disclosure is required by law;
4. When there is special requirement for the improvement of public hygiene or the well-being of a child, and it is not possible to acquire the consent of the individual concerned;
5. When there is special requirement for the protection of the life, body or assets of a person, and it is not possible to acquire the consent of the individual concerned; or
6. When there is a special requirement to co-operate with a person or organization entrusted with the performance of a task prescribed by law by a national or local government or other public organization, and it is not possible to acquire the consent of the individual concerned.

4.Governing Law
The Company shall observe all applicable laws, government guidelines and other regulations pertaining to the handling of personal information in the possession of the Company.

5.Personal Information Related Inquiries
Proper procedures for the appropriate and timely handling of complaints and inquiries related to the handling of Personal Information have been established. Please direct questions or complaints related to the handling of Specific Personal Information to the following:

• Personal Information Inquiries
• Direct inquiries to the Personal Information Manager
• Tel: 03-5826-4470 10:00 to 16:00
• Email: info＠ino-consult.com

This Policy has been provided to all employees and has also been made available for outside public viewing. Furthermore, the Company provides training and education to all its employees in order to raise awareness of protection and management of Personal Information.

Established: December 1, 2015
INO Consulting Co., Ltd.
Representative Director Takehiro Kimura