Personal Information Protection Policy

Information Services International- Dentsu, Ltd.
Kamai Setsuo, President and COO

As an information service provider, we have established a "Personal Information Protection Management System" based upon the recognition of the significance and the social context of personal information protection, and have set our personal information protection policy as shown below. All of us, including all board members and staff members, will put this policy into practice, maka effort for the appropriate protection of personal information.

1. The following will apply to the acquisition, application and provision of personal information:
   • Whenever acquiring or applying personal information the purpose should be specified first, and then be notified or announced publicly, along with avoiding unnecessary application beyond the original purpose without consent of the relevant person.
   • Also, whenever providing personal information to a third party, consent of the relevant person shall be obtained first except as otherwise required by law.
2. We will observe all laws, national guidelines and other regulations concerning personal information management.
3. We will specify the representatives of the personal information management, limiting the number of such representatives to the minimum, along with taking appropriate human/physical/technological safety management measures in order to prevent leakage, loss or destruction of the obtained or provided personal information.
4. When outsourcing personal information management services, we will select service providers who meet appropriate personal information protection standards, along with providing the necessary and adequate supervision concerning safety management of personal information.
5. In order to maintain appropriate personal information protection standards, we will periodically review the Personal Information Protection Management System , which is accompanied by the changes of social conditions and various external and internal environments such as technical progress, and make effort to continuously improve our management system.

Contact for personal information management

Information Services International- Dentsu, Ltd., Corporate Strategy & Planning Division
E-mail: privacy-info@group.isid.co.jp
Telephone number: 03-6713-6100

Established December 9, 2000
Final revision: November, 2006

We will and make effort to protect personal information in accordance with the "Personal Information Protection Policy," and also, observe the following points concerning personal information management, as a service provider engaged in personal information management:

Application purposes

We will apply personal information with the following purposes:

• To provide consulting service, software product sales/support, system integration service, information process/communication service and other products/services from our company or group businesses
• To communicate business information to customers
• To execute contracts concluded between the customers and our company
• To send our newsletters and other publications
• To introduce products/services provided by our company and group businesses
• To introduce seminars/exhibitions and other events organized (hosted/co-hosted/supported) by our company and group businesses
• To send out questionnaires for purposes such as customer satisfaction surveys
• To respond to customer inquiries or requests
• To manage individual members of our business partners and temporary staff, based on various implemented contracts
• To respond to the execution of right of our stockholders and to fulfill our obligations based on the Commercial Law and other relevant laws
• To conduct personnel and labor management of our staff members, and to perform task verification in departments such as General Affairs and Accounting & Finance
• To perform the activities such as staff employment and recruitment
• To fulfill other purposes with prior consent of the relevant person

Whenever a need arises to change the aforementioned application purpose, we will ask for the customer's consent, except for the cases otherwise permitted by law.

Furthermore, there are cases where we outsource a part of our service and entrust the outsourcee with the necessary personal information. Whenever we entrust personal information, we select outsourcees who maintain certain personal information protection standards, along with taking the necessary measures such as concluding a contract concerning personal information management and providing necessary and adequate supervision for the outsourcee.

Provision to a third party

We will not provide or disclose personal information to any third party except for cases when entrusting it to an outsourcee as described above, or in any of the following cases:

• When we have consent of the relevant person
• When it is necessary for protecting a human life, body or property, and the relevant person is incapable of giving consent
• Other cases where the law demands its disclosure/provision

Disclosure, correction, suspended application and deletion of personal information

When you have requests for disclosure, correction, suspended application or deletion of personal information, or other inquiries, please contact us at the following address, with your name and point of contact (email address or telephone number) along with your request or inquiry. After confirming that you are the said person or the legitimate agent of the said person, we will respond to your request within a reasonable term and scope.

Contact for personal information management

Information Services International- Dentsu, Ltd., Corporate Strategy & Planning Division

E-mail: privacy-info@group.isid.co.jp
Telephone number: 03-6713-6100

Please note that there are cases where we cannot respond to your request concerning disclosure and other processing of personal information we posses based on the relevant laws.

Privacy mark and other certifications

We were granted the privacy mark in December 2000, which is given by the Japan Information Processing Development Corporation to service providers who carry out appropriate personal information management, and have been making effort to provide appropriate personal information management.

Also, we have obtained the information security standards "BS7799" and "ISMS" in March 2005, together with 42 companies of the Dentsu group, and the Dentsu group group has been making effort as a whole to continuously improve information security.

Press release: "42 companies of the Dentsu group obtain the information security standards "BS7799" and "ISMS certification standard as a group"

Revision

"Personal Information Management" is subject to change without notice, according to revisions of the relevant law or changes in the policy of the Information Services International - Dentsu, Ltd., and the Dentsu group.

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