neton, Inc. engages in planning and production of websites, operation of shopping sites and other such services. As a business that processes information, including the personal information relevant to an advanced information society, we aim to establish a shared awareness of the importance of protecting personal information by doing so ourselves and also vow to establish, implement and maintain the following information protection policy.

neton, Inc. handles the following information as personal.

1. Customer lists, business cards, name registers and information that identifies individuals entrusted to us by customers, cooperating companies and other clients
2. Information that identifies individuals that was obtained from other business activities
3. Information that identifies all employees (including board members) and other individuals from the head office and all group companies with which consignment relationship exists

Purpose of protecting personal information

The protection of personal information is a crucial theme for us in conducting our business activities. For customers as well as for our company and employees (including board members), who handle this information, personal information is a crucial information asset, the steadfast protection of which is a major responsibility. neton institutes company-wide initiatives to protect personal information, ensuring customer security and fulfilling our responsibility to society.

Collection of personal information

We collect only the range of information necessary to meet our purpose of collection.

• Information is gathered through just and lawful means.
• We specify the purpose of collecting information in advance and obtain consent before acquiring the information.
• When the customer is under the age of 15, we will obtain the consent of the customer’s guardian.

In addition, we have devised measures so that such information is not used for other than its intended purpose. Should the necessity arise for this information to be used other than for its intended purpose, the consent of the individual concerned is to be obtained, except where such use is permissible by law.

Purpose of using personal information

neton uses the personal information it collects for the following purposes.

[Purposes for which customer information is used]

• For facilitating online payments and delivering templates
• For registering affiliated members
• For distributing e-mail magazines
• For responding to inquiries
• For agency registration
• For delivering free templates
• For facilitating forum use
• For registering members for template editing service
• For providing editing service
• For introducing and providing a variety of information on product-related planning, development, sales and product specifications
• For introducing our products, services, etc.
• For improving customer service through questionnaires and the like
• For the exercise of rights and fulfillment of obligations based on contracts with customers, laws, etc.
• For service cancellation and post-cancellation management
• For legal observance
• For fulfilling e-mail magazine distribution service obligations
• For appropriately and smoothly fulfilling transactions and contracts with customers

[Purposes for which applicant and employee information is used]

• For interviews and hiring, regardless of employment status: regular employee, contract employee, or part-time employee
• For work-related contact, information exchanges, attendance management, wage payment, evaluations, benefits, and the fulfillment of obligations under labor-related laws, such as health, safety and other types of labor management, and under tax- and social-welfare-related laws
• For the acceptance, fulfillment and management of various procedures stipulated in the in-house regulations
• For notifying and reporting to public offices, participating parties, etc.
• For emergency contact purposes

Provision of personal information

Except in the following cases, customers’ personal information will not be provided to third parties.

• When the customer has given consent
• When the law recognizes provision to a third party, such as for lawful inquiries made by public agencies

Consignment of personal information

Except in the following case, customers’ personal information will not be consigned to third parties
When the handling of personal information is consigned, within the necessary range for achieving the usage purpose that has been stated to the customer, to collaborating, affiliated, and subcontracting companies that have concluded nondisclosure agreements with us

• Appropriate management of personal information

To prevent and to rectify the leakage, loss or defamation of the personal information that we handle, we will steadfastly implement security measures and devise appropriate information-related countermeasures, including countermeasures to illicit access and computer viruses.

• Legal observance

In the course of our business, we will observe the laws and norms that pertain to personal information. In addition, we will strive to ensure that our management mechanisms conform to said laws and norms.

• Ongoing improvement

To accommodate changes in the social environment pertaining to the handling of personal information, “Personal Information Protection Management System” will be reviewed as necessary, beginning with this policy. Ongoing improvement will be strived for and optimum conditions constantly maintained.

• Disclosure, correction and deletion

Please direct inquiries pertaining to personal information, including its disclosure, correction, and deletion, to the contact person specified below. Please e-mail or fax your inquiries and make sure to include your name, postal address, return e-mail address (for inquiries made via e-mail), and the specifics of your inquiry. The same applies to personal information acquired prior to the formulation of this protection policy. As soon as the identity of the inquiring party has been confirmed, a response will be made without delay.
The identity of the inquiring party will be confirmed via the following methods.

• The party will be asked three (3) questions pertaining to the personal information.
• When a proxy is involved instead of the inquiring party, said proxy will be confirmed by means of an official letter of proxy from the party concerned.

When the identity of the inquiring party has been confirmed, we will send said party a “Request for Disclosure” form via post. Please fill out the required items on the “Request for Disclosure” form and send it back to us along with a postal money order for \3,000 to cover the processing fee.

Handling complaints and consultations

To ask questions about this personal information protection policy or to file complaints with us, please e-mail or fax the contact person specified below. Make sure to include your name, postal address, return e-mail address (for inquiries made via e-mail), and the specifics of your inquiry

Contact person for inquiries

Hirotaka Nakamura, in charge of personal information management

FAX：+81-6-6305-6773

neton, Inc. is a target business of the following authorized personal information protection organization. The following consultation office will also address complaints and consultations on how personal information is handled at neton.

Name of authorized personal information protection organization：
Japan Information Processing Development Corporation（JIPDEC）

Contact person for complaints resolution：
Privacy Mark Promotion Center, Section for Consultation about Complaints Regarding Personal Information Protection
Address: Kikai-Shinko-Kaikan Bldg. Shibakoen 3-5-8, Minato-ku, Tokyo 105-0011
Tel:+81-0120-700-779 / +81-3-5776-1379