PRIVACY POLICY

Basic Policy

1. We will comply with all applicable laws, regulations, national guidelines, and other norms (hereinafter referred to as "laws, regulations, etc.") pertaining to the handling of personal information and we will handle personal information appropriately.
2. When acquiring personal information, we will limit the scope of such information to what is necessary for our business operations and will acquire such information in a lawful and fair manner, clearly indicating the purposes of use and the contact points for inquiries from the individuals in question.
3. Personal information obtained shall be used within the scope of the specified purposes of use, and shall not be used for any other purposes or provided or disclosed to any third party without the consent of the individual in question, except as required by law, and measures shall be taken to ensure that, when personal information is provided or disclosed to a third party with the consent of the individual in question, the third party handles the personal information appropriately.。
4. We will take necessary and appropriate security control measures to prevent leakage, loss, or damage of the personal information we handle and, if any of these problems occur, we will identify the cause and take corrective measures without delay.
5. When outsourcing the handling of personal information, we will take necessary and appropriate security control measures vis-à-vis the service provider, conclude a suitable contract with the service provider, and provide necessary guidance and management to the service provider.
6. We will respect the rights of individuals and we will respond to requests for disclosure of personal information in accordance with laws, regulations, etc., to a reasonable extent, except in cases where such requests fall within the exceptions stipulated by laws, regulations, etc.
7. We will continuously improve our system for managing the protection of personal information.
8. We may revise all or part of this Basic Policy in future in accordance with changes made to the provisions of laws, regulations, etc. In such cases, we will disclose the revised content on our website.

Purposes of Use of Personal Information and Inquiries Regarding Personal Information

1. Acquisition and use of personal information

The items of personal information that we obtain and retain, the means by which we obtain it, and the purposes for which we use it are as follows.

• Personal information items
  1. Basic information
     • Name, address, sex, date of birth, nationality, e-mail address, telephone number, facsimile number, etc.
  2. Additional information
     • Employer information (company name, address, telephone number, organization, position, etc.), information on family members (name, relationship, date of birth, etc.), etc.
  3. Information obtained from contact
     • E-mails, website form entries, letters, survey responses, etc., sent to the Company
  4. Information automatically collected from our website
     • Cookies, IP addresses, domains, browser types, access dates/times, etc.
  5. Information stipulated by administrative authorities and required under laws, regulations, etc.
• Methods of obtaining personal information
  1. (1) Obtaining information from the individual in question
     • Oral or written communications, telephone calls, business cards, websites, etc.
  2. (2) Obtaining information from persons duly authorized by the individual in question
     • Persons applying for products and services, persons making referrals, etc.
  3. (3) Obtaining information from business partners
• Purposes of use of personal information
  1. (1) Customer's personal information
     • To propose, sell, and provide products, services, and support
     • To provide information on products, services, etc., handled by the Company and its group companies
     • To provide information on events (seminars, exhibitions, etc.) held (sponsored, co-sponsored, or supported) by the Company and its group companies
     • To register the use of services, etc., provided by the Company and its group companies
     • To contact customers, conduct business negotiations/meetings, execute contracts, etc.
     • To respond to customer inquiries and requests
     • To conduct and administer training
     • To carry out surveys
       *Please refer to the“List of Group Companies”here for more information on our group companies
  2. (2) Personal information of business partners
     • To contact, negotiate/meet with, and execute contracts with business partners, etc.
     • To respond to inquiries and requests from business partners
  3. (3) Personal information of shareholders
     • To exercise rights and perform obligations in accordance with laws, regulations, etc.
     • To complete various procedures
     • To implement shareholder measures that facilitate relations between shareholders and the Company
     • To manage shareholder information in accordance with laws, regulations, etc.
  4. (4) Personal information of applicants for employment and retired employees
     • To provide information, communication and notification to prospective employees
     • To carry out employment selection procedures
     • To perform duties related to personnel and labor affairs (including benefits) for retired employees in accordance with laws, regulations, etc.
     • To provide information about the Company to retired employees, contact them when there is a need to do so (including invitations to social gatherings, etc.), and manage retired employees' information
  5. (5) Personal information of executives and employees
     • To make business contact
     • To pay compensation (wages, bonuses, benefits, etc.), carry out personnel and labor management, provide benefits
     • To conduct health management
  6. (6) Other
     • Public information (official gazettes, websites, commercially available books/directories, etc.) and personal information obtained from third parties
       To provide information on products and services handled by the Company and its group companies as well as on events (seminars, exhibitions, etc.) held (sponsored, co-sponsored, or supported) by the Company and its group companies, and to conduct various questionnaire surveys
     • Personal information entrusted to the Company in connection with consigned operations
       To fulfill contracts with service providers for contracted services such as system development, consulting, system support, education/training, etc.
     • Telephone call record information
       To ensure the accuracy of telephone conversations and to respond appropriately to inquiries and requests made via telephone
     • Records of access to/from our facilities and video recordings at our facilities
       To manage security, e.g., crime prevention and disaster prevention
     • Information automatically collected from our website
       To collect and analyze trends in customer access to the website in order to improve website functionality, services, operations, sales promotion, etc.
     • Other
       To fulfill purposes of use notified to and agreed upon in advance by the individual in question

The main businesses in which we use personal information are as follows:
Network integration business (network consulting, network design and management, network equipment installation and construction, network equipment sales, network computing services, operational support services and educational services)
If it becomes necessary for us to use personal information beyond the scope of the purposes of use previously announced, we will ask the individual in question for his/her consent to the new purposes of use, except when the use of personal information is permitted by laws, regulations, etc. or when other exceptional circumstances pertain.

The consent of a legal representative or other person will be required if an individual under 16 years of age or whose capacity for understanding is significantly lacking is to provide personal information to the Company.
Please contact the Personal Information Contact Desk indicated in 6. below if you wish to stop the use of all or part of your personal information that we have obtained and retain in accordance with laws, regulations, etc.

2. Outsourcing and sharing of personal information

1. (1) Outsourcing of handling
   We may entrust the handling of personal information to the following subcontractors to whom we outsource all or part of our operations to the extent necessary to achieve the purposes of use. In such cases, we will select a party that meets our established criteria as a service provider, conclude a contract on the handling of personal information, and pursue appropriate management and supervision to ensure that necessary and appropriate security control measures are taken.
   • Business partners or subcontractors for products and services handled by the Company and its group companies
   • Business operators or experts who provide business or operational management or other professional advice
   • Our group companies
   • Other parties
2. (2) Joint use
   We may share the following personal information of our customers with our group companies as necessary to conduct business activities jointly with our group companies. In such cases, the Company will provide the individuals in question with advance notification of the purposes of use, etc.
   To ensure that necessary and appropriate security control measures are taken, we will manage personal information appropriately in accordance with agreements on the joint use of personal information concluded between our group companies and the Company.
   1. (1) Basic information
      • Name, address, sex, date of birth, nationality, e-mail address, telephone number, facsimile number, etc.
   2. (2) Additional information
      • Employer information (company name, address, telephone number, organization, position, etc.), family information (name, relationship, date of birth, etc.), etc.
   3. (3) Information obtained from contact
      • E-mails, website form entries, letters, survey responses, etc., sent to the Company
   4. (4) Information automatically collected from our website
      • Cookies, IP addresses, domains, browser types, access dates/times, etc.
   5. (5) Information as instructed by administrative authorities and required by laws, regulations, etc.

3. Provision and disclosure of personal information to third parties

We will not provide or disclose personal information we have acquired to third parties without the consent of the individual in question, except in exceptional cases that include those described below. When providing or disclosing personal information to a third party with the consent of the individual in question, we will take appropriate measures to ensure that the party to whom the information is provided or disclosed safeguards this personal information.

1. (1) When required by laws, regulations, etc.
2. (2) When it is necessary for the protection of life, limb or property and it is difficult to obtain the consent of the individual in question
3. (3) When it is especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the consent of the individual in question
4. (4) When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute tasks prescribed by law and obtaining the consent of the individual in question is likely to impede the execution of such tasks
5. (5) When the third party is an academic research institution, etc., and it is necessary for the third party to handle personal information for academic research purposes (including when academic research purposes constitute only some of the purposes of handling the personal information but excluding when there is a risk of unjustified infringement on the rights and interests of the individuals in question)

4. Provision to third parties located in foreign countries

We shall comply with the requirements of laws, regulations, etc., when providing personal information acquired by us to third parties located in foreign countries.

5. Procedures for responding to requests for disclosure, etc., of personal information and inquiries regarding the handling of personal information from the individual in question

1. (1) Contact for requests for disclosure, etc.
   The following Personal Information Contact Desk will accept requests for disclosure, etc., of personal information from the individual in question in accordance with laws, regulations, etc. If you wish to request disclosure of your personal information, please submit an "Application for Disclosure, etc." to the Inquiry Desk in the manner described in 2. below.
   ＜Mailing Address＞
   Net One Partners Co., Ltd.
   Personal Information Inquiry Counter
   Postal Code: 100-7026
   JP Tower 2-7-2 Marunouchi, Chiyoda-ku, Tokyo
2. (2) Forms to be submitted for requests for disclosure, etc.
   Please fill out the "Application for Disclosure, etc." and mail it to the Personal Information Inquiry Desk. A template of the "Application for Disclosure, etc." can be downloaded from the relevant materials section on this page.
   Please note that a fee may be charged after an application has been received, depending on the nature of the inquiry/request.
3. (3) After confirming that the person making the request for disclosure of personal information is the individual in question or his/her representative, we will respond to the request and contact the individual in question.
4. (4) If you have any questions or complaints regarding our handling of personal information, please fill out the "Personal Information Inquiry Sheet" and mail it to the Personal Information Inquiry Desk. A template of the "Personal Information Inquiry Sheet" can be downloaded from the relevant materials section on this page.

6. Use of cookies and web beacons on our website and recording of IP addresses and domains

1. (1) We may use cookies and web beacons to improve the functionality of our website, enhance our services, improve our operations, promote sales, etc. These cookies and web beacons do not have the functionality to identify specific individuals.
2. (2) We may record IP addresses and domains pertaining to access to the website in order to ascertain and analyze trends in customer access to the website and to resolve problems encountered on the website. However, no specific individuals can be identified from such data.
3. (3) As stated above, the functionality described in (1) above does not have the ability to identify a specific individual, and the data described in (2) above cannot be used to identify a specific individual; however, we may, with your prior consent, collect and analyze trends in your visits to our website by linking information that can identify you as a specific individual with the functionality described in (1) above and the data described in (2) above. The information collected and analyzed will be used to improve the functionality of the website, enhance services, improve operations, and promote sales.
   • *Cookies are functions that save user information in a browser to reduce data entry tasks and to display the optimal content to the user. Users can set their browsers to refuse cookies or to display a warning when cookies are saved. If cookies are not saved, you may not be able to use all or part of the website’s services or you may face other restrictions.
   • *Web beacons are functions that monitor access conditions related to the user's device and collect statistical data regarding the usage rate of a particular website; they are sometimes referred to as clear GIFs.

7. Items pertaining to security control measures

The main security control measures to be taken by the Company are as follows.