1.Name of enterprise

F@N Comamunications, Inc.

2.Manager’s (or its representative’s) name, title, department and contact details

Name:
Hiroshi Matsumoto, Chief Privacy Officer
Department:
Director and Vice President, F@N Communications, Inc.
Contact:
privacy@fancs.com

3.Purpose of use for personal information
(excluding Individual Number and Specific Personal Information in this section)

(1) Purposes for which written personal information (including websites, emails, etc., hereafter referred to as “written”) obtained directly from the individual may be used

Description
Purpose of use
Customer information (including persons attending seminars, responding to questionnaires or registered membership data)
Making contact in relation to the company’s operations (affiliate services, media services and other related services), distributing email newsletters, providing information on new products, services and seminars, conducting questionnaires, confirming details for the purposes of accounting audits, etc.
Inquiry information
Responding to inquiries
Shareholder information
Disclosing information, sending out items by post, paying dividends, etc.
Investor and analyst information
Providing details of results briefings, providing other types of information
Client information (including agencies)
Reviewing transactions, placing and receiving orders, paying bills, making contact in relation to services, providing information on new products, services and seminars, conducting questionnaires, confirming details for the purposes of accounting audits, etc.
Journalist Information related to press and publication (including reporter, writer, interviewer or interviewee)
Requesting interview or press materials, or sending press releases or invitations for press conferences, etc.
Job applicant information
Recruitment activities (checking documents, conducting interviews, evaluating candidates, contacting applicants, etc.)
Employee information
Labor-related procedures, social insurance, welfare administration, etc.

(2) Purposes for which non-written personal information obtained directly from the individual may be used

Description
Purpose of use
Customer information
Confirming order details (call records)
Entry/exit data, video footage, audio data
Security management for crime and disaster prevention, etc.

(3) Personal information in the event of contracting

Description
Purpose of use
Customer information
Information processing services in accordance with an agreement with the outsourcer, membership activities, shipping promotional products, etc.

4.Purpose of use for Individual Number and Specific Personal Information

Description
Purpose of use
Employee
[Taxation]
*Making Withholding Certificates
As for a member of Executive or Employee *Shareholding Ownership Plan, providing such Plan in order to make Certificates of Remuneration Payment
[Sociattl Insurance]
*Making notifications, applications, requests or certificates regarding Health Insurance / Employees Pension Insurance
*Making notifications, applications, requests or certificates regarding Employment Insurance / Industrial Accident Compensation Insurance
Employee’s spouse and relatives
[Taxation]
*Making Withholding Certificates
[Social Insurance]
*Making notifications regarding Health Insurance / Employees Pension Insurance
Business Partner
[Taxation]
*Making Certificates of Remuneration Payment regarding fees and commission charges *Making Certificates of Remuneration Payment regarding real property transactions

5.Provision or outsourcing of personal information to third parties (excluding Individual Number and Specific Personal Information in this section)

Customer’s personal information may be provided or outsourced to a third party in the following circumstances only.

  1. (1) If the subcontractor sends out direct mail or emails, or provides information or another service by alternative means, on behalf of the company
  2. (2) If the subcontractor requires information in order to provide individual services on behalf of the company, including after-sales services
  3. (3) If the company gather or analyzes individuals’ personal information for the purposes of providing statistical data, which is only disclosed once it has been processed so that individuals cannot be specified or identified
  4. (4) If disclosure is required by law, the courts or any other government agency
  5. (5) If the customer has otherwise provided their consent for specific purposes
    If the company intends to outsource all or part of its services, it selects a subcontractor carefully, ensuring that they have sufficient management systems in place to adequately protect personal information. The company then concludes a confidentiality agreement with the subcontractor and ensure that its customers’ personal information is rigorously managed.
  6. (6) If the company provides information with the Japan Affiliate Service Kyokai (JASK) or a JASK member company
    Since October 1, 2007, the company has been providing personal information with the Japan Affiliate Service Kyokai (JASK; http://j-ask.org/) and JASK member companies, in relation to partners that have disadvantaged e-commerce sites (advertisers) or engaged in malicious acts that have damaged confidence in its services.

6.Provision or outsourcing of Individual Number and Specific Personal Information to third parties

Customer’s Individual Number and Specific Personal Information may be provided or outsourced to a third party in the following circumstances only.

  1. (1) If disclosure is required by law, the courts or any other government agency
    If the company intends to outsource all or part of its services, it selects a subcontractor carefully, ensuring that they have sufficient management systems in place to adequately protect Individual Number and Specific Personal Information. The company then concludes a confidentiality agreement with the subcontractor and ensures that its customers’ personal information is rigorously managed.

7.Disclosure of personal information, etc.
( including but not limited to Individual Number and Specific Personal Information in this section)

“Personal information subject to disclosure” shall refer to personal information that has been systematically organized, and over which the company has the authority to respond to any request from the relevant individual, including notification of the purpose of information, disclosure, revisions, additions, deletions, suspension of usage, removal, and suspension of provision to a third party.
For full details of requests regarding disclosure or other such actions, please contact the [Inquiry Desk] specified at the end of this document.

(1) Notification of purpose or disclosure of personal information subject to disclosure
If the company receives a request from an individual regarding notification of purpose or disclosure of personal information subject to disclosure, it immediately notifies the individual of the purpose for which their personal information is being used or disclose the relevant information. If it is not possible to identify such personal information, the company informs the individual that is the case.
In any of the circumstances listed in points a) to c) below however, notification of purpose or disclosure of personal information may not be possible. In such an event, the company immediately notifies the individual and provide an explanation.
a) If there is any risk of damage to the life, body, property, or other rights and interests pertaining to the individual or a third party
b) If there is any risk of serious interference with the adequate performance of operations by the relevant enterprise
c) If there is violation of the law or other regulations
(2) Revisions, additions to, or deletions from personal information subject to disclosure
If, as a result of disclosure, the company receives a request to revise, make additions to or delete specific items of personal information subject to disclosure on the grounds that they are factually inaccurate, it immediately carries out any necessary investigations and alter the relevant personal information based on its findings. Once alterations have been made, the company shall immediately notify the individual (including details of alterations).
(3) Right to refuse use or provision of personal information subject to disclosure
If the company receives a request to suspend use of or delete personal information subject to disclosure, or suspend provision of such information to a third party, from the relevant individual, it does so as requested. After taking the requested action, the company immediately notifies the individual. If it is not possible to comply with the request due to any of the circumstances specified under points a) to c) in the above Paragraph (1) however, the company immediately notifies the individual and provides an explanation.

8.Voluntariness regarding the provision of personal information
(including but not limited to Individual Number and Specific Personal Information in this section)

Customers are given full discretion over whether or not they choose to provide the company with their personal information. If the company is not provided with required items of personal information excluding Individual Number and Specific Personal Information, however, it may be unable to provide individual services to an adequate standard.
In addition, if the company is not provided with Individual Number and Specific Personal Information, it may be unable to submit or provide required documents for social insurance and taxation.

9.Obtaining information via methods that the relevant individual does not easily recognizes

Cookies and mobile phone identification numbers (fixed identification numbers) are used to provide a more convenient browsing experience next time the relevant customer visits the company’s site. They do not infringe upon the customer’s privacy in any way, and will have no negative impact on the customer’s computer.
Sections of the company’s website that require customers to enter personal information use measures such as SSL (Secure Sockets Layer) data encryption system to ensure security. The company also has a strict policy of protecting information within the website, using measures such as firewalls. Please be aware however that, due to the nature of online communications, it is not possible to completely guarantee security.

Inquiry Desk Inquiries regarding the company’s privacy policy should be directed as follows.

Personal Information Complaints and Advice Desk
F@N Communications, Inc.
Aoyama Diamond Building (2F), 1-1-8 Shibuya, Shibuya-ku, Tokyo
150-0002
Contact: privacy@fancs.com

Name and contact details for authorized personal information protection organization

The name of authorized personal information protection organization the company joined, and contact details for resolving complaints, are as follows.

Privacy Complaints Desk
Japan Information Processing Development Corporation (JIPDEC)
Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
Contact: 03-5860-7565 (toll free) 0120-700-779
※These contact details are not for inquiries regarding the company’s products or services