Handling of Personal Information

1.Name of enterprise

FAN Comamunications, Inc.

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

Name: Takashi Yoshinaga, Director
Department: Chief Executive Officer, FAN Communications, Inc.
Personal Information, etc. Complaints and Advice Desk

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

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

(3) Personal information in the event of contracting

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

5.Shared use of Personal Information

Personal Information may be used jointly with our group companies as follows.

(1) Items of personal data
Name, address, age, telephone number, email address, usage and purchase history of our services

(2) Information of joint party
WAND Co., Ltd.

(3) Purpose of use
・To provide information on products, services, seminars, etc. of our group companies
・To improve, research, and develop products and services of our group companies

(4) Manager’s name, title, department and address

Name: Yuichi Kurosaki, Chief Privacy Officer
Department: CEO, WAND Co., Ltd.
Address: 1-1-8 Shibuya, Shibuya-ku, Tokyo

6.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) If the subcontractor sends out direct mail or emails, or provides information or another service by alternative means, on behalf of the company

(2) If the subcontractor requires information in order to provide individual services on behalf of the company, including after-sales services

(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) If disclosure is required by law, the courts or any other government agency

(5) If the customer has otherwise provided their consent for specific purposes

(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.

7.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) If disclosure is required by law, the courts or any other government agency.

(2) 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.

8.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.

9.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.

10.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.
FAN Communications, Inc.
Aoyama Diamond Building (2F), 1-1-8 Shibuya, Shibuya-ku, Tokyo 150-0002

Personal Information, etc. Complaints and Advice Desk