OPTiM®

Basic Policy for the Act on the Protection of Personal Information

With the Act on the Protection of Personal Information effective from April 1^st, 2005, we have established and have been implementing a personal information protection policy as follows.
We recognize the importance of personal information that is disclosed by customers and business partners, and handle such information in full compliance with the Act on the Protection of Personal Information. In order to provide high-quality products and services, we take the following steps to protect personal information.

1. (Compliance with laws and regulations)
   We observe private information protection acts and associated regulations.
2. (Corporate system)
   Regarding handling private information, we establish the necessary rules, systematize the management process, and establish systems for private information protection.
3. (Collection of personal information)
   When collecting personal information, we explicitly indicate the purpose of use, and after receiving permission to do so, collect information only to the necessary extent.
4. (Disclosure/loaning out of personal information)
   When disclosing or loaning out personal information, we clarify the purpose of use and receive permission, and the collected information is used only to the necessary extent. We do not use information beyond the extent of usage defined when seeking permission from the user.
5. (Ensuring accuracy)
   We take the appropriate measures to keep personal information accurate and up-to-date.
6. (Security measures)
   We will strictly manage personal information, and take precautionary measures to protect the information from harmful acts, including unauthorized access, loss, destruction, falsification, and leaks.
7. (Internal education)
   We conduct training on how to handle personal information protection for employees to ensure they fully understand the protocol.
8. (Restriction of disclosures to third parties)
   Except when required by law, we do not disclose nor provide information to a third party without permission from the customer or partner.
9. (Disclosure and modification of private information)
   

   When customers or partners require confirmation or modification of personal information, we will respond in a timely manner.
   When confirming or modifying collected personal information, we require a written document from the person in question or an agent that explains the pertinent information. We then verify the document to protect the information from being leaked to an unauthorized third party.
   We may receive a prescribed fee for correspondence related to confirmation or correction of personal information.
   For further information, please contact us at the phone number below.

   OPTiM Corporation
   Director of Corporate Management Department TEL: +81-3-6435-8570

10. (Continuous review of internal system)
    We regularly review the internal corporate system for handling personal information, and perform any necessary improvements.
11. (About use of Google Analytics™)
    We use Google Analytics™ to better understand how our sites are used in order to create the best browsing experience for our visitors. This service collects and analyzes visitors’ access logs using cookies, but individual visitors are not identified. When using any site run by us, the visitor will be deemed as to have given permission for data processing performed by Google for the purpose mentioned above. For more information, please consult the Google Analytics™ terms and conditions at the link below.
    https://www.google.com/analytics/terms/us.html

This English translation of our Privacy Policy is for reference purposes only. The original Japanese version will prevail as the official authoritative version.

Shunji Sugaya
President, OPTiM Corporation