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PRIVACY POLICY

Basic Policy on Information Security
The Handing of Personal Information of Business Partners and Payers
Handling of Personal Information in Connection with Employment

Basic Policy on Information Security

We, NIHON SEKKEI, INC., are entrusted with the important information of others, including our clients, and regard the proper handling of these information assets as our social responsibility.
For this reason, we have set forth our basic policy on the proper protection and use of information assets in this Basic Policy on Information Security (hereinafter, the "Basic Policy") with which we shall comply.

Objectives and Measures

This Basic Policy is intended to facilitate the proper handling of the information assets entrusted to us as well as protect said information assets from various risks such as leakage, theft, unauthorized use, destruction and falsification. We are implementing organizational, personnel, physical and technical security management measures based on this Basic Policy on Information Security.

Scope of Application

This Basic Policy applies to our subcontractors such as subsidiaries as well as temporary staff, etc. who handle information assets in addition to all our officers and employees who handle information assets. Aforementioned personnel are committed to acting in compliance with this Basic Policy. They shall comply with the provisions set forth in this Basic Policy during their tenure as well as after their resignation or the completion of their duties.

Management System

We will take the proper organizational security management measures such as developing an organizational structure and enacting rules and regulations in order to properly manage information. We have established an Information Management Chief to supervise the planning, formulation and promotion of aforementioned measures and are taking the necessary steps in order to implement various measures relating to information management.

Compliance with Laws and Regulations

We will comply with the laws and regulations concerning the management of information, this Basic Policy and rules, etc. enacted based on this Basic Policy (hereinafter collectively referred to as "this Basic Policy, etc.") in the execution of business.

Education and training

We will provide education and training to all our officers and employees in order to make the content set forth in this Basic Policy, etc. well known and enhance awareness of information security.

Evaluation and Improvement

We will evaluate the management situation and improve management measures, etc. as necessary.

Date: 10/3/2016

The Handing of Personal Information of Business Partners and Payers

We, NIHON SEKKEI, INC., are entrusted with the personal information of others, including our clients. We will properly protect, use and securely handle personal information in compliance with the Act on the Protection of Personal Information and the various internal regulations we have enacted based on this Act.

1. Acquisition of Personal Information

We will set forth the purposes of use of personal information and will acquire personal information only as necessary to achieve said purposes of use. We will acquire personal information fairly and legitimately; we will never acquire personal information through fraudulent means.
If acquiring personal information from a third party, we will take care to ensure there is no fraud by avoiding the acquisition of personal information that we know to have been leaked, etc.

2. Use of Personal Information

We may use personal information to facilitate the proper execution of business and transactions, etc. We will identify the business and services, etc. in relation to which personal information will be used, as well as the purpose of use, so that the individuals who have entrusted us with their personal information can reasonably envision our usage thereof.

3. Management of Personal Information

We are implementing organizational, personnel, physical and technical security management measures based on this Basic Policy on Information Security in order to securely manage personal information and prevent the leakage and loss of and damage to the same.

4. Provision of Personal Information to Third Parties

We may provide personal information to third parties within the scope necessary to achieve the purpose of use or based on the provisions set forth in laws and regulations. However, we will stop providing an individual's personal information to third parties at the request of the individual concerned. Please note that we may also outsource the handling of personal information. In this case, we will select a contractor who implements appropriate measures for the protection of personal information.

Date: 10/3/2016

Handling of Personal Information in Connection with Employment

We, NIHON SEKKEI, INC., will properly protect, use and securely handle the personal information we have received from job applicants in compliance with the Act on the Protection of Personal Information and the various internal regulations we have enacted based on this Act.

1. Acquisition and Purpose of Use

We will acquire personal information from applicants through the registration form on our website within the scope necessary to employ personnel at our company.

2. Definition of Applicants

Applicants refer to those seeking employment in our company who have used the registration form on our website to send us their personal information with the purpose of obtaining employment information and after having understood and agreed to all of the terms related to the handling of personal information.

3. Management of Personal Information

We are implementing organizational, personnel, physical and technical security management measures based our Basic Policy on Information Security in order to securely manage the personal information of applicants and prevent the leakage and loss of and damage to the same.

4. Outsourcing

We may outsource the operation of our website through which applicants provide their personal information, etc. to a specialist.

5. Provision of Personal Information to Third Parties

We may provide personal information to third parties within the scope necessary to achieve the purpose of use or based on the provisions set forth in laws and regulations. However, we will stop providing an individual's personal information to third parties at the request of the individual concerned.

Date: 10/3/2016

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