1. Philosophy of the Protection of Personal Information

Personal Information shall be handled deliberately under the philosophy of respecting the personalities of individuals.
In performing our company’s software development and information processing work, Personal Information must be addressed in safe and appropriate handling.

2. Basic Policy

Personal Information is personal valuable property.
All personnel engaging in works at System EXE, Inc. shall establish, implement and maintain the management system for Protection of Personal Information (“Protection of Personal Information Management System”), and handle the Personal Information accurately and safely.

3. Purpose of the Protection of Personal Information Management System

ⅰ. Establishing standards for proper acquisition, use and provision of the Personal Information, and establishing rules of operation for the standards.

ⅱ. Establishing a code of conduct and any specific rule for the prevention and correction of unauthorized access to the Personal Information, and divulgence, loss or damage of the Personal Information.

4. Organization Activities

The following activities shall be carried out to specify the basic policy:

ⅰ. Appointment of Chief Privacy Officer (CPO), and allocate authorities and responsibilities to CPO to establish, implement and maintain the Protection of Personal Information Management System, and have CPO conduct the works;

ⅱ. Appoint Chief Privacy Auditor and conduct an audit;

ⅲ. Improve internal regulations and how to apply them based on an internal audit;

ⅳ. Request cooperation to companies and individuals with whom our company has business connections in order to achieve the purpose of the rules;

ⅴ. This Privacy Policy shall be in a browsing condition by publishing on our company’s home page (URL= http://www.system-exe.co.jp) or company brochure, etc.;

ⅵ. With respect to handling of the Personal Information and the Protection of Personal Information Management System, establish a “Consultation Desk for Receiving Complaints and Consultations” which accepts complaints and consultations from personnel, and handle the issue quickly and appropriately;

ⅶ. All of the directors and employees shall comply with Act on the Protection of Personal Information, the laws on protection of Personal Information, guidelines created by the competent ministry and other principles; and

ⅷ. Confirm, audit, and take corrective measures and preventive actions, etc. for the operation of the Protection of Personal Information Management System, and continuously improve it.

5. Handling of the Personal Information

ⅰ. Acquisition, Use and Provision of the Personal Information
Our company will appropriately acquire, use and provide the Personal Information taking software development, information processing work and its scale into consideration. Our company will make the purpose of the use clearly to the object person and make it public on our company’s homepage. Our company shall not use the Personal Information for any purpose other than the purpose explicitly stated in our company’s homepage. Our company shall take measures not to use the Personal Information for the purpose other than for intended purpose.

ⅱ. Respect of Rights
Our company respects individual rights related to the Personal Information, and in case that our company is required to disclose, correct and delete his/her own Personal Information by himself/herself, Company shall correspond to the request within a reasonable period of time and an appropriate range.

ⅲ. Implementation of Security Measures
Our company shall take measures for the prevention and correction of unauthorized access to the Personal Information, or the divulgence, loss or damage of the Personal Information such as preparing internal regulations and conducting education relating to the protection of the Personal Information for all employees, and implement proper security measures.

Date of Enactment of First Version: November 18, 2004
Date of Revision: September 1, 2007
Date of Enactment of Final Version: January 5, 2016

System EXE, Inc.
Representative Director and President
Yasuji Ohba

Please contact the following “Consultation Desk for Receiving Complaints and Consultations” for inquiries regarding the content of this policy, and for consultation regarding complaints and disclosure, etc.

System EXE, Inc. “Consultation Desk for Receiving Complaints and Consultations”
(Location) 5F, Yaesu-Mitsui Bldg., 2-7-2, Yaesu, Chuo-ku, Tokyo
(Phone) 03-5299-5351
(E-mail) privacy-p@system-exe.co.jp