Kinnetix K.K. (hereinafter referred to as “Company”) establishes the following basic rules for the protection of personal
information as a policy regarding the protection of personal information.

1. Compliance with relevant laws and regulations


We will comply with laws and other norms related to personal information and will do everything possible to protect your important personal information.



For detailed information please refer to the Personal Information Protection Committee website: https://www.ppc.go.jp/en/index.html

2. Personal information


Personal information includes personal name, address, phone number, date of birth, age, gender, family structure, hobbies,
preferences, lifestyle, e-mail address, ID, organization, work, work address, work phone number, bank account number,
credit card number, website visit information, complaints, consultations, and other inquiries, etc.,
and it is possible to identify a specific individual by combining one or more of the above.

3. Use of personal information service


We will use the collected personal information to provide the following services.

• 1) For communication, delivery of materials, etc.
• 2) To verify that you are the person or agent
• 3) To create statistical data processed into a form that cannot identify individuals
• 4) For research and development of products and services by conducting market research, data analysis, questionnaires, etc.
• 5) To perform other duties appropriately

4. Restrictions on the purpose of use


We will handle the acquired personal information within the scope necessary to achieve the purpose of use.
When handling personal information outside the scope of the purpose of use, we will obtain the consent of the member in advance.
However, this does not apply in the following cases.

• i. When required by law
• ii. When it is necessary to protect the life, body or property of a person and it is difficult to obtain the consent
  of the person
• iii. If it is necessary for a national institution or local public entity or a person entrusted by it to cooperate in
  carrying out the affairs stipulated by laws and regulations, obtaining the consent of the principal will hinder the execution
  of the affairs.

5. Acquisition of personal information


We will obtain personal information by the following lawful and fair means and will not obtain it in
an unfair manner contrary to the will of the members.

• 1) When we obtain personal information indirectly, we confirm that the personal information we obtain
  is properly obtained by the provider.
• 2) When we obtain personal information, we will notify or announce the purpose of use in advance.
  Members will also be notified or announced when the purpose of use is changed.

6. Appropriate protection of personal information


We will take appropriate measures to ensure that your personal information is accurate and up-to-date.
We will also manage the personal information of members appropriately and safely.

• 1) Personal information on paper will be stored in a locked drawer
• 2) Personal information on computer files will be password protected
• 3) Computers handling personal information will be installed with anti-virus software
• 4) Employees and any partners or contractors will be trained on personal information law and proper handling
  of personal information

7. Supervision of contractors


Our company may outsource the handling of the acquired personal information. In that case,
we will conclude necessary contracts such as basic contracts related to the deposit of personal
information and perform necessary and appropriate supervision for those who have been commissioned.

8. Provision of personal information to third parties


As a general rule, we do not provide personal information of a member to a third party without the consent of the member. Provided only after obtaining the consent
of the member after identifying the destination and provision.

9. Disclosure of personal information


We will respond without delay when a member requests the disclosure of his / her personal information.
However, in the following cases, all or part of it may not be disclosed.

• 1) When there is a risk of harming the life, body, property or other rights and interests of the member or a third party
• 2) When there is a risk of significant hindrance to the proper implementation of our business
• 3) When there is a risk of violating other laws

10. Procedures for correction of personal information, suspension of use, etc.


If the member himself / herself requests correction, addition, deletion, suspension or erasure of the personal information of the member,
the Company shall confirm the identity of the member within a reasonable period of time.

11. Use of statistical data


We may create statistical data that has been processed so that the individual cannot be identified based on the personal
information of the acquired member. For statistical data that cannot identify individuals, we can use it without any restrictions.

12. Disclaimer


In the following cases, we are not responsible for the acquisition of personal information by a third party.

• 1) When the member himself / herself reveals personal information to a third party using the function of our service or other means
• 2) When an individual can be identified by personal information sent or entered by the member

13. Revision of basic rules for personal information protection


We may revise all or part of the basic rules for personal information protection. If there are important changes, we will notify you on our website.

14. Inquiries regarding Basic Rules for Personal Information Protection


Kinnetix K.K. NK Bldg 3F, 1-7-14 Koyasumachi, Hachioji-shi, Tokyo 〒192-0904

support@kinnetix-jp.com