Investor Communications Inc. (hereinafter, “the Company”) may receive information necessary for the conduct of its business (hereinafter, “Personal Information”), such as the names, addresses, telephone numbers, and email addresses of customers and their children, from enrolled students, their guardians and their representatives, persons who have made inquiries, or persons who have otherwise provided personal information to the Company (hereinafter collectively referred to as “you”), when applying for various classes, requesting various information materials, or making inquiries to the Company. Fully recognizing the importance of the Personal Information provided to us, the Company establishes and complies with its “Basic Policy on the Protection of Personal Information” (hereinafter, the “Basic Policy”) as set forth below.

1. Purposes of Use of Personal Information

The Company will handle Personal Information only within the scope necessary to achieve the following purposes of use. When you provide Personal Information, you are deemed to have consented to the Company’s use of that Personal Information in accordance with this Basic Policy.

• To create rosters for emergency contact and similar purposes for enrolled students and their guardians; to send invoices, various notices, and teaching materials; to organize classes; to conduct class operations such as attendance management, academic advancement consultation, and academic advancement guidance; and to make inquiries and confirmations from the Company necessary for other business operations, as well as to improve the services operated by the Company
• To provide information about various events and other matters planned or hosted by the Company or by a third party entrusted by the Company, or to request participation in various surveys and the like
• To respond to various inquiries (including telephone contact, email, direct mail, the distribution and sending of various notices, and confirmation of receipt of information materials in connection with the use of the services operated by the Company)
• To identify children within the school building
• To create statistical data processed into a form that cannot identify individuals
• To use Personal Information for purposes that the Company has individually specified at the time you provided the Personal Information

2. Disclosure of Personal Information

With respect to the Personal Information you have provided, the Company may disclose Personal Information in the cases set forth below. However, in the cases of items 2 and 3, this applies only where it is difficult to obtain your consent.

1. When there is a request from a relevant government ministry or agency based on laws and regulations
2. When it is necessary for the protection of the life, body, or property of a person
3. When it is especially necessary for improving public health or promoting the sound development of young people
4. When it is necessary to cooperate with a national government body, a local government, or a person entrusted by either of them in carrying out affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the performance of those affairs
5. When Personal Information is provided in connection with the succession of a business due to a merger or other reason, and it is handled within the scope of the purpose of use prior to the succession

3. Procedures for Disclosure, Correction, Deletion, and the Like of Personal Information

Based on a request from the individual, the Company will respond to requests for the disclosure, correction, addition, deletion, suspension of use, or erasure of Personal Information. In such cases, we will verify the identity of the individual using a prescribed method.

4. Use of Statistically Processed Data

Based on the Personal Information it receives, the Company may create statistical data processed so that individuals cannot be identified. The Company may use statistical data that cannot identify individuals without any restrictions.

5. Compliance with Laws and Regulations

The Company complies with laws and regulations concerning Personal Information, guidelines established by the government, and other norms.

6. Implementation of Security Management

The Company takes appropriate security management measures to prevent the loss, destruction, falsification, and leakage of Personal Information.

7. Outsourcing of the Handling of Personal Information

The Company may entrust all or part of the handling of your Personal Information to a third party. In such cases, the Company concludes a business outsourcing agreement with the contractor, confirms the safety of the contractor’s information management system, and provides necessary and appropriate supervision.

8. Changes to the Privacy Policy

The Company may revise the content of this Basic Policy as necessary in accordance with the enactment or amendment of relevant laws and regulations. In such cases, the Company will publish the “Basic Policy on the Protection of Personal Information” reflecting the revised content on the Company’s website.

9. Continuous Improvement of Information Management

The Company continuously reviews its management system and initiatives for the protection of Personal Information.

10. Contact for Inquiries Regarding the Handling of Personal Information

Investor Communications Inc., Personal Information Protection Manager
Address 5-4-5 Koishikawa, Bunkyo-ku, Tokyo
Phone 03-5981-9308

Revised July 22, 2020