1. The Company shall strictly adhere to laws, nationally established guidelines, other standards, contracts, in-house rules etc., pertaining to personal information protection.
2. Personal information entrusted to us directly from consumers shall be collected and used, or provided to third parties only upon giving prior explanation of the purpose of collecting such information and receiving the consumers'consent.
3. Personal information entrusted to us from clients shall be handled upon establishment of rules for protection and handling of personal information.
4. Personal information entrusted to us from business partners shall be handled upon establishment of contracts and memoranda between the consignee and the Company.
5. A person responsible for management of personal information in the Company shall be appointed, and an in-house management system provided to carry out proper management of personal information.
6. Necessary and appropriate countermeasures and preventive and corrective measures, from both technical and organizational aspects, shall be taken against the risk of unauthorized access to personal information and loss, destruction, falsification, or leakage of personal information.
7. The person responsible for management of personal information shall handle complaints and inquiries from both corporations and individuals. Depending on their content, complaints and inquiries will be cross-checked with various laws, regulations, contracts, and in-house rules, and all background information and outcomes will be recorded. Furthermore, improvements will be made promptly if required.
8. The Company shall conduct education on the personal information protection policy for officers and all employees, to ensure that they understand the personal information protection policy, and that they comply with the systems and rules the Company has set down in relation to personal information protection.
9. The Company gives highest priority to protecting the rights and interests of individuals, and shall deal quickly with changing environments, continuously improving the management system.

Date established: January 31, 2005
Date revised: April 1, 2010
Geoff Dossor
COO
Proximity Japan

Receiving and Using Personal Information

The Company may receive and use personal information as follows, in accordance with JIS Q 15001.

1. The Company may receive personal information from customers in connection with transaction and recruiting inquiries. In this case, we will use the personal information entrusted in us only for replaying to, and contacting, customers as well as for other purposes specified when gathering such information.
2. The Company may, upon being commissioned by a client, receive personal information from customers in the capacity of secretariat for gift campaign applications and applications for event participation. In such cases, we will use the information entrusted in us only for purposes specified when gathering that information, such as customer inquiries and contacts, drawings, sending gifts, and invitation for event participation.

Disclosure of personal information to consignees

The Company may, for the purpose of smooth execution of operations, consign part of the operations to consignees, and entrust them with personal information of customers within the necessary scope. In such cases, we shall select consignees that meet company-established standards, conclude contracts on the handling of personal information, and carry out appropriate supervision.

Management of personal information

The Company conducts strict security measures to prevent loss, misuse, and alteration of personal information. We shall maintain a secure environment to guard against unauthorized access, and review security measures as advances are made in technologies.

Disclosure, correction, addition, deletion, etc. of personal information

The Company will maintain customers' personal information in as accurate and updated form as possible.
Upon customer request, we will disclose, correct, add, delete, etc. registered information. However, we may refuse said request in part or in whole, upon explanation of the reason if we judge that any of the following applies.

• The individual or a third party's life, health, property, or other rights or interests may be harmed.
• The appropriate execution of the Company's business may be seriously hampered.
• Laws will be violated.

When requesting disclosure, correction, addition, deletion, etc. of customers' personal information held by the Company, the requesting party must present one of the following documents to the Company to confirm his or her identity.

• Driver's license
• Health insurance card
• Passport
• Other documents that can verify identity

The customer shall pay a shipping and handling fee of 1,050 yen (including tax) per request after being invoiced by the Company for disclosure or notification of purpose of use of personal information held by the Company.

Inquiries related to personal information

For inquiries related to personal information managed by the Company,

Contact N.Kobayashi at Proximity Japan
Telephone: 81-3-6221-8004
Fax: 81-3-6221-8810
e-mail　pjinfo@proximity.jp