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Code of Conduct for Protecting Personal Information

1. “Code of Conduct for Protecting Personal Information”

AI inside AI inside Inc. (hereinafter the “Company”) shall strive to thoroughly comply with the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of May 31, 2013), etc. and endeavor to implement measures listed in the following items to protect personal information in accordance with guidelines of the Personal Information Protection Committee, other related guidelines and documents published by administrative bodies.

1. Strengthening employee education

The Company shall prepare learning materials on protection of personal information, distribute them to all of its regular employees and temporary employees, and implement training at least once a year for all of its regular employees and temporary employees who handle personal information.

2. Developing internal regulations concerning protection of personal information

The Company shall develop internal regulations concerning protection of personal information, present a clear policy for handling personal information, and ensure that the Company’s strict stance on personal information leaks, etc. is disseminated in-house.

3. Assigning a Personal information Protection Manager and strengthening the manager’s function

The Company shall establish the post of Personal Information Protection Manager, assign the Information Security Administration Manager to the post, and develop a system where the role of the manager is clarified, for the purpose of supervising compliance with laws, regulations and guidelines, formulation of internal regulations, development of an audit system and other handling of personal information.

4. Implementing appropriate information security measures

To prevent leakage, loss and corruption of personal information and otherwise manage the safety of personal information, the Company shall take necessary and appropriate measures, such as managing access to personal information, putting restrictions on taking out personal information, and preventing unauthorized access by outside parties.

5. Contracting out operations

  1. The Company may contract out all or a part of operations for handling personal information, with respect to sales of various services, etc., responses to inquiries, equipment maintenance, fee-related operations, marketing and other operations.
  2. When entering into a service contract, the Company shall conduct a full review of whether the counterparty is qualified as a contractor. In a service contract, the Company will set forth safety management measures, maintenance of confidentiality, subcontracting conditions and other matters related to appropriate handling of personal information, and properly supervise its contractors by implementing measures, such as periodically monitoring the status of how outsourced work is conducted.
  3. When we undertake work from a company, if the company provides (entrusts) personal information to us, we will use such personal information to the extent necessary to achieve the purpose of the contract with the company.

6. Developing and improving an audit system

The Company will develop a system that enables it to internally audit whether personal information is protected properly.
In addition, audits using access logs are considered effective for early detecting those who leak personal information and preventing leaks through suppression effect of such early detection. Therefore, the Company will consider how to implement such audits.

7. Appropriate collection, use, provision, publication, etc. of personal information

When collecting personal information, the Company shall clarify the purpose of use of the information and employ fair and legitimate means, such as application forms and other documents, screens of websites, etc. and oral communication. In addition, the Company shall appropriately take actions such as using, providing and publicizing personal information, taking into account the nature and size of business, and implement measures to prevent use of acquired personal information for other than the intended purpose.

8. Responses to inquiries

With respect to personal information related to a person and handled by the Company, if the Company receives a complaint, request for consultation, or inquiry from that person about disclosure, correction, stoppage of use or other matters, the Company shall make an appropriate response.

9. Continuous improvement of activities to protect personal information

The Company shall review and improve activities in 1. to 8. above related to protection of personal information on a continual basis.

10. Revision

The Company may revise the whole or a part of the Code of Conduct for Protecting Personal Information. If a material change is made to it, we will inform you on our website or via any other channel in a recognizable manner.

Scope of the Code of Conduct for Protecting Personal Information

The terms “personal information,” “personal data” and “retained personal data” used in the Code of Conduct for Protecting Personal Information have the meanings defined in the Act on the Protection of Personal Information, regardless of whether such information or data relates to our customers, employees of companies we transact with, or our employees.
Unless otherwise stated in each section, the Code of Conduct for Protecting Personal Information shall apply to all personal information acquired by the Company and all personal data managed by the Company.

Established August 3, 2015
Revised December 26, 2017
AI inside Inc.
Taku Toguchi, Representative Director and CEO

< Consultation desk related to protection of personal information>
Consultation desk for personal information
Personal Information Protection Manager, General Manager of Administration Division
Tel: 03-5468-5041

2. Handling of Personal Information

The terms “personal information,” “personal data” and “retained personal data” used in the Code of Conduct for Protecting Personal Information have the meanings defined in the Act on the Protection of Personal Information, regardless of whether such information or data relates to our customers, employees of companies we transact with, or our employees.
Unless otherwise stated in each section, the Code of Conduct for Protecting Personal Information shall apply to all personal information acquired by the Company and all personal data managed by the Company.

AI inside Inc. (hereinafter the “Company”) shall use personal information for the following purposes.

1. Purposes of use of personal information not acquired directly using documents

  1. Personal information handled in work which is entrusted to us by a company we transact with
  2. To provide character recognition services
  3. To perform contracts and appropriately manage their details
  4. To conduct activities for research and development of artificial intelligence

2. Purposes of use of personal information subject to disclosure

  1. Personal information of companies we transact with
    To appropriately manage the details of contracts with companies we transact with
  2. Personal information of our shareholders
    To exercise rights and perform obligations in accordance with the Companies Act and the Commercial Code
    For the Company to provide various benefits
    To implement various measures to facilitate a good relationship between shareholders and the Company
    To manage shareholders, for example by preparing data of shareholders based on specified criteria in accordance with laws and regulations
  3. Personal information of those who wish to join the Company
    To provide information on job offers, recruitment and other matters to, and be in contact with, those who are interested in the Company as their place of employment or make a job application
    To conduct recruiting and screening activities
  4. Personal information of those who make an inquiry to the Company
    To improve customer service, etc. of the Company
    To accurately understand the details of an inquiry and information provided and make an appropriate response

Note that if we use relevant personal information for other than the above purposes, we will, in each case, clarify the purpose of use and obtain prior approval from the individual concerned.

3. Provision of personal information to third parties

The Company shall formulate personal information protection regulations, etc. concerning the handling of personal information and enforce the regulations, etc. as an organizational initiative, thereby ensuring security of personal information provided or entrusted to us. Except in any of the following cases, we will not disclose personal information to any third party.
In addition, even if we disclose personal information to our external contractor with which we have concluded a non-disclosure agreement, we will work to prevent the contractor from divulging and providing the information to another party, for example by including a related obligation in the agreement, and information we provide shall be anonymized as much as possible.

  1. When the individual concerned gives approval
  2. When the whole or a part of operations for handling personal information are outsourced to an external contractor with which the Company has concluded a non-disclosure agreement beforehand, to the extent necessary to achieve the purpose of use of the personal information
  3. When disclosure is required by a court, laws and regulations, etc.
  4. When personal information is disclosed in a manner that does not allow individuals concerned to be identified
  5. When personal information is disclosed to protect rights and assets of the Company

4. Consultation desk for inquiries about personal information and contact point for complaints

If you have an inquiry or complaint about the Company’s handling of personal information, please contact:

Personal Information Consultation Desk, AI inside Inc.
Address: Shibuya Daiichi Seimei Building 4F, 3-8-12 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan
Tel: 03-5468-5041
(Service hours: 9 a.m. to 5 p.m.; excluding Saturdays, Sundays, public holidays, the Year End and New Year holidays, and non-business days of the Company)

5. Contact information of a personal information protection-related accreditation organization to which the Company belongs

JIPTEC
Contact point for complaints, consultation and information provision with regard to protection of personal information by business operators granted a Privacy Mark
Tel: 0120-116-213/0120-700-779
(Consumer consultation service hours: 9:30 to 12:00, 13:00 to 16:30)

6. Disclosure, correction, stoppage of use, etc. of retained personal data

A complaint or request by a person for (1) notification of purpose of use, (2) disclosure, (3) correction, addition or deletion, (4) stoppage of use, erasure or stoppage of provision to a third party (actions described in (1) to (4) are hereinafter referred to as “Disclosure, etc.”) with respect to retained personal data related to that person shall be responded to in the following manner.

(1) Contact point to which a request for Disclosure, etc. should be sent

If you make a request for Disclosure, etc., please attach necessary documents to a specified request form and send them to the address indicated below by mail.
When sending by mail, please use delivery-certified mail or simplified registered mail so that delivery records can be confirmed.

Shibuya Daiichi Seimei Building 4F, 3-8-12 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan
To General Manager of Administration Division, AI inside Inc.
Tel: 03-5468-5041
(Service hours: 9 a.m. to 5 p.m.; excluding Saturdays, Sundays, public holidays, the Year End and New Year holidays, and non-business days of the Company)

(2) Documents to be submitted at the time of requesting for Disclosure, etc.

When requesting for Disclosure, etc., please download the request form [1] indicated below, print it out, enter all necessary information in the form autographically, enclose documents [2] to confirm the identity of the individual concerned, and send them to the address described in (1) above.

[1] Application form specified by the Company

Request Form for Disclosure, Correction, Stoppage of Use, etc. of Personal Information

[2] Documents for confirming the identity of the individual concerned

Any of copies of 1) “driver’s license,” 2) “passport,” 3) “residence card” or “special permanent resident certificate” and 4) “health insurance card + certificate of residence obtained within 3 months.”
Please send us a copy that shows the name and address of the individual concerned.
If you send us a certificate showing your registered domicile, please hide the section indicating the registered domicile by affixing a sheet on the section and then make a copy of the certificate.

(3) Expenses incurred when requesting for Disclosure, etc.

In the case of disclosure of personal information and notification of purpose of use, we charge you a fee of 1,000 yen (including tax) for each request.
In the case of correction, addition, erasure, stoppage of use or stoppage of provision to a third party, we do not charge you any fee.
Please enclose postal stamps of 1,000 yen along with the submissions. You are requested to bear the postage fee for sending to the Company.

Please understand that if the amount sent as a fee is insufficient or if the fee is not enclosed, we will notify you to that effect; however, if you fail to pay the fee within a specified timeframe, we will deem that your request for disclosure or notification of purpose of use has not been made.

(4) How to reply to a request for Disclosure, etc.

Within one month after receipt of a request form, we will send a reply to the address described in the request form indicated in (2) above by registered mail with delivery restricted to the addressee.
Point to note with a request, etc. for Disclosure, etc.: Please understand in advance that if you visit the Company in person to make the request, we do not accept it.
If you make a request by a method that does not allow a delivery record to be kept (such as regular mail), other than specific delivery-certified mail or registered mail, the Company shall not take any responsibility in the event of loss, etc. of a request form.
Be sure to make a request by specific delivery-certified mail or simplified registered mail.
Please understand in advance that a request form specified by the Company must be used and any other request form is not acceptable.
For a request form, you are requested to download the form from this website and print it out or send a request for the form to the address indicated in (1) above.

(5) Purpose of use of personal information acquired with respect to a request for Disclosure, etc.

Personal information we acquire as a result of receiving a request for Disclosure, etc. shall be used only for an investigation that is necessary for responding to the request for Disclosure, etc., identification of the individual concerned, and a reply to the disclosure request, etc.
Documents, etc. submitted shall not be returned. After we finish replying to a request for Disclosure, etc., we will appropriately manage and discard them.

(6) Request for Disclosure, etc.

In the below cases where a reply, etc. cannot be made, we cannot handle a request for Disclosure, etc.
If the Company decides not to disclose or take any other action, we will notify you of such fact along with the reason therefor.
Note that even in the case of non-notification of purpose of use or non-disclosure, we will charge you a specified fee.
Documents, etc. submitted by you shall be returned at your expense.

  1. When we cannot identify the individual concerned due to reasons such as a discrepancy between the address described in the request form, the address described in a document used to identify the individual concerned and the address registered with the Company
  2. When a legal representative makes a request but we cannot confirm his/her authority of statutory representation
  3. When there is a problem with specified submissions
  4. When personal information possessed by the Company cannot be identified based on information entered in the request form
  5. When information requested to be disclosed is not personal information subject to disclosure
  6. When there is a possibility that life, body, property or other rights and interests of the individual concerned or a third party may be harmed or damaged
  7. When there is a possibility that the proper operation of business of the Company may be significantly obstructed

7.Personal Information Administration Manager

Personal Information Protection Manager, AI inside Inc.