MAGAZINE HOUSE CO., LTD.
Basic Policy on the Protection of Personal Information

MAGAZINE HOUSE CO., LTD. (located at 13-10, Ginza 3-chome, Chuo-ku, Tokyo; Shuichi Tetsuo, president; hereinafter referred to as “MAGAZINE HOUSE”, “we”, “us” and “our”) strongly recognizes the importance of protecting personal information and will properly manage and use personal information in compliance with the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as the “APP”) and the applicable laws, regulations and guidelines, as well as in accordance with the following policy. Personal information means information that can be used to identify a specific individual, such as address, name, telephone number, and e-mail address (including information that can be easily cross-checked with other information to identify a specific individual) and information that is considered personal information under the law:

1. Purpose of using personal information

<Your personal information>

We use personal information provided by you for the following purposes:

• To confirm your purchase of and deliver the magazines or books you purchased.
• To confirm your application for and send emails about the events or seminars you applied for.
• To confirm your subscription to and send emails about the email newsletter services you subscribed to.
• To confirm your registration with and send emails about the members-only services you registered with.
• To invoice, receive payments for, and confirm the invoicing and payments for the products or services you purchased or registered for.
• To send renewal notices for your periodical subscription and other notices.
• To send you small gifts to thank you for participating in surveys and the like.
• To send you small gifts to thank you for entering prize competitions and the like.

• To improve the products, services or websites you use to improve your satisfaction.
• To customize the products, services or websites you use to suit your needs.
• To conduct surveys about how satisfied you are with the information or products you ordered.
• To monitor your usage status to use it for the improvement of existing services and the development of new services.

• To provide you with information on periodicals, books, digital content, various members-only services, and various other services.
• To invite you to participate in surveys or various events, and to inform you of the survey results etc.
• To monitor your product or service and website usage status and provide you with information about, and surveys by, companies and organizations which may be considered beneficial to us and you.

<Other personal information>

e. To communicate with our customers (or in the case of a corporate customer, with its executives) for business purposes, to execute contracts and agreements, to carry out business negotiations, and to manage customer information.

f. To communicate with, and provide information to, job applicants in our recruitment activities and to use other personal information for any other purposes necessary to carry out recruitment activities.

g. To communicate with our employees for business purposes, to pay remuneration (e.g. wages, bonuses, allowances), to manage human resources and labor, to provide employee welfare and benefits, and to carry out health management.

Please note that we may amend the information you registered with us if any changes are made to the information we collected from you that may affect the delivery of or the invoicing for your purchased goods, such as the name of your city, town or village, your zip code, the name of your financial institution, or the expiration date of your credit card.
Furthermore, we may collate personal information we collected from you with other information we manage. For example, we may associate such personal information with a system that manages periodicals that we publish in order to verify you are one of our regular subscribers.

2. Security measures

We take the following security measures to prevent any divulgence, loss, or corruption of personal information and to appropriately manage other personal data:

Basic policy

• The Basic Policy is put in place to ensure that personal information is properly processed and to publicize a point of contact that deals with questions and complaints.

Rule for processing personal data

• The Personal Information Processing Rule is put in place to specify how personal information should be processed at each information processing stage, including its collection, use, retention, provision, deletion, and disposal. A Personal Information Manager and a Personal Information Officer have been appointed and their respective duties have been defined.

Organizational security measures

• A manager who is responsible for processing personal data (Personal Information Manager) has been appointed.
• Staff who are authorized to process personal data and the scope of personal data they are authorized to process have been clearly defined.
• We have a well-established communication system in place to report to the Personal Information Manager any actual or potential violation of laws and regulations or company rules that has been detected.
• Regular self-assessments and audits by other departments and an external organization are conducted to check how personal information is processed.

Administrative security measures

• Regular training is held for our employees to learn the key points in processing personal information.
• A personal information confidentiality clause is included in our Workplace Rules.

Physical security measures

• In areas where personal information is processed, staff entry and exit is controlled and restrictions are placed on devices brought into such areas. Measures are taken to prevent unauthorized staff from viewing personal information.
• Measures are taken to prevent the theft or loss of devices, electronic media, and paper documents that contain personal information.
• Measures are taken to prevent personal information from being readily disclosed when transporting devices and electronic media which contain personal information on or off the company premises.

Technical security measures

• Access controls have been implemented to limit the number of holders of access rights and the scope of personal information they are authorized to access.
• The information system that processes personal information is protected from unauthorized access by external parties and malicious software.

Monitoring of external environment factors

• Security measures are taken while monitoring the personal information protection system in the US where personal information is held. (Some states in the US have personal information protection laws, but there is no federal law that comprehensively governs the protection of personal information. Nevertheless, we have a system that ensures the company that holds your personal data will not process your personal data. We also have a system that enables us to duly respond to your requests for the disclosure or cessation of use of your personal information.)

3. Provision of personal information to third parties

We will not disclose any personal information provided by you to any third party unless:

• You have given consent for such disclosure;
• Your personal information is disclosed to our outsourcees or other organizations to the extent necessary to achieve the purpose of using your personal information that has been clearly indicated to you;
• The disclosure is required by law; or
• The disclosure is urgently required to protect the life, body, property, or any other material interests of a person.

4. Outsourcing

We may outsource to a third party such administrative work as sending notices to you, organizing campaigns, and analyzing information including your purchase history. In this case, we will exercise the necessary and appropriate oversight of such outsourcee in compliance with the APP.

5. Collecting, using, and providing information associated with identifiers, e.g. cookies

Our website may use cookies. A cookie is a piece of information in text format that is sent by a website you visit to a web browser and is stored by the web browser. A web beacon is a technique used to send information on when you have viewed webpages or emails into which minute pictures are embedded. This website uses cookies, web beacons, or any other similar technologies (hereinafter, “Cookies”) to store and use your information for the following purposes:

• To identify the operating system, browser, and IP addresses of the device you use and to monitor the webpages you have viewed.
• To statistically process and use for reference purposes to provide information services more effectively information that can be used to analyze your interests and preferences by collecting your website browsing history or e-commerce purchase history (the “Informative Data”).

Data which may be collected include:

• Cookie IDs (an identifier assigned when a cookie is sent by a website)
• URLs of webpages you have visited using your computer (browser)
• Types (segments) of webpages you have viewed using your computer (browser) and analysis results
• Websites you have visited and webpages you have viewed using your computer (browser) and your other activity and behavior history

Individuals cannot be identified by the above information.
By changing your browser settings, you can refuse to accept cookies or can display a warning when you receive cookies. Most of the services available on our website can still be used even if your browser does not accept cookies. Please note, however, that without cookies, some of the services may not function properly, your use of the services may be restricted, the speed of your computer may significantly slow down, or you may not be able to use the services at all.

The following opt-out option is available to you. Please read it carefully. You are welcome to exercise this option.
Online privacy notification

With your consent, we collect, collate with your personal data, and use for advertising and other purposes, your website browsing history collected by cookies from a data management platform (DMP) operated by a third party as well as the analysis results.

6. Anonymously processed information

We anonymously process your personal information so that you cannot be identified and provide the anonymously processed information to third parties. We intend to continue to create similar anonymously processed information and provide it to third parties. Items of your personal information that are included in anonymously processed information created are as follows:

• Your sex
• Your age
• The prefecture you live in
• The name and quantity of the products you purchased

Items of your personal information that are included in anonymously processed information provided to third parties are as follows:

• Your sex
• Your age
• The prefecture you live in
• The name of the products you purchased

Anonymously processed information will be provided to third parties in the following manner:

• Uploaded to a server or transmitted by a file transfer service used by us under contract in order to enable the third parties to access the anonymously processed information.
  We take security measures to protect anonymously processed information in accordance with the separately established Personal Information Protection and Security Measures Manual.

7. Pseudonymously processed information

We pseudonymously process your personal information so that you cannot be identified unless it is collated with other information and analyze and use the pseudonymously processed information for the purpose of developing our new products and services.
We take security measures to protect pseudonymously processed information in accordance with the Personal Information Protection and Security Measures Manual, which is separately established.
In addition, we jointly use your pseudonymously processed information as follows:

(1) Items of your personal information

• Your address
• Your purchase history

(2) Scope of users

(3) Purpose of use

• Analysis for developing our new products and services

(4) Person responsible for managing persona data

8. Requests to disclose personal data held by us

If you or your representative requests that we disclose personal data of yours that we hold, we will respond to the request without delay except in the following circumstances. We will inform you if such data will not be disclosed or does not exist.

• The disclosure could harm your or any third party’s life, body, property, or other rights or interests;
• The disclosure could significantly affect the proper execution of our business; or
• The disclosure could be in violation of law.

In addition, if you or your representative requests that we correct, add, delete, cease to use, erase or cease to provide to third parties your personal data held by us, we will respond to the request in compliance with laws and regulations after conducting an investigation.

9. Amendment to the Privacy Policy

We review this Privacy Policy from time to time to make improvements. We reserve the right to amend the Privacy Policy unless otherwise specified by law or in this Privacy Policy. Amendments to the Privacy Policy will come into effect when you are notified of them in a manner designated by us or are published on our website.

10. Contact us

If you have any questions or complaints about how we process your personal data, please contact us at:
Personal Information Protection Inquiry Desk
General Affairs Department
MAGAZINE HOUSE CO., LTD.
13-10, Ginza 3-chome, Chuo-ku, Tokyo 104-8003, Japan
Telephone: 03-3545-7111 (opening hours: 9:30 to 17:30)
info_privacy@magazine.co.jp