Personal Information Protection Policy - "TOTOKU INC."

  1. TOTOKU INC. (hereinafter referred to as “Company”) shall establish the personal-information-protection management system for the appropriate protection and management of personal information.
  2. When collecting personal information, Company shall clarify usage purposes and collect it legally and within appropriate scope.
  3. Company shall not disclose customers’ personal information without their prior consent. This provision, however, shall not apply in case of mandatory request for disclosure based on laws; in case of illegal activities, such as unauthorized access and blackmailing; and in case of other special reasons.
  4. Company shall pursue appropriate data management to prevent the loss, misuse, falsification, etc. of personal information.
  5. Upon customers’ request for the confirmation, correction, deletion, etc. of their personal information, Company may meet their request within reasonable scope only if their identification is verified.
  6. Company shall comply with applicable laws and regulations pertaining to personal information and make every effort to review and revise this Policy as appropriate.

March 9, 2005

TOTOKU INC.

Handling of Personal Information

Following are the descriptions about the handling of personal information at TOTOKU INC. (hereinafter referred to as "Company").

  1. Usage purposes

    Company will use customers' personal information for the offer or announcement of our products or services for customers, for replies to customers' inquiry, for product R&D, for service enhancement, for the creation of any statistical materials, for sales activities, and for other justifiable reasons.

  2. Collection of browsing history

    1. On Company’s websites “totoku.co.jp and totoku.com” (hereinafter referred to as “Websites”), viewer information is automatically collected, including an Internet domain name, IP address, and other information pertaining to Websites browsing, etc. In this case, customers’ “personal information” cannot be tracked. Collected information will be used as guidance for the smooth implementation of Websites’ services and for better customer services.
    2. Cookies (computer files that are sent by the central server and stored in users’ PC, for the identification of users on the part of the central server) are used on Websites. With the use of cookies, however, customers’ privacy will never be infringed, or customers’ PCs will never be harmfully affected.
  3. Share of personal information of minors aged under 16

    If minors aged under 16 intend to give Company their "personal information," it shall be done with the consent of their parents.

  4. Restrictions on usage and share

    Company will not disclose customers' personal information to the third party unless it is agreed by customers in advance. This provision, however, shall not apply in case of mandatory request for disclosure based on laws; in case of illegal activities, such as unauthorized access and blackmailing; and in case of other special reasons.

  5. Measures to ensure safety

    1. Company shall pursue appropriate data management to prevent the loss, misuse, falsification, etc. of customers’ personal information
    2. When collecting personal information on Websites, Company will encrypt data.
    3. Company shall not be responsible in any way for the protection and use of personal information that is collected on third party’s websites linked to Websites.
  6. Checks/ Correction

    Upon customers' request for the confirmation, correction, deletion, etc. of their personal information, Company may meet their request within reasonable scope only if their identification is verified.

  7. Compliance with applicable laws and regulations/ Revision of this Policy

    For the safety of personal information, Company shall comply with applicable laws and regulations pertaining to personal information. Also, Company may review and revise this Policy as appropriate. All amendments will be announced on this page.

TOTOKU INC.