Personal Information Protection Policy

(Public statement regarding personal information)

■ Handling of personal information

１．Purposes of use for the personal information handled by the Company

• （１）When the Company is going to collect personal information directly from an individual in writing (including via the website, via e-mail, etc.), for the purposes of use that apply when information is collected directly from an individual in writing, the Company will clearly indicate this to the individual beforehand in writing.
• （２）Purposes of use for personal information collected otherwise than as indicated in the previous paragraph

Type of information	Purposes of use
Information pertaining to individual customers	Carrying out user support.
	Managing use histories.
	Responding to inquiries.
	Providing information (including advertising and publicity) on the Company’s products, services, events, etc.
Information pertaining to contact persons at clients and suppliers	Confirming details of orders placed and received, carrying out billing, providing maintenance, and performing related tasks. (Information such as communication records and bank account numbers.)
	Providing information (including advertising and publicity) on the Company’s products, services, events, etc.
Personal information that the Company receives from customers as a result of outsourcing from another company (including location history, logs of e-mails sent and received, information on communications, information on terminal operation, as well as information — such as vital data — transmitted from devices)	Performing the subcontracted tasks in an appropriate manner.

Public announcement regarding personal information that is subject to disclosure
With regard to personal information in the Company’s possession that is subject to disclosure, the Company will handle, in accordance with the terms set forth below, requests from those to whom the information pertains — or from their representatives — with regard to notification of the purposes of use, disclosure of the information, correction, addition, or deletion of the information, discontinuation of use or elimination of the information, or discontinuation of the providing of the information to third parties (hereinafter collectively “requests for disclosure, etc.”).

• ａ）Company name
  Phone Appli Inc.
• ｂ）Personal Information Protection Manager
  Name: Yoshihisa Tsuchiya
  Departmental affiliation: Administration Dept.
  Contact telephone number　：03‐5488‐7085
• ｃ）Purposes of use for all types of personal information subject to disclosure

Type of information	Purposes of use
Information pertaining to individual customers	Carrying out user support.
	Managing use histories.
	Providing information (including advertising and publicity) on the Company’s products, services, events, etc.
	Responding to inquiries.
Information pertaining to contact persons at clients and suppliers	Confirming details of orders placed and received, carrying out billing, providing maintenance, and performing related tasks. (Information such as communication records and bank account numbers.)
	Providing information (including advertising and publicity) on the Company’s products, services, events, etc.
Information pertaining to the Company’s employees	Carrying out human resources and labor management, operations management, health management, and security management with regard to employees.
Information pertaining to individuals applying for employment at the Company	Contacting applicants and managing the Company’s recruitment operations.
Specific personal information	Using the information for the purposes of use set forth in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.

• ｄ）Contact point for submission of complaints regarding the handling of personal information subject to disclosure
  Personal Information Inquiry Contact, Phone Appli Inc.
  8th Floor, Hulic Kamiyacho Building, 4-3-13 Toranomon, Minato-ku, Tokyo, 105-0001, Japan
  E-mail：support＠phoneappli.net
  TEL：03‐5488‐7085
• ｅ）Authorized personal information protection organizations
  The Company is not currently a member of any authorized personal information protection organization.
• ｆ）Procedure for dealing with requests for disclosure, etc., of personal information subject to disclosure
  • 1）Contact point for submission of requests for disclosure, etc.
    Direct any requests for disclosure, etc., to the Personal Information Inquiry Contact given above.
  • 2）Procedure for requests regarding disclosure, etc.
    • ①After we receive your request, the Company will send you by postal mail the prescribed request form that you must use, the Request Form for Disclosure, etc., of Personal Information Subject to Disclosure.
    • ②Send the completed form (and, if you are filing the request as a representative, documentation to show that you are a representative) as well as a postal money order for the amount of the fee (only if you are requesting notification of the purposes of use or requesting disclosure) by postal mail to the Personal Information Inquiry Contact given above.
    • ③After we receive your request, in order to verify the identity of the person in question, we will ask you to verify, from among the personal information items that the Company has on record for the person in question, approximately two items of information (e.g., telephone number and date of birth) that permit the person in question to be identified.
    • ④In principle, we will send our reply in writing (in the form of a sealed letter sent by postal mail) to the person in question.
  • 3）In the case of a request filed by a representative, documentation showing that the person making the request is a representative
    If you are filing a request for disclosure, etc., as a representative, then enclose documentation proving that you are a representative as well as documentation proving your identity. In the case of information on your legal domicile found in the documentation, show only the prefecture of your domicile, and render the rest of the address unreadable by some means such as marking it out in black. In addition, either do not send us documentation containing your Individual Number, or else render every digit of the number unreadable by some means such as marking it out in black.
    ① Documentation to prove that one is a representative
    If the representative has been delegated to make the request for disclosure, etc., by the person in question:
    ・Power of attorney (original) of the person in question
    If the representative is serving as legal representative of a minor, an official copy of any of the following:
    ・Certified copy of family register
    ・Certificate of Residence (indicating family relationship to head of household)
    ・Any other official document showing that one has the right to legally represent the person in question
    If the representative is serving as legal representative of an adult ward, an official copy of any of the following:
    ・Certificate of matters recorded in Guardian Registration, Etc.
    ・Any other official document showing that one has the right to legally represent the person in question
    ② Documentation proving the representative’s identity
    ・Driver’s License
    ・Passport
    ・Health Insurance Card
    ・Certificate of Residence
    ・Basic Resident Register card
  • 4）Fee for request for notification of purposes of use or for request for disclosure
    ¥1,000 per request
    (Enclose a postal money order when you send us your request form, etc.)

Anonymizing of information, and providing of anonymized information to third parties The Company gives public notice that, with regard to the information possessed by the Company that is indicated below, and for the purposes indicated below, the Company anonymizes said information, taking appropriate protective measures so that specific individuals cannot be identified and so that the personal information that was used cannot be reconstructed, and provides the anonymized information to third parties.

• a）Information items related to individuals
  ① Information from physical examinations and medical questionnaires administered to the Company’s officers and employees Year of birth, gender, data from physical examination items (numerical values, etc.), and data from medical questionnaire items (medical history, symptoms the person in question is aware of, lifestyle, etc.)
  ② Terminal operation information, data communication information, and place of work Organization name, terminal operation information (keystrokes, mouse clicks, microphone input, names of applications used, data transmission destinations, and data communication ports, but in a form such that details cannot be identified), and information on place of work. Once in the first five business days of each month, the Company anonymizes such information for at most the previous three months.
• b）Purposes
  ① Information from physical examinations and medical questionnaires administered to the Company’s officers and employees Used for research and analysis with regard to health and productivity management
  ② Terminal operation information, data communication information, and place of work Used for research and analysis with regard to work style reform
• c）How the information is provided
  ① Information from physical examinations and medical questionnaires administered to the Company’s officers and employees Password-protected electronic files sent on external storage media via registered mail
  ② Terminal operation information, data communication information, and place of work Password-protected electronic files sent on external storage media via registered mail