Privacy Policy

April 1, 2005
Phoenix Associates Co., Ltd.
Peter A. Owans, President

Phoenix Associates will endeavor to ensure appropriate management and safekeeping of personal information held by us based on the following guidelines.

1. Compliance

Phoenix Associates shall comply with the Law concerning the Protection of Personal Information (Act for Protection of Computer Processed Personal Data held by Administrative Organs) and other related laws and related government authority guidelines.

2. Collection of Personal Information

Phoenix Associates shall utilize legal and fair means in the collection of Personal Information

3. Use of Personal Information

Phoenix Associates shall inform clients or announce in advance the objectives of use of Personal Information, and shall use it within the range necessary to attain the objectives specified.

4. Provision of Personal Information

Phoenix Associates shall not provide third parties with Personal Information without the Client's consent.

5. Handling of Personal Information

Phoenix Associates takes necessary steps to secure and protect Personal Information correctly and safely from unauthorized access, loss, destruction, alteration and leakage.

6. Management of Personal Information

Phoenix Associates shall establish a maintenance system to maintain Personal Information and shall appoint a supervisor to oversee this system.

7. Training of employees

Phoenix Associates shall provide its directors and employees (including part-timers and temporary employees) with the education and training necessary to ensure the appropriate handling of Personal Information.

8. Provision of information to Partner Companies

When Phoenix Associates delegates certain functions of it's business to Partner Companies, it shall ensure that a confidentiality agreement is in place with the Partner to ensure the appropriate management of Personal Information by the Partner.

9. Response at time of accident

If an accident occurs, such as leakage of Personal Information, Phoenix Associates shall immediately inform the individual(s) and other parties involved, announcing necessary information, and take measures to prevent any recurrence of such an accident.

10. Review of Privacy Policy

Phoenix Associates shall, in taking appropriate measures in the handling and management of Personal Information, maintain appropriate and prudent management and will strive to make continuous improvements concerning the handling of Personal Information.

11. Inquiry Counter

Phoenix Associates shall handle complaints and other inquiries concerning Personal Information by appointing a person responsible for managing the information.

Contact: Ichisuke Kato
General Manager, Sales Division Tel: 03-5427-6231

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