Basic Personal Information Protection Polic

Enactment Date: January 24, 2006 Revision Date: June 18, 2007 Ashley Associates President  James Ashley

Ashley Associates (“the Company”) considers the protection of personal information, which has become increasingly important with the rapid development of information technology in recent years, to be an important corporate obligation. The Company has prepared this Personal Information Protection Policy to ensure every employee is thoroughly familiar with the Company's rules for the administration of such information.

1. Acquisition, Use and Provision of Personal Information
1. Purposes of use
   When handling personal information, the Company will use the data only for purposes that are within the scope of the purposes of use and for which the Company clearly obtained explicit consent when receiving the information directly from the person in question. The Company will use personal information obtained by other methods only within the scope of separately disclosed purposes of use. The Company's general purposes of use are described here.
   Information concerning the Company's administration of personal information related to selection for employment is described here.
2. Use and provision of personal information
   In its usage and provision of personal information, the Company will not extend beyond the scope of activity necessary to achieve that information's intended use. The Company has also instituted measures required to prevent personal information from being used in a manner that is not intended.
   However, this rule does not apply in circumstances corresponding to any of the following situations.
1. When the Company has received the explicit consent of the person in question.
2. When the Company is required to disclose the personal information by law, ordinance etc.
3. When the Company must disclose personal information to protect the lives, physical well-being or property of the person in question or the general public and it would be difficult to obtain the consent of the person in question.
4. When the Company is required to cooperate with an institution of the central government or local authority or a party acting under charge of an institution of the central government or local authority to carry out an activity provided by law, and there is a potential the accomplishment of the activity in question will be obstructed by obtaining the consent of the person in question.
3. Consignment of Personal Information
   From time to time the Company may consign the processing of personal information to a third party in order to improve the efficiency of the Company's business. In such instances, the Company will require the third party to control the personal information in a manner identical to the Company, based on a written agreement or other documentation.
4. Entrusted Personal Information
   From time to time the Company may be entrusted with personal information as a result of its business activities. When performing activities to administer personal information, the Company will prescribe the work contents based on an agreement or other documentation, and use the personal information under appropriate controls.
2. Proper Control and Safe Retention of Personal Information
   The Company will retain personal information under strict control and will seek to keep the details of personal information it retains accurate and up to date, within the scope necessary to achieve its purposes of use. In addition, the Company will implement appropriate data security measures and corrective actions to prevent unlawful access to, loss, destruction and falsification of personal information. The Company will conduct timely audits of the effectiveness of its data security measures.
3. Observance of Laws, Regulations, Etc.
   The Company and its employees will observe all laws and other regulations concerning personal information
4. Establishment and Continuous Improvement of a Personal Information Protection Organization
   The Company will prepare rules, policies and other guidelines to protect personal information, establish a management position and designate a personal information protection manager. The Company will strive to continuously improve these measures.
5. Response to Complaints and Consultations
   If a complaint or a request for a consultation arises concerning personal information in the possession of the Company, from the person in question or the person's representative, the Company will respond promptly after confirming the identity of the person in question. Please use the contact information below for complaints or consultations regarding the Company's handling of personal information.
   ��107-0062
   8F Minami Aoyama First Building, 7-8-1 Minami Aoyama, Minato-ku, Tokyo
   Ashley Associates   Attention: Personal Information Protection Manager
   TEL: 03-5469-2869
   E-mail: privacy@ashleyassociates.co.jp

Administration of Personal Information

• Purposes of Use for the Company's Business

  The Company retains personal information to conduct the following business operations:

  • Strategy development
    Improvement of interactive strategies, best practices case studies, user analyses, performance evaluations and customer loyalty
  • Implementation and operation services
    Website-related design, Web hosting, brand/company website development, promotion of online sales, e-commerce, translation job , customer database management, e-mail marketing and newsletter publication
  • Backup and other support of Japan performances by the London theatrical company ITCL
  • Report to, conduct business discussions with, conduct meetings with and perform agreements with its customers
  • Respond to inquiries from customers
  • Select and hire employees, manage job applicants and report to employees
  • Manage employees
    
    
• Discretionary Provision of Personal Information

  When the Company has asked the person in question to provide personal information, the provision of the Personal Information from the person in question to the Company is discretionary. When such personal information is not received however, in some cases it may become impossible for the Company to provide its services.
  In addition, in some instances this might interfere with administrative activities related to selection for employment.

Cookies
This website uses cookies for some purposes. “Cookies” are information our web server sends to a visitor's browser. The term refers to the technology to send and store small amounts of information on a visitor's computer when someone accesses the Company's website. The information stored in the cookie is restricted to information that does not identify the individual, such as the session ID. If you do not wish to accept the cookie, you can change the settings on your browser. In some cases, however, this may prevent you from receiving certain services.

Access Log to This Website
The Internet Protocol address used when the computer the customer uses connects to the Internet is recorded. The Company may use this information to prevent unlawful computer access and respond when such access is detected, and to identify and solve the cause of problems that occur with the server. The Company uses this information only to control and operate this web site appropriately and safely, and does not use the information to relate IP addresses to customers' personal information.

Administration of Personal Information for Employment Selection

Ashley Associates (“the Company”) seeks to control and protect personal information received from applicants for selection for employment based on the following policies. We request that individuals submit their application only after they have read and understood the contents and consent to these policies.

1. Purposes of Use
   • The Company uses information such as name, sex and date of birth to identify applicants for employment.
   • The Company uses contact information such as telephone number, e-mail address and mailing address to respond to inquiries concerning recruitment and inform applicants of interview dates and other relevant matters.
   • The Company uses names or information that can identify an individual or information such as employment history and qualifications for personnel and human resources management after an individual has been hired.
2. Provision of Personal Information
   The Company does not disclose, provide or entrust to third parties the personal information of individuals who apply for employment unless the Company has obtained the applicants' consent, except in the situations described above or when required by law. From time to time, however, the Company may disclose the contents of applications without applicants' consent, within a scope that does not violate related laws, when requested by a government agency to disclose personal information based on lawful procedures.
3. Discretionary Provision of Personal Information
   Providing personal information to the Company is discretionary. When such personal information is not provided to the Company, however, in some instances this might interfere with the administrative activities related to employment selection.
4. Notification of the Purpose of Use for Personal Information
   You have the right to request notification of how your personal information is being used. If you require this notification, please contact the Personal Information Protection Manager.
5. Disclosure, Correction, Addtion and Deletion of Personal Information
   Applicants for employment have the right to request disclosure of their own personal information, and the right to demand corrections to or deletions of their personal information. When such action is required, please contact the Company's personal information manager. For details on the procedure please refer to “Inquiries Concerning the Disclosure, Correction, Addition and Deletion of Personal Information”.
6. Right to Refuse the Use or Offering of Personal Information
   You have the right to request that the use of your personal information be terminated, that it be deleted, or that it no longer be offered to third parties. If these actions are required, please contact the Personal Information Protection Manager.
7. Disposal of Personal Information
   When the Company has decided to not hire an applicant as a result of the employment selection process, the Company will retain the personal information received from the applicant for a specified period of time, then dispose of the information using an appropriate procedure.
8. Inquiries Concerning Personal Information
   Please use the contact information below for inquiries regarding the Company's handling of personal information.Inquiries Concerning the Company's Administration of Personal Information
   ��107-0062
   8F Minami Aoyama First Building, 7-8-1 Minami Aoyama, Minato-ku, Tokyo
   Ashley Associates   Attention: Personal Information Protection Manager
   TEL: 03-5469-2869
   E-mail: privacy@ashleyassociates.co.jp
   

 Inquiries Concerning the Disclosure, Correction, Addition and
Deletion of Personal Information

1. Individuals Who May Submit Requests

• Person in question
• A representative who has been entrusted by the person in question
• Lawful representatives of minors and adult guardians

2. Format for Requests
When submitting a request, please enter the appropriate information on the Request for Disclosure Etc. of Personal Information form. The form is available in the following PDF file format.

Request form format (PDF file: 17 kb)
Title: Request for Disclosure Etc. of Personal Information
Acrobat Reader5.0 or later version

3. Request Procedure
As a rule, all requests must be submitted in writing. Please submit the required documents by regular mail.

Required documents

1. Request for Disclosure Etc. of Personal Information
2. Copy of an identification card issued by a public institution, for verification of personal identity.
   One copy of a driver's license, passport, pension book, health insurance card, alien registration, etc.
   Note: When the document contains information on registered domicile, please black out such information
   
   When a request will be made by a representative, the following documents are required in addition to the above.
   
   
3. Power of attorney
   The format is discretionary. However, the document must include the authentic signature, seal and address of the person in question and the representative's name and address.
4. Copy of the representative's identification card issued by a public institution
   One copy of a driver's license, passport, pension book, health insurance card, alien registration, etc.
   Note: When the document contains information on registered domicile, please black out such information

The Company may contact individuals by telephone or other means to verify personal identity.

4. Replies to Requests
The Company will reply in writing concerning the personal information within approximately two weeks after being able to verify personal identities. To prevent the leak or loss of personal information during mailing, the Company will utilize "Restricted Delivery Mail Service" to forward its response. Depending on the details of the request, however, on some occasions the Company may not be able to respond within the time limit indicated above.

5. When the Company Cannot Accept a Request
The Company cannot accept requests in the following cases. Your understanding is appreciated.

1. When it cannot verify the identity of the person in question or the representative.
2. When documents are incomplete.
3. When there is a potential for endangering the life, physical well being, property or other rights and interests of the person in question or a third party.
4. When there is a potential for causing a significant obstacle to the proper implementation of the Company's activities to administer the relevant personal information.
5. When responding would violate a law.

6. Administration of Personal Information obtained concerning a request
The Company does not use personal information obtained based on a request for activities other than disclosure, deletion and correction of information in its possession. The Company will retain the Request for Disclosure Etc. of Personal Information in its possession for three years after responding to the request. The Company will dispose of all documents used for personal identification at the point it time it has completed its response to the request.

7. Inquiries Concerning Personal Information
Please use the contact information below for inquiries regarding the Company's handling of personal information.
��107-0062
8F Minami Aoyama First Bld. 7-8-1 Minami Aoyama, Minato-ku, Tokyo
Ashley Associates   Attention: Personal Information Protection Manager
TEL: 03-5469-2869
E-mail: privacy@ashleyassociates.co.jp

8. Certified Personal Information Protection Organization Complaint Consultation Office
Ashley Associates is registered as and “eligible company” under Japan Information Processing Development Corporation, which is authorized as a Certified Personal Information Protection Organization based on the provisions of Article 37 of the Personal Information Protection Law. Although the Company has established an inquiry desk concerning personal information, if you have questions or complaints regarding the Company's response that you believe must be resolved, or if you are uncertain about how the Company handles personal information, please contact the following office directly.

• Where to apply to seek resolution of a complaint

Japan Information Processing Development Corporation
Privacy Mark Promotion Center
Personal Information Protection Complaint Consultation Office
Address: Kikai Shinko Kaikan Building, 3-5-8 Shibakouen, Minato-ku, Tokyo, 105-0011
TEL: 03-5776-1379 / Free Dial: 0120-700-779