Personal Information Protection Policy

Enacted on September 26, 2018

QOLead, Limited (hereinafter referred to as the “Company”) places its first priority on earning trust from its customers; and observes the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”), Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter referred to as the “Code Act”), related laws, guidelines, and other codes stipulated by the government, to ensure the protection of personal information.

1．Purpose of use of personal information

(１)Purpose of use of personal information

Personal information shall be used to the extent necessary to achieve the following purposes of use and shall not be used for purposes other than these:

① Personal information obtained in association with entrusted business

(i) Providing services in the area of elderly healthcare
(ii) Operating entrusted development of services
(iii) Providing information related to the Company’s work/operational management, and enhancement of products/services
(iv) Work related to/accompanied by the above

② Personal information obtained through opportunities other than entrusted business

(i) Various business contacts, meetings, managing customer information, handling inquiries, etc.
(ii) Providing/notifying of employment opportunities to applicants
(iii) Employment, accounting, and general affairs administration of the Company
(iv) Work related to/accompanied by the above to execute other duties

（２）Notwithstanding the previous item, specific personal information including personal numbers stipulated by the Code Act (hereinafter referred to as the “Personal Number”) shall be used to the extent necessary to execute the following tasks and shall not be used for purposes other than below even if a person has given consent.

① Preparation of payment records of remuneration, fees, contacted amount, and prizes/li>
② Preparation of payment records on real estate transactions/li>
③ Other duties related to ① and ② above

（３）These purposes of use shall be posted on the Company’s website and be available when such information is obtained from the person directly in writing.

2．Types of personal information obtained and held

Personal information the Company obtains and holds, shall be personal information necessary to achieve the purposes of use in the previous item, including name, address, date of birth, sex, occupation, health status, company/group of affiliation, contact address/telephone number/email address, and Personal Number.

3．Method of obtaining personal information

Proper methods shall be used to obtain personal information in line with the Personal Information Protection Act, the Code Act, and other related laws and regulations.

4．Provision of personal information

（１）The Company shall not provide personal information to outside sources except for the following cases:

① When the person consents to such use
② When the use is legally obligatory
③ When some tasks are commissioned, to the extent necessary to achieve the purposes of use
④ When the provision of such information is authorized in accordance with other personal information protection laws.

（２）Notwithstanding the previous item, the Company shall not provide specific personal information to outside sources unless it is authorized by the Code Act.

5．Protection and control of personal information

The Company shall strive to ensure that personal information is accurate and updated. To obviate and take corrective actions for the leakage, loss, and damage of personal information, the Company shall take measures, as necessary, for managing organizational security, human security, physical security, and technical security to continuously improve personal information protection management system. The Company shall also select a “Legal compliance leader” to ensure promotion of the proper control of information and to work toward the protection of personal information.

6．Requests for disclosure or correction of personal information

If the disclosure or correction of personal information is requested, the Company shall promptly respond to such request after confirming the requester’s identification unless there are special reasons that may significantly hinder proper execution of duties.

7．Review of personal information protection policy

To ensure proper protection of personal information, this policy shall be reviewed in consideration of environmental changes.

8．Inquiries on handling of personal information

For any questions or requests regarding the handling of personal information, please contact Customer Service shown below. The Company shall be available to address inquiries and take measures promptly if any complaints are filed or consultation is requested regarding the personal information the Company retains.

Customer Service

QOLead
Person responsible for personal information control
General Affairs and Planning Unit
03－3797－0916
(9:00-17:00, Monday to Friday, except public holidays)

QOLead, Limited
Yasumasa Iwai,
CEO