Personal Information Management Policy

1. Personal information controller

Future Architect, Inc. (hereinafter the "Company") has appointed the following person as its personal information controller responsible for measures necessary for the protection of personal information, such as the formulation, implementation and management of measures as well as their evaluation and improvement.

Personal information controller: Yohei Saito, Vice President

2. Purpose of use of personal information

1. Company and its affiliates collect personal information for the following purposes:
   (i) Personal information of users of IT solution services offered by Company and its affiliates:
   • for use to the extent necessary in accordance with an agreement with customers, for example, the use of personal information of customers or customers' business partners to the minimum extent necessary for developing, servicing and managing information systems, and conducting related services;
   • for use to the extent necessary for offering and suggesting IT solution services of Company or its affiliates and for dispatching invitations for seminars and events of Company or its affiliates; and
   • for use to the extent necessary for the administrative work of Company and its affiliates, such as business communications and business records.
   (ii) Personal information of participants or prospective participants in seminars and events sponsored or co-sponsored by Company:
   
   • for use to the extent necessary for the administration of seminars and events, such as dispatching invitations, processing applications, responses at the venue, and follow-up support after events; and
   • for use to the extent necessary for offering and suggesting IT solution services of Company or its affiliates and for dispatching invitations for seminars and events of Company or its affiliates.
   (iii) Personal information of shareholders of Company and its affiliates (shareholder information):
   • for complying with laws and regulations including the Companies Act and Commercial Code, such as taking procedures, dispatching documents and managing shareholders data as required, and maintaining the compliance; and
   • for implementing measures to facilitate the relationship between Company and its shareholders.
   (iv) Personal information of job applicants of Company and its affiliates:
   
   • selection of employees of Company and its affiliates, and communications necessary for selection; and
   • communications with selected candidates for procedures before joining the company.
   (v) Personal information of alliance companies providing the service for Company and its affiliates:
   • for use to the extent necessary for performing the business of Company and its affiliates, such as business communications and business records; and
   • for use to the extent necessary for Company's security and crime prevention.
   (vi) Personal information of business partners of Company and its affiliates:
   • for use to the extent necessary for the administrative work of Company, such as business communications and transaction records.
   (vii) Personal information of employees and former employees of Company and its affiliates:
   • for use to the extent necessary for employment management, such as personnel management procedures, payroll, work assessment, training, recruitment, job assignment, benefits, safety and health;
   • for use to the extent necessary for Company's security and crime prevention; and
   • business communications with them during or after the employment.
   (viii) Personal information of persons other than the abovementioned who made inquiries with Company:
   • responding to inquiries, making communications and keeping track records of cases.
2. Use of personal information for any purpose not specified in the foregoing paragraph requires consent from you (the data subject) for each instance, excluding the following cases:
   (i) use of information under laws and regulations;
   (ii) where it is necessary for protecting human lives, bodies or property, and where it is difficult to obtain consent from you;
   (iii) where it is specifically necessary for the improvement of public health or healthy and sound child development, and where it is difficult to obtain consent from you; or
   (iv) where it is necessary for cooperating with state or local government agencies or their contracted service providers in their performance of duties under laws and regulations, and where obtaining prior consent from you may adversely affect the duties.
3. The purposes of use of personal data retained by Company are as set out in (i) through (viii) of paragraph I above.

3. Provision of personal information to third parties

1. Company may provide the collected personal information to third parties in the following cases:
   (i) where consent from you is obtained;
   (ii) where it is permitted under laws and regulations;
   (iii) where it is necessary for protecting human lives, bodies or property, and where it is difficult to obtain consent from you;
   (iv) where it is specifically necessary for the improvement of public health or healthy and sound child development, and where it is difficult to obtain consent from you; or
   (v) where it is necessary for cooperating with state or local government agencies or their contracted service providers in their performance of duties under laws and regulations, and where obtaining consent from you may adversely affect the duties.

4. Sharing personal information

1. Company may share collected personal information with third parties in the following cases:
   (i) where Company determines that it is necessary to share information with its affiliates for conducting business, and where you consented to the joint use of the information with the affiliates; or
   (ii) where Company needs to share personal information, such as information collected at co-sponsored seminars, with a third party for conducting business, and where you consented to the data sharing.

5. Entrustment of processing of personal information

1. Company may entrust a third party to process collected personal information, to the extent necessary for achieving the purposes for which the information is to be used.
   (i) For entrusting the processing of personal information, Company will confirm that the service provider maintains a sufficient level of protecting personal information in advance of entering into a service agreement and ensure appropriate monitoring during the period of service entrustment.
   

6. Incidental information

1. Company may collect information that cannot identify the data subject by reference to it alone, such as viewing history of webpages using cookies or IP addresses (hereinafter referred to as "incidental information"), to the extent necessary for business.
2. When providing incidental information to a third party, Company will ensure that the data subject's consent is obtained, except as provided by the applicable laws and regulations, with respect to any incidental information by which the recipient may re-identify the data subject.

7. Management of personal information

8. Consequence of refusing to submit personal information

Company asks you to submit personal information to the extent necessary for conducting business. It is up to your discretion whether to submit your personal information to Company; however, please note that you may not be able to benefit from Company's services if you refuse to submit your personal information.

9. Responding to request for disclosure of personal information

Company will, without delay upon your request, notify the purpose of use of personal information in Company's possession, disclose (including the disclosure of records of data transfer to third parties), correct, add or delete the content of such information, suspend the use of or delete, or terminate the provision of such information to third parties (hereinafter collectively referred to as "disclose" or "disclosure," as the case may be), except as otherwise provided by laws and regulations.

1. Personal information or records of data transfer to third parties to be disclosed are limited to those which Company is authorized to disclose.
2. If you wish to request the disclosure of information, contact Company by any of the following means:
   (i) contact Company according to the contact details and method for requesting disclosure as designated by Company upon the submission of your personal information; or
   (ii) if the contact details are not certain, contact Company by means of (a) a web inquiry form or (b) a request form as set forth below:
   (a) Web inquiry form
   Contact Company via the URL specified in Section 10 below. A staff member will contact you to provide necessary guidance.
   (b) Request form
   Fill in a request form for disclosure of personal information available from the web link (https://www.future.co.jp/architect/policy/PDF/FAI-KaijiShinsei.pdf) and send it to the following address by postal mail, together with attachments as instructed in the request form.
   [Address]
   Future Architect, Inc., Contact for Personal Information Protection
   Art Village Osaki Central Tower
   2-2, Osaki 1-chome, Shinagawa-ku, Tokyo, 141-0032
   We only accept requests for disclosure made by the data subject or an agent acting on his/her behalf.
3. We may refuse to disclose information for any of the following requests:
   (i) a request for disclosure with respect to personal information or records of data transfer to third parties for which Company is not authorized to disclose;
   (ii) a request for disclosure for which Company cannot ascertain that it is a request from the data subject or an agent acting on his/her behalf;
   (iii) a request for the notification of purpose of use, provision, deletion, suspension of use or provision to third parties, that falls under any of the following:
   • where the request involves the risk of having an adverse impact on the life, body, property or any other rights and interests of the data subject or third parties;
   • where the request involves the risk of having a material adverse impact on the proper conduct of Company's business; or
   • where accommodating the request may violate laws and regulations.
   (iv) a request for the correction, addition or deletion of the content for which there is no need to respond, such as a request which is contrary to facts.

10. Contact for inquiry concerning the protection of personal information

1. For any inquiry, consultation or complaints concerning the processing of personal information by Company, contact the following:
   
   Personal information controller: Yohei Saito, Vice President
   Inquiry form (Contact for Protection of Personal Information):
   https://www.future.co.jp/en/contact_us/
   
2. Company is a member of an accredited personal information protection organization. You may lodge an application for dispute resolution with the following organization:
   
   JIPDEC, Personal Information Protection Consultation Service Office
   Address: 12th Floor, Roppongi First Building, 9-9 Roppongi 1-chome, Minato-ku, Tokyo, 106-0032
   Phone number: 03-5860-7565 (toll-free number: 0120-700-779)
   *This is not an inquiry contact concerning services offered by Company.