Privacy Policy of IMPACT Inc.

IMPACT Inc. (hereby, "we") fully understands that protection of personal information and personal rights is a task that relates to the company's social responsibility. We strictly obey any related rules and regulations and will conform this Privacy Policy below upon establishing our personal information management (privacy policy, related regulations and documents such as manuals) and having our employees fully understand the above to handle any acquired personal information.

1. Definition of Personal Information
We define "personal information" as Personal Identifiable Information, hereby “PII” (e.g. name, birthday etc.) or any information that can be linked to a particular person (e.g. Email/mailing address, bank account info, age etc.)

2. Particularized use of PII
We will limit the usage of PII only to a particular purpose or course.

①PII of personal clients
In relevance of any event information within our business duties
In relevance of any consultation and inquiries within our business duties
In any relevance of surveys conducted within our business duties
②PII of shareholders
・Any act in relevance of exercising of legal rights or fulfilling of legal obligations legal
・Any act in relevance of various beneficial programs (Shareholder benefits etc.)
・Any act in relevance of implementation of measures (Surveys etc.)
・Any act in relevance of shareholder management in accordance to related laws (Shareholder database etc.)
③ PII of any person related to any business associates
・Any necessary business associated contacts or negotiations
・Clients’ information management, payments and income amortization etc.
④ PII obtained from consignments of business associates
・Execution of any contract that is consigned by a business associate
⑤ PII related to recruitment or retirement
・Provision of recruit information to applicants
・Human resource management
・Provision of information in response to inquiries of retirees and etc.

3.Restricted PII use
At IMPACT Inc., we will not handle PII without authorization of the person or go beyond extent of its necessity. This also applies to cases of a merger no PII will be handled without personal authorization or if it is beyond its extent of necessity pre-merger unless
① when the law states otherwise.
② under the circumstance when personal life assets need to be protected and obtaining authorization from the person is difficult.
③ under the circumstance of a public health improvement or promoting of children’s healthy upbringing and obtaining authorization is difficult.
④ under the circumstance that such authorization would likely hinder disruptions to subcontractor that is cooperating with national government body, or regional public body, or when the consignee is performing a legal act.

4.Retrieving of PII
At IMPACT inc., we DO NOT retrieve personal information by any inappropriate means. Furthermore, upon termination of employment contract, we will be responsible to dispose PII upon the person’s consent.

5.Notice on the usage of PII upon retrieving
The purpose of the use of PII will be informed of, or publicly announced, whenever PII is retrieved unless:
① under the circumstance that there is a possibility that life, assets or other rights of the person, or any third party, would be exposed to danger if this notice is served.
② under the circumstance that the right and rightful profits of IMPACT Inc, would be violated if this notice is served.
③under the circumstance that the serving of such notice would likely hinder disruption to INPACT Inc, when cooperating with a national government body, or a regional public body, or when we perform a legal act.
④ under the circumstance that the purpose of use of PII is deemed as obvious based on the actual situation.

6.Change of purpose of PII use
Any change of purpose of use of PII that is related to the terms pre-change and is deeded as rational, will be informed of, or officially announced.

7.Safety management of PII and supervision of employees
We will put in our best effort to prevent any leakage, loss or damage of PII by limiting PII data access to authorized personnel only and enforcement of password security. Furthermore, documents that contains PII will be safekept in lockable cabinets or vaults and will be shredded to be disposed once usage period expires.

8.Supervision of subcontractors
When handling PII (all or part of) is subcontracted, subcontractors are to sign up a contract hence obliged to agree with nondisclosure terms plausible in such contract and will be supervised pertinently if necessary.

9.No PII will be disclosed to a third party without the authorization of the person unless
① the law states otherwise
② under the circumstances that personal life or assets is under threat and needs to be protected when acquisition of the person’s authorization is deemed difficult.
③ under the circumstance of a public health improvement or promoting of children’s healthy upbringing and acquisition of the person’s authorization is deemed difficult
④ under the circumstance that such authorization would likely hinder disruption when we cooperate with a national government body, or a regional public body, or perform a legal act.
⑤ under the circumstance when PII being processed as statistical data is in an unidentifiable state.
⑥ under the circumstance that the below has been informed of, or announced officially beforehand:
A)when data disclosure to a third party is mentioned in the purpose of use
B)when it is included in the data provided by a third party
C)When the means of how PII is provided to a third party has been revealed.
D)when provision to a third party is to be ceased upon request of the person unless under the below circumstances that the definition of “a third party” mentioned above will not apply:
(i) when IMPACT Inc, necessarily subcontract the handling of PII, be it all or part of, to achieve purpose of use.
(ii) when PII is passed on during a merger or other activities that involves business succession.
(iii) when the person is aware of, or has been informed of beforehand, the name of the person who is in charge of info management should PII be shared with particular personnel that are responsible for the shared PII with knowledge of who and why such PII is shared. Meanwhile, should there be any change in the purpose of use or change of person in charge, we will inform the person regarding the change or keep it in a knowable state when PII is being shared with particular personnel.

9.Providing and sharing of PII with a third party
We may provide, or share, PII with associates mentioned below. These associates are bound by contract that includes terms of nondisclosure and will be supervised for safe PII management.
① Provider or shared user: IMPACT Inc,
② Reason to share: to make subcontracted business with associates smooth
③ Purpose of shared use: See item 2: Particularized use of PII
④ Items to be provided or shared: restricted to necessary info that help performing tasks of subcontracted business

10. Official announcements of matters regarding PII
We will keep the PII related matter mentioned below in a knowable state and will not be hesitant in replying should the person makes a request.
① The purpose of use (expect when this obligation is exempted by laws regarding PII protection. We will also reply the inquirer ASAP even when legitimate rejection to answer is in order.)
② Setting up of point of contact regarding PII inquiries

Contact IMPACT Inc,
toiawase@impactinc.co.jp
PII management person-in-charge Akihiko Seimiya
〒150-0011
3-20-4 Higashi, Shibuya, Tokyo
Tel. +81-3-6419-7546 Fax. +81-3-6419-7596
Operation Hours: 10:30~18:00(Closed on Sat, Sun and PH)

11. Disclosure of PII
We will disclose PII immediately to the person should we be requested so. However, should any of the below situations occur by disclosing the PII, there is a possibility that only part of or none shall be disclosed and a notice with such regard will be served.
① when there is a possibility that our employee or a third party’s personal life, assets or other rights are endangered
②when there is a possibility to cause an obvious disruption in fulfilling obligated tasks.
③ when it contradicts other laws

12. Amendments of PII
We will correct and make amendments in the contents of PII only when the person confirms the info is false and requests correction or amendment unless certain prescribed procedures are applicable. Necessary investigations will be carried out to authenticate if it is necessary for the purpose of use and based on the result, amendments will be made and the person will be informed.

13. Cease of use
When being requested by the person whose PII, according to the very person, has been used other than the pre-stated purpose of use, or forged, or obtained by illegal means, to cease use of or erase PII, investigations will be carried out and based the result of which use of PII use will be ceased and the person will be informed. However, other alternatives should be made available in order to protect the person’s rights under the circumstances that cease of use would be difficult due to possible occurrence of costly expenses if use of PII is ceased.

14.Explanation of reasons
We, being requested or not, will try to give explanations to the person when the below has been confirmed:
① No notice will be served about purpose of use
② Only partial disclosure or no disclosure
③ No ceasing of information provision to a third party

15.Disclosure of our PII
Procedures for acquiring notice on purpose of use, disclosure, correction and cease of use will be as follows:
① applicable person for requesting a disclosure
・ the person himself/herself
・ when the person is not of legal age or incompetent, his/her attorney
・ the person’s assigned representative upon requesting of the disclosure
② Documents required for disclosure request
(when applicant is the person himself/herself)
・ Application form for disclosure of PII recognized by IMPACT Inc,(only registered seal allowed)
・ Documents of personal authentication
・Certificate of registered seal
(When applicant is the person’s attorney)
・ Application form for disclosure of PII
・ Documents of personal authentication(each for the attorney and the person)
・ Letter of attorney (recognized by IMPACT Inc,)
③ Point of contact for requesting PII disclosure
Please mail to the address below:

Contact IMPACT Inc,
〒150-0011
3-20-4 Higashi, Shibuya, Tokyo
Tel. +81-3-6419-7546 Fax. +81-3-6419-7596
toiawase@impactinc.co.jp

④Charges for requesting a disclosure
¥1000 per request for disclosure of PII or purpose of use.
 Please include a stamp for returning postage, or anything equivalent in the envelope.
⑤ Miscellaneous
We will reply in written notice within reasonable time once we have confirmed the authenticity of the inquirer’s personal info.
Explanations will be given even if inquiry did not go through.

IMPACT Inc,
CEO: Akihiko Seimiya
Enactment: Mar. 4, 2010
Last revised: May 1, 2017