HANDLING OF PERSONAL DATA

The collection, use, and protection of personal data by BayCurrent Consulting, Inc. (hereafter referred to as “BayCurrent”) shall be in accordance with the following policies.

1. DEFINITION OF PERSONAL DATA

In accordance with the Personal Information Protection Act, BayCurrent defines personal data as information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual. This includes, but is not limited to, name, birthdate, and other descriptions, personal identifications numbers, signs, symbols, images, audio, and so on.

2. PURPOSE OF COLLECTING PERSONAL DATA

BayCurrent collects and uses personal data in accordance with the following:
1. We may request personal data from our clients in order to better provide consulting services to them.
2. To provide consulting services and/or information related to consulting services.
3. We may request personal data from our clients in order to respond to their requests or inquiries.
4. We may request personal data from applicants to seminars or events sponsored by BayCurrent.
5. For reference when carrying out recruiting activities.
6. To perform minimum basic day-to-day human resources and employee management operations within the company.

3. USAGE OF PERSONAL DATA

a. Use within BayCurrent In accordance with the above, BayCurrent may make use of client data, including personal data, as part of its business operations.

b. Disclosure to Business Partners and Contractors
When necessary, BayCurrent may provide personal data to its business partners, including contractors. In such a case, only the minimum amount of information necessary to accomplish the task will be shared. Business partners and contractors will be required to manage personal data in accordance with BayCurrent’s policies.

c. Disclosure of Information to Third Parties
BayCurrent will not disclose your information to any third parties without your express consent, except in the following circumstances:

ⅰ To comply with any law, regulation or legal request.
ⅱ To protect human life, health, property, or other such vital interests.
ⅲ To protect the public interest.

However, there may be situations where BayCurrent is required to disclose some minimum amount of personal data to outside parties in order to conduct business. Every effort is made to minimize the amount of data disclosed. Representatives are required to properly store the personal data and are forbidden from using the information for unauthorized or non-business purposes.

4. COLLECTION AND MANAGEMENT OF PERSONAL DATA

a. BayCurrent collects personal information by fair and lawful means.
b. BayCurrent will take measures to protect information assets from unauthorized access, loss, leakage, and tampering.
c. BayCurrent will appoint a personal data management officer for each project and department. All employees, executives, and project stakeholders will be given education and training to raise awareness and ensure proper handling of personal data. Furthermore, BayCurrent will dispose of any stored personal data that we, at our sole discretion, determine to no longer be necessary.

5. CORRECTION AND REMOVAL OF PERSONAL DATA

Please contact us using the information below with requests to correct or delete personal information. We will respond in a timely manner upon confirmation of the inquirer’s identity.

6. CONTACT US

Please direct all individual inquiries to:

BayCurrent Consulting 〒105-6309
Toranomon Hills Mori Tower, 9th floor
23-1, Toranomon 1-Chome
Minato-ku, Tokyo 105-6309
Japan
TEL +81 3 5501 0151
FAX +81 3 5501 0150

Last Revised March 1, 2012

BayCurrent Consulting, Inc.
Chief Executive Officer Yoshiyuki Abe
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