Handling of Personal Information

1. Acquiring of Personal Information and Purposes of Use

IR Japan, Inc. (“the Company”) acquires and uses personal information within an appropriate scope, in accordance with the following purposes of use. When the Company uses personal information for the purpose other than the ones as defined below, it will notify following parties of these purposes and other necessary matters in laws, and it will obtain their consents:

Personal Information of Institutional Investors and Persons in Charge of Proxy Voting

• To notify listed companies’ financial results briefings or IR meetings, and to manage applications for these meetings
• To provide institutional investors and persons in charge of proxy voting with useful information such as the Company’s services and IR information of publicly-traded companies
• To respond to inquiries, opinions, and requests
• To improve qualities of the Company’s services and to provide these services
• To develop the Company’s services and to create new products by conducting market research, data analysis, and questionnaire surveys
• In regards to businesses attendant to foregoing purposes, the Company provides its useful services for institutional investors and persons in charge of proxy voting for the purpose of appropriately and smoothly encouraging companies to conduct engagements with shareholders

Personal Information Provided by Publicly-traded Companies (entrusters)

• To perform tasks entrusted by them

Personal Information of Clients Pertaining to Financial Instruments Handling Business

• To keep records that include personal information in accordance with laws and regulations and to manage IR Japan’s transaction track record, etc.
• To provide information regarding various businesses (*) and to make financial instruments proposals
• To confirm the identity of persons in question in accordance with laws and regulations, etc. and to confirm the qualifications, etc. of clients for using financial services
• To manage dates and other information for ongoing transactions in various businesses
• To make decisions upon clients’ continued use of various businesses
• To exercise rights and fulfill obligations in accordance with contracts and laws based on contracts of applicants, etc. and laws
• To make decisions according to the principle of suitability, etc. and other decisions on the appropriateness of providing various businesses
• To grasp and manage various risks and, in other ways, to facilitate transactions with applicants, etc.
• To use the Individual Number (“My Number”) in preparing and providing statutory documents relating to financial instruments transactions in accordance with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures

* “Various businesses” refer to the following three businesses:
1) Public offering, secondary distribution and brokerage of securities and business incidental thereto
2) Financial advisory business and business incidental thereto
3) Arrangement of capital increase through third-party allotment and business incidental thereto

Personal Information Regarding Job Applicants

• For employment screening in recruitment

Personal Information Regarding Employees

• For employment management

Other Personal Information

• Personal information of candidates for outside directors in the Company’s service : Independent Outside Director Search
  To introduce or select outside directors in the Company or entrusters
• Personal information of the Company’s contractors (refer to 4. “Entrustment of Personal Information”)
  To perform the Company’s businesses smoothly and appropriately

2. Provision of Personal Information to Third Parties

Personal information the Company obtains is not provided to third parties, except for ones the person consents to providing whose personal date is in the Company’s possession, and for cases in accordance with the provisions of laws and regulations.

3. Disclosure, etc., of Personal Information

In the event of individuals’ requests whose personal information is in the Company’s possession, we will respond to these requests, and we will notify and disclose the purposes of use. Also, we will revise, add or delete contents of personal information, discontinue their use, or discontinue providing to third parties. For complaints and consulting about other matters regarding personal information, please contact the person in charge of handling complaints and consulting regarding personal information (9. Inquiries Related to the Protection of Personal Information).

4. Entrustment of Personal Information

Within the scope of its purposes of use, the Company is entitled to entrust personal information to contractors who have signed agreements in taking obligatory measures to appropriately manage personal information by prohibiting subcontracting and taking measures to ensure preventing information leakage.

5. History Information

The Company’s website records information of your browsing history. Such information does not include personal information, and is not used for any purposes other than ascertaining the usage status of the website.

6. Voluntary Provision of Personal Information

Provision of personal information is voluntary. Please note that if the information is not provided the Company is entitled not to provide the Company’s services.

7. Management of Personal Information and Safety Measures

The Company will strive to ensure correctness and safety of personal information by implementing appropriate and rational safety measures against improper access to the information or threats of loss, theft, falsification, or leakage of the information. Also, so that the Company prevents subcontractors from using personal information for unintended purposes and from leaking personal information, the Company will implement proper measures such as developing/improving information management system, developing internal rules, educating employees, and monitoring subcontractors. In the event that a problem occurs, the Company will strive not only to keep the damage at a minimum but also to implement corrective measures immediately.

8. Continuous Improvement of Personal Information Protection Management System

To properly keep personal information, the Company has established Personal Information Protection Management System and will strive to monitor its operation regularly and to improve continuously.

9. Inquiries Related to the Protection of Personal Information