BBSS Corp.a SoftBank group company

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THIS IS A DOCUMENT TRANSLATED INTO ENGLISH TO BE USED AS REFERENCE. THE ORIGINAL LANGUAGE OF THIS DOCUMENT IS JAPANESE. IF TRANSLATED INTO OTHER LANGUAGES, THE JAPANESE VERSION SHALL TAKE PRECEDENCE.

BBSS Corp. (hereinafter referred to as the "Company") strives for thorough compliance with the Act on the Protection of Personal Information (Act No. 57, 2003) and Personal Information Protection Management System - Requirements (JIS Q 15001) and endeavors to execute the following respective items in order to protect personal information.

1.Enhancement of Employee Training

The Company will prepare learning material pertaining to the protection of personal information and distribute the same to all personnel of the Company and dispatched employees, and execute training by making all personnel of the Company and dispatched employees who treat personal information an object at least once a year.

2.Preparation of Internal Regulations pertaining to Protection of Personal Information

The Company will prepare internal regulations pertaining to the Protection of Personal Information, indicate a clear policy pertaining to the treatment of personal information, and make it well known inside the Company that the Company will take a tough stance on personal information leakage, etc.

3.Deployment of Protection Administrator of Personal Information and Enhancement of Function

The Company will deploy a Protection Administrator of Personal Information and assign the Chief Information Security Officer to that post and prepare a system clearing roles to execute compliance with the laws and regulations and guidelines, establishment of internal regulations, preparation of inspection system, supervision of treatment of personal information, and so forth.

4.Implementation of Proper Information Security Measures

The Company will prevent leakage, loss, or damage to personal information; control access to personal information; restrict taking out personal information for safety control of personal information; and take measures to prevent wrong access from outside and other necessary and appropriate measures.

5.Regarding Business Subcontract

The company will work to review and improvement to those further consideration by the protection of personal information. In concluding business subcontracts, the Company will make due check of eligibility for a party to whom the business is subcontracted. In the business subcontract, the Company will prescribe safety control measures, confidentiality, terms and conditions of re-entrustment, and other matters pertaining to the proper treatment of personal information, and appropriately supervise the business subcontractor of the Company by carrying out regular monitoring, etc., on the state of the subcontracted business.

6.Preparation and Enhancement of Inspection System

The Company will prepare a system to inspect the company as to whether the protection of personal information is properly carried out or not.
In addition, the inspection utilizing access log is considered effective to finding out a leaker of personal information and prevent leakage by exerting a deterrent effect thereof, and the Company will study an execution method of such inspection.

7.Proper collection, Use, Provision, and Publication of Personal Information

In use, provision and publication of personal information, the Company will consider contents and size of business and properly execute the same.
In addition, the Company merged with License Online, Ltd. (hereinafter referred to as "License Online") on April 1, 2010, and has since continued the business of said company including personal information related to the business of License Online. Personal information obtained by License Online prior to the merger is used only to the extent necessary to accomplish the usage purpose defined prior to the merger. Additionally, since April 1, 2010, information on collection, use, provision, and publication of the personal information of customers using the Company's "License Online Business" services (hereafter referred to as "License Online Services") is listed in this article and the next. This information is handled appropriately in consideration of the content and scale of the business.

1)Usage purpose of personal information
  • <1> Answering to queries and provision of goods, services, work, etc. Customer Support provision of guidance and information on the procedures with respect to use of the co-users of the service
  • <2> Calculation of usage fee
  • <3> Usage fee billing
  • <4> Marketing research and analysis.
  • <5> Notification of Company’s and/or other companies’ commodities, services and campaign, etc.
  • <6> In addition, the duties that are necessary for the offer of Company's service

In the event the Company uses the personal information concerned for other than the above purposes, the Company will make usage purpose clear every time, and obtain the prior consent from customers.

2)Joint Use

The Company aims at provisions of IT logistics service and uses personal information jointly as follows.

a.The parties who use personal information jointly with the Company:

  • <1> SoftBank Corp.
  • <2> Group companies of the Company

b.Personal information to be used jointly:

This includes all customer personal information obtained by the Company during application or use of the service, such as user IDs, names, addresses, e-mail addresses.

c.Purpose of joint use.

  • <1> Answering to queries and provision of goods, services, work, etc. Customer Support provision of guidance and information on the procedures with respect to use of the joint-users’ service
  • <2> Calculation of usage fee
  • <3> Usage fee billing
  • <4> Marketing research and analysis.
  • <5> Notification of Company’s and/or other companies’ commodities, services and campaign, etc.

d.Protecting manager of personal information used jointly:Chief Information Security Officer of the Company.

  • (1)Clarifies usage purposes each time the personal information of Company employees is collected.
  • (2)Clarifies usage purposes each time the personal information of individuals other than Company customers (such as business connections) is collected.
  • (3)In the event that the Company is requested by the person concerned personally to notify or disclose the purpose of use of or revision of the personal information that the Company receives from the customer, the Company will answer to it in writing (if the person consents to the other means, the Company may answer to it by such means).
    At the time of the said answer, the Company may claim the charge within a reasonable extent taking the actual cost into account.
  • (4)With regard to inquiry by the person concerned about disclosure, revision or the like of personal information which the Company receives from the customer and complaint about treatment of the said personal information, please present the same to the following contact.
    Email:bbss-privacy@bbss.co.jp

8.Continuous Improvement of Action pertaining to Protection of Personal Information in License Online Services

Information in this section (such as proper collection, use, provision, and publication of personal information) is updated periodically as needed. Please confirm periodically.

1.Customers Using the Symantec Online Service

The Symantec Online Service is a security service managed by the Company itself or on behalf of a service partner of the Company.

1)Personal information to be used

In addition to names, e-mail addresses, telephone numbers (including mobile telephone numbers) and credit card information, this includes all customer personal information obtained by the Company during application or use of the service, such as IP addresses, types/versions of browsers, operating systems, platforms, information related to website browsing and information obtained using cookies.

2)Usage purpose of applicable personal information in Company use and joint use

  • <1> Usage fee billing
  • <2> Changes to usage fees/service offerings
  • <3> Confirmation of usage
  • <4> Software downloading
  • <5> Issuance of PIN numbers
  • <6> Customer support
  • <7> Marketing to improve services
    • a. The parties who use personal information jointly with the Company
      Service partners, software manufacturers, download data management companies, credit card companies, delivery agencies, affiliated companies and subcontractors
    • b. Provision of personal information used jointly
      All or part of personal information listed in 1) of this section. In addition, the Company will not provide customer personal information it has collected without consent of the individual to third parties other than service partners, software manufacturers, download data management companies, credit card companies, receiving agencies, affiliated companies and subcontractors. However, this excludes cases where consent has been obtained; there is a pressing legal reason; or there is a need to protect human life and limb or property, and it would be difficult to obtain consent.

2.Customers Using Licensing Services Other than the Symantec Online Service

3)Personal information to be used

This includes all customer personal information obtained by the Company during application or use of the service, such as user IDs, names, addresses, e-mail addresses (including mobile telephone e-mail addresses), company names, group names, division names, positions, locations of places of employment, other information on places of employment, birth dates, gender, age and sales store information name.

4)Usage purpose of applicable personal information in Company use and joint use

  • <1> Estimation of software licenses (total software license products, total software package products, installation media and manuals) appropriate for the license system handled by the Company
  • <2> Creation of suitable content for users
  • <3> Provision of information concerning upgrades, special promotions, new information and new services for software licenses
  • <4> Telephone and e-mail surveys conducted with the objective of improving products and services handled by the Company, increasing website convenience, and running promotions according to user needs.
  • <5> Enhancements and improvements to products and services according to user needs
  • <6> Provision of special information that could be of interest to users
  • <7> Consent when purchasing/downloading products, accessing services and participating in other activities
  • <8> Searching for important software, service and product information
  • <9> Shipping of ordered products
  • <10>Confirmation of participation in seminars and events, issuance of license certificates and communication related to license update procedures
  • <11>Answering queries
  • <12>Provision of after-sales service
  • <13>Gift lotteries and merchandise shipping
  • <14>Usage related to mobile telephones by affiliated companies, such as explanations, contracts and shipping products
  • <15>Support (information provision, product guidance) requested by customers
    • a.The parties who use personal information jointly with the Company
      Sales partners, software manufacturers, affiliated companies and subcontractors
    • b.Provision of personal information used jointly
      All or part of personal information listed in 1) of this section. In addition, the Company will not provide customer personal information it has collected without consent of the individual to third parties other than sales partners, software manufacturers, affiliated companies and subcontractors. However, this excludes cases where consent has been obtained; there is a pressing legal reason; or there is a need to protect human life and limb or property, and it would be difficult to obtain consent.

5)Protection administrator of personal information responsible for license online services (including Symantec Online Service; the same shall apply hereafter)

Chief Information Security Officer of the Company.

6)Management of personal information in License Online Services

Members may at any time confirm their profiles and update their information, with regard to personal information concerning License Online Services.

  • <1> Member profiles
    Members may view and edit their registered personal information on the Registration Information Modification Screen.
  • <2> Registered information
    Information that is registered is used on websites related to the License Online Services managed by the Company. Company will determine if the registration was completed when new profiles are created or when existing profiles are modified. If registration was completed the personal authentication number that was already assigned will be used; if registration was not completed a new number will be created.
    When stopping usage of License Online Services with registered information, users may arrange to stop use or delete information by contacting the Company.
    Additionally, the Company may delete registered information that the Company has determined to be inaccurate.

7)"License Management" service

The Company's "License Management" service manages information on license certificates purchased online using License Online Service and license certificate information customers have registered online. We use information related to these license certificates to show suitable pricing information and to provide information to customers using license products, such as showing discount pricing for additional or upgrade license products and contacting customers when renewable license products have expired. This information can be verified at any time as information belonging to the customer and services can be used with regard to any of the over 4,100 sales partners using License Online Services.

9.Usage of Cookies

1)Usage of cookies

Cookies are extremely small text files that websites save to customer hard disks, and that include personal information and settings provided by customers using these websites. Some websites maintained by the Company use cookies each time a user logs in. These websites encrypt and store unique IDs and sign on times to the hard disk of the customer's computer.
The Company may also use cookies to make it easier for customers to log into the websites it manages. For example, cookies can be configured to store a customer's e-mail address and to retain that information even after the customer logs out. The next time the customer logs in, the e-mail address will be entered automatically, and he or she needs only to enter his or her password.
Users can also place a check in "Login automatically from now on". Doing so will cause the cookie to log in when the website is accessed so that the user does not need to enter his or her password each time. When customers log out from a website that uses cookies, these cookies are stored on his or her computer. However, the Company does not use cookies to identify or differentiate customers.

2)Disabling cookies (opting out)

Cookies used on websites managed by the Company are used only for the purposes defined in 1) and 3) of this section. They are never used for other purposes or to collect personal information. These cookies can be disabled in your browser settings. Note that doing so may render some services provided by the Company unusable.

3)Collection and use of attribute information/behavior history that does not identify individuals

Company websites use programs provided by advertising vendors to conduct behavior marketing (a method of advertising in which advertisements that suit customer interests/tastes are delivered based on website browsing information, etc.) on certain sites.

Cookies are used to collect information on customer visits to these websites for this purpose (however, this information does not include anything that could identify or differentiate individuals).

Advertising vendors use said cookies to deliver advertisements based on past access information for these websites.

Customers who wish to disable these advertisements may disable the use of cookies on the opt-out pages of these advertising vendors.

This must be reconfigured if the browser has changed, cookies have been deleted, or the user has switched to a new PC.

Customers may disable the use of Google cookies on advertising opt-out pages (customers may also disable the use of third party distributor cookies on Network Advertising Initiative's opt-out page).

If you do not opt out, Google, third party vendors and advertising network cookies may be used.
Users may disable some (not all) cookies all at once on Network Advertising Initiative's opt-out page.

The URLs of opt-out pages are listed below.

Google opt-out page:
http://www.google.co.jp/policies/privacy/ads/
Network Advertising Initiative opt-out page:
http://www.networkadvertising.org/choices/#completed

10.Continuous Improvement of Action pertaining to Protection of Personal Information

The Company will continuously review and improve actions pertaining to the protection of personal information set forth in the above clauses 1 to 9.

11.Personal Information under This Privacy Policy

"Personal Information" as used in this Privacy Policy means information on individuals regardless of customers of the Company, personnel of the company of business connections and personnel of the Company, and the name, date of birth, and other descriptions included in the said information, or number given to each individual, or other things with which the individual can be identified such as mark, picture, or voice (including the thing with which only an individual cannot be identified but which can be easy reference to other information and the individual concerned can be identified by such reference).
This Privacy Policy is applied to all personal information in the possession of the Company unless otherwise notified.