Link Technology Co., Ltd.
Atsushi Kawai, President

Link Technology Co., Ltd. will observe laws and regulations regarding the protection of personal information, and considering the importance of out clients personal information, we will handle out clients personal information that we collect and manage, according to the following policies to protect personal information.

1. We will observe laws regarding the handling of personal information, JIS (JISQ 15001) and other national guidelines on requirements related to management systems for protection of personal information, and other related rules such as guidelines of local authorities and industry organizations.
2. We have established optimal and appropriate rules for handling of personal information and have made them into internal regulations with full understanding and recognition of how the personal information made available to our businesses is handled, taking stock of the contents of agreements with customers and their requirements, and we will observe these internal regulations in the collection, use, provision, etc. of personal information.
3. We have stipulated within internal regulations that we will not use or provide personal information to third parties outside the scope of the specified purpose of use. We will deter use outside the intended purpose by clarifying the procedures for use of personal information and will prevent incidents by engaging in such efforts as thorough management of access privileges.
4. Recognizing and analyzing the risk of leaks, loss or manipulation of personal information, we have formulated measures to prevent and correct such things in order to take appropriate steps according to the importance of personal information. Additionally, by reflecting these measures in internal regulations, we have clearly specified the measures to be implemented and given them shape
5. We fully respect the rights of the individual with respect to their personal information. We have established and opened a point of contact to handle complaints, inquiries and requests for the disclosure, correction, discontinuation of use, etc. of personal information and will respond promptly, efficiently and safely.
6. In order to achieve optimal protection of personal information, including the items above, we will maintain, promote and review our management system for the protection of personal information on an ongoing basis and will make improvements as necessary.

Effective as of August 1, 2011

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Handling of personal information

Link Technology recognizes the importance of protecting personal information in an advanced information and communication society and believes that safely and properly handling the personal information of all those with whom we interact, from our customers and the representatives of our business partners to our employees, is an important social responsibility.

We have developed a management system to protect personal information based on our privacy policy in order to properly protect such information on a company-wide basis as a business that handles personal information. We have established an internal system for managing personal information and continually make improvements to it as we implement and maintain it.

Below is an overview of our privacy policy.

Manager in charge of handling personal information

The job title and contact information for the manager in charge of protecting personal information are provided below. This person bears full responsibility for promoting, maintaining, implementing and improving the internal personal information protection system.

Administration Division
Personal Information Protection Manager
E-mail: pmark@link-tech.jp

Types of personal information

The personal information we handle can be broken down into the main categories below.

• Personal information entrusted to us for the purpose of information processing/software development
• Personal information within resumes, transcripts, etc. acquired directly in writing from job applicants
• Personal information related to handling of shareholders acquired directly in writing from shareholders
• Personal information acquired directly from employees or personnel from a subcontractor accepted as on-site personnel to execute our business or indirectly via a third party with the consent of the individual
• Personal information incidental to documents prepared during the course of business transactions with customers (including business cards and organizational charts)

Rules for collection of personal information

We only collect personal information using fair and legal means. Moreover, in accordance with our management system for the protection of personal information, we obtain the consent of the individual prior to collecting the information.

When working with indirectly collected personal information entrusted to us by clients, we confirm with our clients that they have obtained the consent of the individual.

However, we may forgo this in the event that we determine that notifying or disclosing information to the individual or obtaining their consent would put their life/property or that of a third party at risk or violate the law. Such decisions will not be made arbitrarily but objectively based on logical reasoning and common sense.

Voluntariness of providing information

When we collect personal information from an individual directly in writing, we explain the voluntariness as well as the impact on the individual if we are unable to obtain the information on a case by case basis. In many cases, if we are unable to obtain certain personal information, we likely will not be able to provide the individual with services involving said information, but depending on the item, there are also many pieces of information for which provision is voluntary, so in addition to individual points of contact, we also have a point of contact for complaints and inquiries provided below.

Purpose of use of personal information

We use personal information only within the scope of the purpose to which the individual has given their consent.
The purpose of use of personal information we handle within our business is as follows:

• When we take on information processing/software development work, we only use the information to perform the work.
• When hiring, we use the information primarily to make the hiring decision but also to communicate with the job applicant.
• With respect to shareholders, we use the information to make remittances into their bank accounts and to communicate with them.
• With respect to employees, we use the information primarily for internal procedures such as payroll, taxes and personnel/general affairs,but also for company PR and sales information (such as engineer lists) within a certain limited scope.
• With respect to customers and corporate information, we use the information for sales and for records and communication concerning agreements.

Provision of personal information

Within the scope of the purpose of use to which the individual has given their consent, we may share or disclose the personal information we have collected with third parties.
We share/disclose personal information primarily in the following work/formats:

• With respect to employees, we may provide the names of our engineers in the form of a list containing personal information within a limited scope to our customers.
• We may publish the personal information of our employees that would be found on a business card as PR for the company.

Subcontracting of tasks involving personal information

When we take on information processing/software development work, we may entrust a third party with the handling of personal information with the consent of the client in order to serve the purpose. When entrusting a third party with the handling of personal information, we select a business partner that meets a certain level of requirements regarding the proper protection of such information in accordance with our management system for the protection of personal information, and we conclude a confidentiality agreement with them, checking and monitoring the handling of the information after the work is assigned and managing/overseeing the information until it is returned or destroyed after the work is complete.

We may provide the personal information of employees to a third party when subcontracting the preparation of company PR materials (such as brochures and websites) or labor/social insurance operations. In such cases, we handle selection of the company and conclusion of agreements in the same way as subcontracting of software development.

Retention and management of personal information

We retain the personal information we collect for a certain period of time based on internal document control rules according to the format, type, etc. of the information. In particular, with regards to the information of job applicants, policy holders, shareholders and employees for which we have responsibility corresponding to the individual's rights as presented in the following paragraph, there are some items we retain even after the individual is no longer affiliated with us (due to cancellation, leaving the company, etc.) in order to respond to legal requirements and resolve subsequent problems.

We implement reasonable and appropriate safety measures with respect to risk pertaining to personal information based on the rules of our management system for the protection of personal information as we go about managing the personal information we collect (from collection to return or disposal).

Individual's rights relating to personal information

In the event that we receive a request from the individual to which the personal information we retain or manage belongs to exercise the rights described below, we will take action (including deciding whether the request is appropriate or not) and notify the individual of the result (including the reason we were unable to comply with the request if we were unable to do so) without delay.

• Requests from the individual in question for notification of the purpose of use of the personal information in our possession, disclosure of the details and/or correction/deletion in the event that an error is revealed(In some cases, we will be unable to comply, such as with information used for employee evaluation and other information not normally disclosed to employees)
• Requests not to use or provide to third parties the personal information in our possession
  (In some cases, we will be unable to comply as long as the individual remains a job applicant, shareholder, employee, etc.)

The points of contact for the respective services will respond to inquiries regarding the procedures for such requests and will explain the contents of disclosure, format, external proof (means to confirm identity) required of the individual or his/her proxy, etc. In the event that the point of contact is unknown, the point of contact for complaints and inquiries below will handle the request or direct you to the appropriate point of contact.

Continuous improvement of management system for protection of personal information

By periodically educating about and familiarizing employees with our management system for protecting personal information, we will maintain its proper operation, and by regularly auditing the system and reviewing it under the direction of the company president, we will engage in ongoing improvements to as well as promotion and maintenance of the system.

Complaints and inquiries

We have established a point of contact for complaints and inquiries which takes complaints and inquiries regarding all the personal information in our care from the individual in question. This point of contact will also respond to requests for disclosure or discontinuation of use of personal information on behalf of the division in charge of collecting or using the information.