The Code of Personal Information Protection

Enacted on September 9, 2011 ALAXALA Networks Corporation

Background of the Code of Personal Information Protection

ALAXALA Networks Corporation. (hereinafter referred to as "ALAXALA") handles various information, including our technical information and information provided by customers, as a supplier who can provide total solution. With this in mind, ALAXALA has strived to establish and fully enforce an information management system in order to respect the value of the said information.
Considering such background, ALAXALA will attempt to create rules and establish a management system for the personal information protection in ALAXALA, as well as to set a code of personal information protection and spread it among board members and employees. Moreover, ALAXALA will take measures to make such code easily accessible to general public.

The Code of Personal Information Protection

ALAXALA Networks Corporation. (hereinafter referred to as "ALAXALA") will strive to protect personal information appropriately based on this code.

1. Definitions

In this document, "Personal information" is the information below that can be used to identify specific persons.

  • a. Information provided by person to ALAXALA by entering in "Inquiry form" or other forms.
  • b. Information provided by person to ALAXALA through any method other than the above.

ALAXALA shall define that personal information means information about individuals, including the name, age, birth date, address and other descriptions about them, or a number, symbol, code, image or sound assigned to them, that identifies the individuals (it shall also include the information that cannot identify individuals by itself, but can, as it easily can be verified with some other information.) In addition, it shall not be limited to personal identifiers, but shall include any information that indicates a fact, recognition and assessment about the attribute of individuals, including a physical characteristic, property, occupation or status.

2. Scope of Application

This document establishes the handling of all personal information by ALAXALA in the company activities.

3. Activity of Personal Information Protection

ALAXALA protects and manages the personal information by establishing a manager on a department basis with the greatest care and the best effort based on this Code.
And, from the viewpoint of the protection of the rights and interests of the concerned persons, ALAXALA makes efforts to consider the following points.

  • a. Responding to request from concerned persons about their retained personal data by voluntarily stopping its use, etc., such as stopping the sending of direct mail to the concerned person.
  • b. Whether information is entrusted to others or not, promoting the clarification of outside processing, such as clarifying the details of work done outside the business by outsourcers.
  • c. Clarifying the purpose of use more to the concerned persons through activities such as the business voluntarily limiting the purpose of use based on the selections of the concerned persons or the business limiting and showing the purpose of use by type with consideration to the details of the work.
  • d. Specifying as concretely as possible the source personal information was acquired from and the method of acquisition (the type of acquisition source, etc.) on the procedures to meet requests for disclosure and others.

4. Handlig The Code of Personal Information Protection - Collection/Usage Purpose and Provision to Third Party

  1. In relation to ALAXALA 's main business activities for information communication machinery products, ALAXALA will collect and use personal information only to achieve such purpose. For more details of our business activities, please see our website.
    • a. Execution of a contract concluded between ALAXALA and a customer.
    • b. Contacts for business negotiations and meetings with a customer.
    • c. Delivery of after-sales service on products, and sending of information on events and new products.
    • d. Delivery of various business-partnership services.
    • e. Response to various inquiries from a customer.
    • f. Analysis based on questionnaires to improve products and services.
    • g. Provision of personal information to the group company in case of co-operation with them.
  2. When ALAXALA requires a person to provide the personal information as is written in a document directly from the person, ALAXALA will clearly state the purpose of the use beforehand to obtain the consent.
  3. ALAXALA will not provide the personal information with a third party without first obtaining consent of the person, except in the following cases:
    • a. Cases in which the provision of personal information is based on laws
    • b. Cases in which the provision of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person
    • c. Cases in which the provision of personal information is specially necessary for improving public hygiene or promoting the sound growth of children and in which it is difficult to obtain the consent of the person
    • d. Cases in which the provision of personal information is necessary for cooperating with a state institution, a local public body, or an individual or entity entrusted by one in executing the operations prescribed by laws and in which obtaining the consent of the person might impede the execution of the operations concerned
    • e. Cases in which an entry handling personal information entrust the handling of personal information in whole or in part within the scope necessary for the achievement of the Purpose of Use, subject to entring into the appropriate contract between ALAXALA and such entrustee, in order to maintain the protectction of personal information in accordance with this code.
    • f. Case in which personal information is provided as a result of the take-over of business in a merger or otherwise
  4. When required to do so for business activities in which ALAXALA is co-operating with the group companies, ALAXALA may provide such group companies with personal information such as a name, workplace or home addresses, telephone number, fax number, e-mail address, etc. If this is the case, the personal information will be provided in print or electronic media. In addition, the person may request us to stop the provision of the personal information with the group companies.

5. Request to Disclose Personal Information or Raising

When a person wants to request to disclose, correct, add, delete, stop usage, stop provision to a third party, or notify the purpose of usage of his/her personal information (hereinafter referred to as "disclose and so on") held by ALAXALA, or wants to raise complaints, the person is requested to follow the following procedures:

  1. Request to disclose personal information that a person submitted to a either one of ALAXALA 's department.
    • Please contact the relevant department.
  2. Request to disclose personal information that a person submitted through our web site.
  3. Complaints for our personal information handling.

6. Request to person

  1. While most of ALAXALA 's services can be used without the personal information, please note that some services are only available with the submission of the personal information.
  2. Please note that ALAXALA is not responsible for the security of personal information in any non- ALAXALA web site whose link is included in the ALAXALA 's web site.
  3. If a person enters the personal information into the ALAXALA 's website, he or she is required to agree upon the provisions in this document, " The Code of Personal Information Protection ", otherwise you may not use our services (including response to inquiries). Also, if you are aged at 14 or younger, please enter the personal information with the consent of a parent or guardian.
  4. Please note that ALAXALA may ask a person who inquire ALAXALA about handling of Personal Information held by ALAXALA for provision of some identification.

7. Special Note

  1. Our The Code of Personal Information Protection shall be in accordance with the laws of Japan.
  2. ALAXALA may revise this document, "The Code of Personal Information Protection," to improve the handling of personal information and/or due to the revision of laws or ordinances, or other rules or regulations.
  3. The implementation of this document, "The Code of Personal Information Protection," shall be after the issued date (or revised date).
  4. If each ALAXALA website has its own the code of personal information protection, this code shall supersede the provisions of any other code or policies in the ALAXALA websites.
    However, If ALAXALA enter into a certain contract regarding Personal Information protection between a person who submit his or her Personal Information to ALAXALA, such contract supersedes the term and conditions of this code.
  5. If a person calls us, ALAXALA may tape the call to ensure offering clearer answers.