Privacy Policy

■ Handling of Personal Information

（Definition of Personal Information）
1."Personal information" in this Policy refers to information relating to an individual that includes a name, date of birth, or other description, etc., that could be used to identify a specific individual, or that includes an individual identification code. All obtained information relating to customers that does not contain information in itself by which a specific individual could be identified, but which could be used to identify a specific individual by collating it with other information, shall be regarded as "personal information" within the scope that it can be handled in combination with other information.

（Compliance with Laws）
2.When handling personal information, JOEN shall comply with the obligations set forth in the Act on the Protection of Personal Information, various other laws and regulations relating to the protection of personal information, guidelines published by the Personal Information Protection Commission and the competent authorities, as well as to this Policy.

（Use within the Scope of Utilization Purpose）
3.Except where the prior consent of the individual has been obtained, or where it is permitted by law, JOEN shall handle personal information only within the scope required to achieve the previously specified purpose of use, and shall take measures to achieve this.

（Acquisition of Personal Information）
4.JOEN shall endeavour to obtain personal information after expressing in advance the items, purpose of use, and contact point for inquiries, etc., of the personal information to be handled, and after obtaining the consent of the individual.In the event that special care-required personal information such as race and creed, etc., is included in the personal information, except where permitted by law, JOEN shall not acquire such personal information without the consent of the individual. When obtaining personal information from a third party, if a legal obligation to check or create records arises when receiving provision from a third party, JOEN shall comply with this.

（Personal Information of Customers Under the Age of 15）
5.JOEN shall endeavour to comply with all laws and regulations applicable to the collection, storage, and use of personal information relating to customers under the age of 15. In the event of a child having provided personal information to JOEN without the consent of their parent or guardian, we ask that a parent or guardian contacts us at the address specified in this Policy.

（Security Control Action）
6.JOEN shall endeavour to keep the content of personal information accurate, complete, and up to date within the scope of the purpose of use, shall take the necessary and appropriate secure management measures in accordance with technological standards at that point in time in order to prevent unauthorised access, leakage, tampering, loss, or damage, etc., and shall make corrections as necessary.

（Supervision Over a Trustee）
7.JOEN, within the scope required for the achievement of the purpose of use, may entrust the handling of personal information to a third party. In such a case, with regard to the contracting of business to a third party, efforts shall be made to ensure that secure management is performed as strictly as possible in relation to the handling of personal information, such as through the execution of a contract. If a third party in a foreign country is contracted to perform business, and a legal obligation to create records arises, JOEN shall comply with this.

（Third Party Provision）
8.Except where permitted by law, JOEN shall not provide personal information to a third party without obtaining the consent of the individual. If personal information is provided to a third party, and a legal obligation to create records arises at the time of such third party provision, JOEN shall comply with this.

(Respond to a Demand etc. for Disclosure etc.)
9.JOEN shall respond appropriately to requests for the disclosure, amendment, ceasing of use (for introducing products and services, etc.), and deletion of personal information, as well as other comments and inquiries regarding the handling of personal information, based on the provisions of laws and regulations. Please contact the address of the company to which you provided information for assistance.

（Strengthening of Systems, Training, Etc.）
10.To ensure the appropriate handling of personal information, JOEN shall endeavour to continually strengthen and improve internal systems, including reviewing this Policy, by appointing a manager for personal information, establishing internal regulations, training officers and employees, and implementing the appropriate internal audits, etc.