PRIVACY POLICY

SEMCO LTD. (hereafter referred to as “the Company”) shall strictly protect and manage all personal information which it collects through its business operations based on the methods prescribed in this Privacy Policy.

Approach to Personal Information

Personal information is information about living persons which can be used to identify a particular individual, or which can be easily compared with other information to identify a particular individual .Information which has been processed by compilation or analysis so that individuals cannot be identified is not recognized as personal information.

Collection of Personal Information

When the Company collects customer personal information, it shall notify the customer of the purpose of use and obtain the customer’s consent in advance, and shall collect information within an appropriate range.
When personal information is collected, if the customer does not wish to provide certain information which is required by the Company, then the customer may be unable to use the Company services. The customer may decide whether or not to provide information for optional items. Information which has been processed by compilation or analysis so that individuals cannot be identified is not recognized as personal information.

Use and Provision of Personal Information

Collected personal information shall not be used beyond the range of the purpose of use for which consent was obtained in advance. Except in cases when prescribed by law and equivalent cases, customer personal information shall not be disclosed or provided to a third party without the consent of the customer.

Management and Handling of Personal Information

Personal information collected from the customers shall be strictly managed, and appropriate preventive and corrective measures shall be taken to prevent unauthorized access, loss, damage, unauthorized modification, leakage, or other incident involving personal information. Necessary and appropriate training and monitoring of Company employees shall be carried out, and thorough action shall be taken to ensure safe management and appropriate handling of customer personal information.

Outsourcing of Personal Information

The Company may outsource the handling of customer personal information to an outside contractor within the range necessary to achieve the purpose of use. In such cases, the Company shall select a contractor which is capable of correctly handling personal information, and shall conclude an outsourcing contract that includes conditions for handling of personal information. Necessary and appropriate training and monitoring of contractors shall be carried out, and thorough action taken to ensure safe management and appropriate handling of customer personal information.

Personal Information Disclosure, Correction, and Discontinuation of Use

When the customer desires the disclosure, correction, or discontinuation of use related to his or her own personal information, he or she should contact the contact office at the Company. The Company will then promptly take action in accordance with its designated procedures.

Revision of the Privacy Policy

The Company shall observe laws and norms related to personal information, and shall continually improve its systems and mechanisms for management of customer personal information.
This Privacy Policy may be reviewed and revised as needed.In such case, the revised policy shall be immediately disclosed.

2April 1, 2014
SEMCO LTD.