AIPHONE

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Aiphone Co., Ltd. Privacy Policy

Aiphone Co., Ltd. (the “Company”) recognizes the importance of the personal information of individuals, including our customers, and handles such personal information in accordance with the following policies.

1. Basic Policy on the Protection of Personal Information

  1. The Company shall comply with the laws and regulations, the guidelines established by the government or administrative authorities and other rules concerning the protection of personal information and the corporate ethics of the Company.
  2. As part of its personal information protection system, the Company shall assign a person in charge to manage personal information (a personal information protection manager) and clarify the management framework of the Company. In addition, the Company shall ensure that all officers and employees recognize the importance of, and comply with, the Company’s internal rules concerning personal information protection.
  3. The Company shall only handle the personal information of a person within the scope of the purposes of utilization clearly shown to such person. The Company shall not disclose or provide personal information to any third parties, except in cases where the person has agreed thereto or such disclosure is based on the laws or regulations or other justifiable grounds.
  4. The Company shall endeavor to keep personal information accurate and up-to-date, and shall take appropriate safety measures to prevent or correct, as necessary, the illegal access to, leakage, loss or destruction of personal information.
  5. The Company shall respond in an appropriate manner, pursuant to the laws and regulations, to any inquiries, complaints, consultations and requests for disclosure from a person concerning the personal information of such person.
  6. The Company shall establish and maintain a personal information protection management system taking the above into consideration, and shall endeavor to continuously improve such system.

2. Purposes of Utilization of Personal Information and Handling within such Purposes of Utilization

The Company shall collect, hold and utilize the personal information that it already holds and/or collects hereafter within the purposes described below:

  1. To provide services concerning the Company’s products and/or services, including, without limitation, planning, development, research, purchase, manufacture, sales, construction, repair, and inspection;
  2. To provide and/or exchange information concerning the Company’s products and/or services;
  3. To respond to or discuss questions and/or inquiries (*1);
  4. To plan, operate and provide follow-up services concerning exhibitions, events and seminars;
  5. To utilize the same for market research (questionnaires, investigations, etc.) and analysis, planning and improvement of products, and sales and marketing activities;
  6. To utilize the same for recruiting activities and personal management and labor relations;
  7. To provide and/or exchange information to/with the Company’s shareholders and other investors; and
  8. To utilize the same for internal information exchanges and intra-company training with respect to the above, and other activities incidental or related to the above.

(*1) The contents of calls between you and the Company’s call centers (i.e. repair centers and customer counseling centers) may be recorded in order for the Company to understand exactly what your concerns are and to avoid missing any of your requests.

3. Safety Measures

The Company shall endeavor to keep personal information accurate and up-to-date, and shall take appropriate safety measures to prevent or correct, as necessary, any illegal access to, or leakage, loss or destruction of personal information.

4. Supervision over Contractors

The Company may outsource the handling of personal information to a third party when utilizing personal information for the purposes of utilization. In such case, the Company shall assess and select a third party, enter into a confidentiality agreement, and oversee the third party as necessary.

5. Provision to a Third Party

The Company shall not disclose the personal information of a person to any third party without such person’s consent. However, the Company may provide personal information to a third party in cases where:

  1. The person has agreed;
  2. The Company outsources to a third party, within the purposes of utilization, catalogue dispatching, information provision, product planning or development, purchase, manufacture, sales, repair, inspection, data management or other services;
  3. The Company’s outsourcing contractor responds to questions or inquiries from customers;
  4. The Company promotes its services in collaboration with a third party;
  5. Other cases where the Company provides personal information to its outsourcing contractor within the scope necessary to achieve the purposes of utilization;
  6. The handling of personal information is pursuant to the laws and regulations; or
  7. The handling of personal information is necessary for the protection of the life, limb, or property of an individual and where it is difficult to obtain the consent of such person.

6. Use of Statistically Processed Data

The Company may, based on the collected personal information, create statistical data which shall be processed in a manner that cannot identify any individual. The Company may use such statistical data without limitation.

7. Inquiries and Requests for Disclosure

With respect to the personal information provided by a person to the Company, the Company will, based on laws and regulations concerning personal information protection, appropriately respond to such person’s request for disclosure, correction, suspension of use, or deletion of his/her personal information or opinions, inquiries, complaints or consultations. To submit a request, etc., please contact the department to which you provided personal information or any branches or business offices near you, or please contact the inquiry desks below.

For shareholder information stated in the Company’s shareholder registry, please contact the Stock Transfer Agent Department, Mitsubishi UFJ Trust and Banking Corporation, which is the Company’s transfer agent.

Please note that the Company will confirm the identity of the person making the inquiry or request for disclosure, etc.

8. Continuous Improvement

The Company may revise this privacy policy as necessary to protect personal information and to comply with the laws and regulations, guidelines and other rules concerning personal information protection. In order to implement such policy, the Company shall establish a personal information protection management system, and shall implement and maintain the same through intra-company training and internal audits. Furthermore, the Company shall continuously improve the personal information protection management system in order to respond to various changes, including, without limitation, changes in personal information and how to handle such information and the environment surrounding the Company.

Shusaku Ichikawa
President and Chief Executive Officer
Aiphone Co., Ltd.

Enacted: August 1, 2011
Revised: March 2, 2015