HAPSMobile Inc. (hereafter called “HM”) works for implementation of the following matters to ensure full compliance with “Act on the Protection of Personal Information” (Act No. 57 of May 30, 2003) , “Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure” (Act No. 27 of May 31, 2013), “Guidelines for proper handling of Specific Personal Information (for private entities)”, “Personal Information Protection Management Systems – Requirements” (JISQ15001) and others to protect personal information.

1. Strengthened employees' training

Conduct training on management of personal information for employees.

2. Development of company rules concerning personal information handling

Ensure that tough stance of HM against leakage of personal information is fully communicated in HM as well as develop company rules concerning personal information handling to present a clear policy for handling of personal information.

3. Placement and enhanced functions of “chief privacy officer”

Build up a structure with visible roles to comply with laws and guidelines, develop relevant company rules, build up an audit structure and oversee the handling of personal information as well as place “chief privacy officer” to appoint information security manager as such officer.

4. Implementation of appropriate measures for information security

Implement necessary and appropriate measures to administer access to personal information, limit taking-out of personal information and prevent unauthorized access from outside with intent to prevent personal information from being leaked, lost or damaged and safely control personal information.

5. Outsourced operations

(1) Outsource, in some cases, all or part of its personal information handling operations in sales of various services, response to customers' inquiries, facility maintenance, tariff-related works, marketing tasks and other related works.

(2) Fully examine the eligibility of outsourcing agents when concluding outsourcing agreements. Further, set out safety management measures, confidentiality, terms of subcontract and proper handling of personal information in such outsourcing agreements and oversee HM's outsourcing agents in an appropriate manner by regularly monitoring outsourced operations.

(3) Use personal information provided by an outsourcer in association with the acceptance of outsourced operations to the extent necessary for the purpose of the agreement with such outsourcer.

6. Setup/Enhancement of audit structure

Set up an audit structure which enables HM to internally audit whether personal information is properly protected.

7. Proper acquisition, use, provision and announcement of personal information

Upon acquiring personal information, HM legally and fairly obtains personal information by means of application forms, web site or verbal explanation upon clarifying the purpose of use of such personal information. Upon using and providing personal information, and upon announcing retained personal information, HM properly performs the act by considering details and a scale of business.

8. Continuous improvement of personal information protection-related activities

Continuously attempt to review/improve the activities stated in paragraph 1 through 7 above.

9. Revision

HM may revise all or a part of the present “Personal Information Protection Principles”. In the event of a material change, HM announces it on its official web site in an easily comprehensible manner.

Coverage of “Personal Information Protection Principles”

"Personal information" in this "Action Guideline for the Protection of Personal Information" means the information related to the individual, identified by name, date of birth or other explanation, or individual number, other code, image or voice.(Includes information that can not be identified using the information alone, but can easily identify an individual compared to other information.), and the target doesn't matter whether it is the customer of HM, employees of business partners or of HM.

“Personal Information Protection Principles” applies, unless otherwise stated in each paragraph, to all personal information managed by HM.

Supplementary provisions

This Personal Information Protection Principles shall be enforced from April 25, 2019.

Junichi Miyakawa
President & CEO
HAPSMobile Inc.