Personal Information Protection Policy
of Japan Communications Inc.
(Privacy Policy)

Japan Communications Inc. (“the Company”) will comply with laws, regulations and guidelines (including but not limited to “Act on the Protection of Personal Information”, “Telecommunications Business Act” and “Guideline for the Protection of Personal Information in Telecommunications Business”) on handling Personal Information in the telecommunications business and other corporate activities (“the Business Activities”). In addition to that, the Company establishes this Personal Information Protection Policy (this “Policy”) and will comply with the Policy.

1. Name, Address, and name of representative of the Business Operator Handling Personal Information (Telecommunication Business Operator)

(Name) Japan Communications Inc.
(Address) 4-1-28 Toranomon, Minato-ku, Tokyo
(Name of the Representative)
Naohisa Fukuda, Representative Director-President

2. Types of Personal Information

The Company shall handle the Personal Information described below in the Business Activities.

(1) Personal information on the contracting party (“Customer”) of the telecommunication services (including applications provided by the Company for procedures related to the use of the telecommunications services) (“Company Services”)
① Information that provided by Customer on using Company Services
a) Information on Customer’s identification and contact information (Name, address, date of birth, phone number and
email address)
b) Information on Customer’s identification (Items written in the identification documents) (If the identification document is an individual number card, the information includes not only the items written in the individual number card (excluding individual number) but also the digital signature and digital certificates of the individual number
card.)
c) Information on Customer’s payment method (Credit card, Debit card, bank account number, etc.)
d) Information on Customer’s inquiries (including Comments and Requests)
② Information that acquired through use of Company Services by Customer
a) Information on usage status of Company Services (communication history and usage history)
b) Information on usage environment of Company Services (network and communication terminal)
c) Information on usage fee of Company Services (billed amount and payment status)

(2) Personal information on the shareholders (Items written in the Shareholders List)

(3) Personal information on Executive officers and Employees (including Recruitment applicants, Interns, Prospective employees, Contract employees, Temporary Employees) (“Officers and Employees”)

(4) Other personal information on the Company’s suppliers, people contacting the Company’s helpdesk, etc.

3. Purpose of Use of Personal Information

(1) Personal information on Customer

① The Company will use personal information on Customer within the scope of the purpose of use listed below to provide Company Services.

② The Company will use personal information on Customer within the scope of the purpose of use listed below to promote the sales or use of Company Services.

③ The Company will analyze data related to personal information on Customer and use them within the scope of the purpose of use listed below to provide stable operation of Company Services.

④ The Company will analyze data related to personal information on Customer and use them within the scope of the purpose of use listed below to plan and develop Company Services.

(2) Personal information on the shareholders
The Company will use personal information on the shareholders within the scope of the purpose of use listed below.

(3) Personal information on Officers and Employees
The Company will use personal information on Officers and Employees within the scope of the purpose of use listed below.

(4) Other personal information
The Company will use other personal information within the scope of the purpose of use listed below.

4. Sharing personal information with third party

The Company will share personal information on Customer with third parties in the following cases within the scope of the purpose of use listed below.
① In a case when Customer applies for a contract to use Company Services and Customer’s identification is processed using the digital signature and digital certificates of the individual number card, the Company will provide the information recorded on the individual number card and information relating to the digital signature and digital certificates of the individual number card to the following third parties and request them to verify the information.
• Japan Agency for Local Authority Information Systems
• business operators that have been certified under Article 17, Paragraph 1, Item 6 of the "Act on Certification Business of Japan Agency for Local Authority Information Systems Concerning Electronic Signatures, etc." regarding the use of public personal authentication services (limited to business operators who concluded contract with the Company)

② In a case when the fees for Company Services is unpaid even though the payment date has passed, the Company will transfer the claims for the unpaid fees to a third party ("the Assignee”) and will share Customer’s name, address, date of birth, and the amount of unpaid fees, etc. with the Assignee to collect the amount due.

③ In a case when requested by an international telecommunication business operator ("the International Operator”) , the Company will share name, address and phone number, etc. of the Customer who is (or is applying to be) a contracting party of the International Operator based on the operator’s Terms and Conditions, with the International Operator.

④ In a case when Customer moves out to other mobile phone operator by Mobile Number Portability (MNP), the Company will share Customer’s name, date of birth, mobile phone number and other MNP related information to the mobile phone operator and the telecommunication business operator who concluded an interconnection agreement or other relevant contracts with the Company.

⑤ In a case when the Company needs to check the copy of the identification documents provided by Customer, the Company will share the Customer’s information written in the identification documents with Police and other government entities.

⑥ In a case when emergency call entity (Police department, Fire department, Coast guard) contacts the Company and requests information regarding the Customer who made the emergency call (name and address of the Customer regarding the emergency call), the Company will share specified information with these entities.

⑦ In a case when detecting harmful SMS with Company Services’ “harmful SMS prevention system”, the Company will share the information related to harmful SMS (sent date and time of the harmful SMS, sender phone number, and contents) with Mobile Phone Operators who concluded an interconnection agreement or other relevant contracts with the Company and other entities which has alliance with the Mobile Phone Operators in order to take measures for the prevention of harmful SMS.

⑧ In a case when the fees for Company Services is unpaid after contract end date, the Company will exchange personal information of the unpaid Customer between Mobile Phone Operators and BWA service operators as below. This information includes personal information pertaining to the payment status, etc. of the subject claim obtained by the Company from the Assignee of the subject claim.

> Personal information that will be exchanged
Name/Address/Data of Birth/Gender/phone number before contract cancellation/ contact phone number/unpaid situation

> Purpose of exchange
Telecommunication business operators will exchange personal information of the Customer who has not paid the fees even after the contract cancellation among them and utilize the information for application screening in order to prevent unpaid incidents and protect user’s fairness and benefit (Application may not be accepted depending on the situation of non-payment).
Please refer to TCA (Telecommunications Carriers Association) website for the name of the operators with which the Company will exchange information.

⑨ In a case when Customer pays the fees for Company Services by Credit card or Debit card, the Company will provide the card issuer with the information necessary for the card issuer to detect and prevent fraudulent use.

5. The Company’s Safety control measures for personal information

The Company implements countermeasures for information security and other safety control measures to secure the safety of personal information, and prevents illegal access to personal information or loss, corruption, alteration, and leaking of personal information. Also, the Company will improve the safety control measures immediately when it is recognized that improvement is necessary, such as occurrence of security accidents, notifications from the persons himself/herself, or the Company’s internal audits.

6. Protection of the right benefit of the person's himself/herself

(1) Voluntary Suspension of usage
Regarding Personal Information on Customers, in a case when Customer requests to discontinue use of the personal information, the Company will suspend and discontinue use of personal information on Customer within the scope of the purpose of use listed in above 3.(1)②, such as providing information by email.

(2) Subcontracting and Operation
Regarding Personal Information on Customers, the Company may subcontract the following operations that is within the scope of the purpose of use listed in above 3.(1)①.

(3) Source or method to obtain personal information
Regarding Personal Information on Customers, the Company will obtain personal information on Customer from sources or by methods as below.
① Obtained from Customer (including dealers of the Company or lawyers and other attorneys)
② Obtained from Customer through use of Company Services
③ Obtained from other mobile phone operators or telecommunication business operators who have an interconnection agreement or other agreement with the Company for mobile number portability (MNP) application operations
④ Obtained from mobile phone operators and BWA service operators, who will exchange non-payment related information with the Company
⑤ Obtained through Credit bureau inquiry
⑥ Obtained through inquiry or notification from Government entities, judicial entities, and other public entities

7. Provision of Personal information to Third Parties in Foreign Countries

The Company may provide personal information on Customer to third parties in foreign countries. In this case, the Company will provide personal information on Customer with Customer’s consent, except for cases that fall under any of the following.

(1) In a case when the third party is located in a foreign country that has a system for protecting personal information that is recognized to be at the same level as Japan in terms of protecting the rights and interests of individuals.

(2) In a case when the third party has established a system necessary for continuously taking measures equivalent to the measures (“Equivalent Measure”) that business operators handling personal information in Japan is required to take regarding the handling of personal data.

In the case of (2) above, the Company will take the necessary measures to ensure that the third party continues to take Equivalent Measure. If Customer would like to confirm the details of this, please make a request to the Company in accordance with the method set forth in 8. below.

8. Personal information Disclosure, correction, and suspension of use

The Company will accept request about personal information held by the Company, such as notification of purpose of use, disclosure, correction, deletion, suspension or providing information regarding personal information protection measure (“Disclosure Request, etc.”) as below.

1) Method of disclosure request, etc.

① Submit the Company’s prescribed application form (“Application form for Disclosure, etc.”), to “Personal Information Disclosure Request, etc. Desk” through postal mail, fax, or email.

② Please attach one of the following identification documents to the Application form for Disclosure, etc. to enable the Company to confirm applicant’s identity.

a) For requests from persons him/herself, a copy of the driver’s license card, individual number card (side with photo only), passport, residence list card with photo, health insurance card, residence card/special permanent resident certificate, or residence certificate (without individual number)

b) For requests from attorney, identification documents of the persons him/herself and attorney as described above in a), as well as a letter of attorney, including Stamp on the letter and stamp certificate

③ Upon confirmation of applicant’s identification, the Company will response via postal mail, fax, email or other ways which was requested by the applicant. If the method requested by the applicant is expensive or difficult, the Company will response via postal mail.

④ Please note that the response may take a few days.

2) Acceptance and support desk for Disclosure Request, etc.
① Acceptance and Support desk (Postal mail, Fax, email)
Personal Information Disclosure Request, etc. Desk,
Japan Communications Inc.
Address: 4-1-28 Toranomon Minato-ku Tokyo Toranomon Towers Office
Zip code:105-0001
Fax: 03-6435-9186
email: hello@j-com.co.jp

② Support desk (Phone)
03-6633-2063 (Time of operation:10:00-17:00)

3) Fee for Disclosure request, etc.
In the case of response by postal mail or fax, the applicant needs to pay 600 yen as fee per request. Please send a 600-yen postage stamp or postal money order by postal mail.

Download
「Application Form for Disclosure of Personal Information」
「Application Form for Correction, etc. of Personal Information」
「Application Form for Suspension of Use, etc. of Personal Information」
「Application Form for Suspension of Sharing Personal Information to Third Party」
「Application Form for Providing Information regarding Personal Information Protection Measure」

9. Consultation desk for Personal information handling

If you have any opinions or questions regarding the Company’s handling of personal information, please contact below.

Japan Communications Inc. JCI helpdesk
Tel: 03-6633-2063(time of operation:10:00-17:00)
Inquiry:https://www.nihontsushin.com/mail

10. Name of authorized personal information protection organization and contact for consultation

The Company is a member of the Telecommunications Personal Information Protection Promotion Center of the Japan Data Communications Association, an authorized personal information protection organization.

If you have any opinions or questions regarding the Company’s handling of personal information, you may contact below.

https://www.dekyo.or.jp/kojinjyoho (Japanese Only)