GMO Internet, Inc. Privacy Policy

About the Handling of Personal Information

GMO Internet, Inc. (hereafter gGMO Interneth) recognizes the importance of protecting personal information in the operation of its Internet Infrastructure and Internet Media businesses and the entire company adheres strictly to the Privacy Policy laid out below. In addition, the companyfs Internet Infrastructure business and Internet Media business seek to ensure customer trust through the active protection of personal information in cooperation with distributors, industry organizations and government agencies, etc.

1. Policy for Handling Personal Information

GMO Internet observes a number of regulations including Japanese laws and ordinances, Guidelines for the Protection of Personal Information in the Telecommunications Business Field (hereafter gthe Guidelinesh), and the companyfs own regulations. In regard to the appropriate management and protection of personal information handled in the course of business, GMO Internet has established the following privacy policy with the objective of operating and improving a secure personal information protection structure for customers, vendors, stockholders, and stakeholders (hereafter gCustomers etc.h) of as well as directors and employees of the company (hereafter gemployeesh).

(Compliance with Laws, Regulations etc.)

In the acquisition, usage and all other handling of personal information of Customers etc. GMO Internet complies with provisions of the Act on the Protection of Personal Information, telecommunications business laws relating to privacy of communications, gthe Guidelinesh and this privacy policy.

(Declaration of Specification of Purposes of Utilization of Personal Information)

GMO Internet specifies and declares in advance the purpose of utilization of personal information obtained wherever possible. When personal information is obtained directly as a result of details provided by Customers etc. in a contract or other document, the purpose of use shall be explicitly stated in advance. Please refer to Article 2. (Purposes of Utilization of Personal Information) below.

(Handling Within Scope of Purpose of Use)

GMO Internet handles the personal information of Customers etc. only to the extent necessary to achieve previously specified and declared usage objectives. However, the company may use personal information of Customers etc. outside the scope of usage purposes where provided for in Article 6, paragraph 3 of gthe Guidelinesh.

(Period of Retention)

Except where otherwise prescribed by law, GMO Internet determines the length of time it is necessary to retain personal information of Customers etc. to achieve the objectives of pre-disclosed usage purposes. At the expiry of this period or when the objectives of the usage purposes are achieved, personal information is promptly destroyed. However this limitation does not apply in cases specified in Article 10, paragraph 2 of gthe Guidelinesh.

(Secure Information Management)

GMO Internet strives to maintain current and accurate records of personal information, we have also taken necessary and appropriate measures to ensure the secure management of personal information in order to safeguard against unauthorized access, falsification and leakage, loss, or damage.

(Supervision of Employees)

GMO Internet conducts necessary and appropriate supervision over the employees to ensure secure management of personal information pertaining to Customers etc. In addition GMO Internet conducts training to ensure employees handle personal information appropriately.

(Supervision of Entrustee)

GMO Internet may entrust some or all of the handling of personal information pertaining to Customers etc. to a third party, within the scope of purposes of utilization of personal information. When selecting trustees, we verify that personal information is handled suitably and demand that personal information pertaining to the companyfs Customerfs etc. be handled appropriately. In addition GMO Internet exercises necessary and appropriate supervision over the trustee to ensure the secure control of the entrusted personal information, through measures such as the inclusion in contracts of provisions relating to the auditing of personal information.

(Provision of Personal Information to a Third Party)

GMO Internet will not provide personal information of Customers etc. to a third party without obtaining prior consent except where provided for under Article 15, paragraph 1 of the Guidelines or where otherwise prescribed by law.

(Shared Use, etc.)

Where certain personal information is supplied to a third party as allowed for under Article 15 paragraph 4 of the Guidelines, GMO Internet is not required to treat that party as a third party and may entrust the handling of personal details of Customers etc., provide personal information to the party or share use of information with specific individuals or entities without obtaining prior consent of the Customers etc. The scope of shared use is confined mainly to GMO Internet Group however information may also be shared with other specified parties. GMO Internet provides notification by publishing on each service web site, the scope of the shared use, the purpose for which the personal information is used and the name of the individual or business operator responsible for the management of the personal information.

(Request for Disclosure, etc.)

Customers etc. wishing to be informed of the purposes of utilization of personal information, or who seek disclosure, correction, addition or deletion of details, or who wish to prevent GMO Internet or a third party using personal information should apply in accordance with the companyfs procedures. Please refer to the relevant service web site to view procedures for requesting disclosure, correction, addition or deletion of personal information.

(Management of Grievances)

GMO Internet deals promptly and appropriately with grievances and other inquiries from Customers etc. regarding the handling of personal information. Contact details for grievances and other inquiries are listed on each service web site.

(Handling of Leakages)

In occurrences such as the leakage of personal information pertaining to Customers etc., relevant facts will be promptly provided to the customers etc. and the leakage will be promptly and appropriately handled.

(Ongoing Improvement)

GMO Internet strives to continually improve internal handling of personal information through the improvement of internal regulations regarding the protection of personal information and through continued employee training and internal auditing.

2. Purposes of Utilization of Personal Information

Japan Registry uses personal information to the extent necessary to achieve the following purposes of use.

1. For the purpose of tasks relating to provision of services including personal certifying, operation, billing, accounting, invoicing, and debt collection, as well as modifying, updating or canceling the billing information, or to send notification. And correspond with the customer support to above tasks.

2. To send out documents relevant to the domain registration and renewal, and information update, to Registry and other institution whom acts to provide their duties.

3. To provide domain registration information published on Whois which has been approved by ICANN, Registry, and other institution whom acts to provide their duties.

4. To answer the telephone, email, fax, etc. we receive and to communicate with our customers regarding the service we provide.

5. To provide service related information including, "Domain Registration Status", "Rental Server Usage Status", and " Service Charges and Invoicing" to our customers by telephone, email, fax, etc.

6. To send out documents relevant to the operation and provision of this service and to provide service related information to our customers by telephone, email, fax, etc.

7. To provide information related to any other services provided by GMO Internet or services provided by affiliated companies to our customers by telephone, email, fax, etc.

8. To provide information related to services provided by our alliance partners to our customers by telephone, email, fax, etc.

9. For the purpose of analysis and to conduct surveys with the objective of improving service and other services provided by GMO Internet and affiliated companies.

10. To conduct campaigns associated with this service.

11. To provide information to our customer who requests to disclose their own information being kept in our records in case we can confirm the customerfs identity.

12. To disclose information requested by Japanese and international public institutions.

13. To disclose information requested by ICANN, Registry, Registrar and other institution whom acts to provide their duties.

14. To achieve any other purposes within the scope of the consent provided by the companyfs customers.

3. Provision to Third Parties and Shared Use

Personal information acquired from customers of GMO Japan Registry is provided to and shared with other parties as detailed below. Personal information shall not be provided to or shared with third parties except in the following cases. GMO Internet is accountable for the management of personal information and shall handle customer inquiries through its Customer Support service.

Key Systems Name, organization name, address, telephone number, fax number, e-mail address
NeuStar, Inc. Name, organization name, address, telephone number, fax number, e-mail address
Melboourne IT Name, organization name, address, telephone number, fax number, e-mail address
VeriSign, Inc. Name, organization name, address, telephone number, fax number, e-mail address
Afilias Limited Name, organization name, address, telephone number, fax number, e-mail address
NeuLevel, Inc. Name, organization name, address, telephone number, fax number, e-mail address
Public Interest Registry Name, organization name, address, telephone number, fax number, e-mail address
Japan Registry Services Co., Ltd. Name, organization name, name of department, position, postal code, address, telephone number, fax number, e-mail address
GMO Payment Gateway, Inc. Name, credit card number, card expiration date
JCB Co., Ltd. Name, credit card number, card expiration date
Resona Card Co., Ltd. Name, credit card number, card expiration date
Mitsubishi UFJ NICOS Co., Ltd. Name, credit card number, card expiration date

Note: Personal information may be shared within the GMO Internet Group.

I. Extent of Shared Use

GMO Internet Group companies (subsidiaries and affiliated companies listed at the following URL:
http://www.gmo.jp/en/profile/outline.html)
*The composition of the group is subject to change as a result of new companies being established, group restructuring and other events. Please check the above link for the latest information on the composition of the GMO Internet Group.

II. Purposes of Utilization of Personal Information

Each company in the GMO Internet Group has defined Personal Information Purposes of Use. Information shared among group ompanies shall be used in accordance with the relevant usage purposes.

III. Shared Personal Details

Name, address, email address, telephone number, contract details, and other information within the limits of the above usages purposes.

IV. When the personal information of customers is shared outside the group special measures are required.

V. Personal information about customers may be supplied to a third party in the provision of services only after consent is obtained in advance from the concerned customer.

VI. In some cases the handling of personal information is entrusted to a company outside the group. However, in these cases GMO Internet only selects companies that have higher personal information protection management standards than our own. Required measures are taken in regard to a duty of confidentiality agreement. At the same time GMO Internet ensures appropriate management and supervision of the concerned company.

VII. GMO Internet may disclose personal information when ordered to do so by the government or a court order.

4. Proper Acquisition of Personal Information

1. GMO Internet acquires personal information only as necessary and through appropriate measures.

2. GMO Internet may set cookies on client computers for certain reasons. The company uses personal information (IP address and the account names, passwords and IDs required to use some services) contained in cookies. This information is only used for the purposes listed in the usage purposes stated by the company.

3. Some emails sent to customers advertising GMO Internet services direct the customer to a URL with parameters (personal URL) that contains encrypted information identifying the customer. Information about customer browsing activity that is collected from these personal URLs may be used by GMO Internet services, however information is only used for the purposes listed in the usage purposes stated by the company.

5. Disclosure, etc. of Personal Information

1. When an individual seeks disclosure, amendment, deletion or notification of usage purposes in regard to their own personal information (excluding information acquired from stockholders), GMO Internet shall respond within a reasonable time in accordance with the Act on the Protection of Personal Information Articles 25 and 26 following the process determined by GMO Internet and laid out below in section 2. Where no such data exists, the individual shall be informed immediately. (In regard to requests about personal information acquired from stockholders such as transfers and bank accounts to which dividends are paid, it is necessary to inquire to the companyfs stockholder register administrator, Mitsubishi UFJ Trust and Banking Corporation. Please see section 6 for details regarding stockholder inquiries.)

2. Requests for disclosure etc. shall be dealt with in the following manner. Please be aware that we will not accept requests by telephone, fax, email, verbally or by any method other than that laid out below.

(1) Please contact GMO Internet for the relevant form (Personal information disclosure request, Personal information amendment request, Notification of purpose of usage request).

(2) Fill in the required details.

(3) If applying in person you will need to supply the following documents.

1) A copy of your Certificate of Residence or certificate of matters in the alien registration records (made within less than a month of submitting the request) and one of the following.

i. Driver's license

ii. Passport copy

iii. Health insurance copy

iv. Pension book copy

v. Alien registration certificate copy

(4) If a proxy is applying on your behalf you will need to supply the following documents.

i. Original copy of a Certificate of Residence of the relevant person

ii. Power of Attorney form

iii. Original Seal Registration Certificate of the person for whom the Power of Attorney form was created
* In case the proxy is a statutory representative, documents verifying the credentials of the representative should be supplied in lieu of the above in addition to one of the following.

iv. The proxyfs driverfs license (copy)

v. The proxyfs passport (copy)

vi. The proxyfs health insurance card (copy)

vii. The proxy's pension book (copy)

viii. The proxy's alien registration card (copy) (5) Please send (2) and (3) (and (4) if the request is being submitted by a proxy) by certified mail to the relevant service (see below) at the following address.

Address
GMO Internet, Japan Registry Personal Information Manager
Cerulean Tower, 26-1 Sakuragaoka-cho, Shibuya-ku Tokyo 150-8512

(6) In regard to requests for notification of purpose of usage and disclosure of personal data, after verifying the identity of the sender of the documents, GMO Internet will send out an invoice for handling fees. Please submit payment by bank transfer to the account listed on the invoice. Any bank transfer costs should be paid by the customer. Handling fees are charged for each service for which information is disclosed. In regard to requests other than notification of purpose of usage and disclosure of personal data, we will proceed as soon as verification is complete
Contents Fee
Handling Fee JPY 5,000 (Not Include Tax)
(7) In regard to requests for notification of purpose of usage and disclosure of personal data, after confirming receipt of payment, GMO Internet will send a response by certified mail.
* If you have any queries regarding the response please inquire at the relevant point of contact listed below 6.

6. Inquiries and Grievances

Please submit any grievances or requests for disclosure in regard to personal information to the points of contact listed below. Please be aware that we will not process requests received in any other form (including visiting our offices in person). GMO Japan Registry Team: http://www.japanregistry.com/contactinfo.php


NOTICE) This English version of Privacy Policy is made based on Japanese original version. GMO Internet does not warrant and guarantee the correctness of this translation. In the case when discrepancy between Japanese version and English version occurs, Japanese version shall prevail.





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GMO Internet, Inc.