We, Axell Corporation("Axell") has established and endeavors to implement on a continuous basis our Privacy Policy, recognizing that to protect personal information provided to Axell is so important, in order to pursue full compliance with the Act on the Protection of Personal Information (Law No. 57 2003) and other relevant laws and ordinances of Japan ("the Law").

1.Our Responsive Action to Enforcement of the Law

Along with the establishment of our Privacy Policy, Axell endeavors to implement educational activities for employees for the purpose of company-wide full recognition of the importance of personal information in each stage of handling of personal information, including acquisition, use, holding, transfer and deletion.

2.Strengthening Information Related Security Measures for Protection of Personal Information

Axell endeavors to strengthen the information related security measures, including techniques to prevent unauthorized access and computer viruses, in order to protect personal information under our control from unauthorized access, loss, destruction, alteration and leakage.

3.Active Supervision of Subcontractors

In the event that Axell entrusts subcontractors with the handling of the personal information held by it, from the aspect of protection of personal information Axell selects subcontractors carefully and requests such subcontractors to take appropriate measures to safely manage the personal information, and supervise such subcontractors to ensure appropriate responsive action.

4.Strengthening Internal Management System for Protection of Personal Information

Axell endeavors to strengthen its internal Management system, and continuously checks and confirms the enforcement status, to secure proper enforcement of the safety management of personal information.

5.Provision of personal information

Axell recognizes that appropriate protection of personal information is its responsibility, and does not provide any identified personal information to any third parties without consent of that person except in cases as are permitted by the Law.

6.Disclosure, Correction, cessation of use and deletion concerning the personal information

Axell confirms that under the Law a person has the right to request a notice of the intended purposes for use, disclosure, correction or addition or deletion, cessation of use, elimination, or cessation of the provision to any third parties, concerning his or her personal information, and, upon request for any of the foregoing, Axell will respond promptly pursuant to the procedures prescribed by Axell.

7.Establishment of Service Desk for Customer Complaints, etc.

Axell is establishing Personal Information Protection Section to respond suitably and appropriately to complaints in regard to the handling of personal information provided by the complainer to Axell.

Axell will review the above Privacy Policy at an appropriate time and strive to make improvements on a continuous basis.

Prescribed: March 28, 2005
Revised (latest): April 16, 2007
Kazunori Matsuura
Representative Director & President
Axell Corporation

Personal Information Protection Section, Management Department, Axell Corporation
E-mail：privacy@axell.co.jp

1.Intended Use of Personal Information

Axell will use all or a part of the personal information provided to Axell for the following purposes:

• [1]To respond to inquiries or provide consultation;
• [2]To provide support for products;
• [3]To develop products, conduct questionnaire surveys, conduct marketing research, and/or perform monitoring;
• [4]To have discussions regarding products;
• [5]To send information on exhibitions, events, etc.;
• [6]To provide information on products and services; and
• [7]For other business affairs related to or incidental to the business affairs listed above.

In the event that any intended purpose is individually and separately informed or announced, the personal information is used for such purpose.

2.Provision of Personal Information

Axell does not disclose or provide to any third party the personal information provided by any customer, except where:

• [1]The customer has given prior consent on the disclosure or provision of the personal information;
• [2]The disclosure of the information is requested by a court, police or other national authorities or any organization similar thereto;
• [3]Axell considers it necessary in its reasonable judgment to disclose or provide the personal information in order to protect life, health and/or property, etc., of Axell (including distributors and agencies of Axell) and/or any third party; and
• [4]Handling by distributors, agencies and others of Axell is considered to be appropriate in order to properly respond to inquires from customers or provide support (in this case, Axell will provide such distributors, agencies and others with the name, address, telephone number and/or e-mail address of a customer to the extent necessary, via prevailing means of communication, etc. The customer may request Axell to suspend the provision of his or her personal information.).

3.Outsourcing of Handling of Personal Information

In order to achieve the purposes set forth in Paragraph 1 above, Axell may outsource the handling of the personal information of customers to any external subcontractors of Axell. In such case, from the aspect of protection of the personal information Axell selects proper subcontractors carefully and requests such subcontractors to take appropriate measures to safely manage the personal information and supervise such subcontractors to ensure appropriate responsive action.

4.Joint Use

Axell may use the personal information of customer jointly within scope provided below to achieve any of purposes set forth in Paragraph 1above:

• [1]Items of personal information that may be used jointly
  All the personal information of customer, excluding personal information that the customer has specifically requested not to be used jointly.
• [2]Scope of the entities that will use the personal information
  Axell Group Companies (click here)
• [3]The purpose of use for joint users
  Same as provided in Paragraph 1 above
• [4] Name of the party responsible for the management of the said personal information
  Axell Corporation

5.Cookie Policy

In order to provide customers with improved services, cookies may be used on websites operated by Axell. Depending on the browser a customer uses, the customer may be able to change its settings so as to inactivate the cookie function. As a consequence however the customer may not be able to access some or any of the services provided on our websites.

6.Usage of tool for improving service

Axell may collect, analyse, and use information related to customers' usage of our websites using cookies and similar technologies in order to improve the websites and services offered to customers. The websites primarily use the following tool for this purpose:
■Google Analytics
Tool provider: Google Inc.
Google Analytics terms of service
Google privacy policy
Google Analytics analyses customers' use of the websites (access, traffic, routing, etc.) using cookies issued by the Axell. Axell receives the results of that analysis from Google Inc. and uses them to assess use of the websites.

7.Request for Disclosure of Personal Information, etc. / Service Desk for Customer Complaint or Consultation

Point of contact for any notice of intended purposes for use, or any request on disclosure, correction or addition or deletion, suspension of use, elimination, or suspension of the provision to any third parties, concerning the personal information provided to Axell and any complaint or consultation on the personal information is as follows:

Personal Information Protection section,
Management Department, Axell Corporation
E-mail：privacy@axell.co.jp

With respect to a request for disclosure of personal information, etc., any customer will be required to submit certain documents so as to confirm that the request is made by the customer himself or herself or his or her agent. In the case of any notice of intended purpose for use, etc., the customer may be requested to bear the relevant cost, such as postage. For further information, please contact the point of contact mentioned above.

1.Name of Business Enterprise

AXELL CORPORATION (the "Company")

2.Compliance with Applicable Laws and Regulations and Guidelines

When handling Individual Numbers and Specific Personal Information* (hereinafter collectively called "Specific Personal Information"), the Company will observe and comply with "Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (Gyosei Tetsuzuki ni okeru Tokutei no Kojin wo Shikibetsu suru tameno Bango no Riyo nado ni kansuru Horitsu)" ("Individual Number Act"), "Guidelines on Appropriate Handling of Specific Personal Information (Tokutei Kojin Joho no Tekisei na Toriatsukai ni kansuru Guidelines) (Business Enterprise Version)", "Act on the Protection of Personal Information (Kojin Joho no Hogo ni kansuru Horitsu)" ("Personal Information Protection Act") and various other guidelines promulgated by the Personal Information Protection Commission.
* Specific Personal Information refers to personal information containing the Individual Number therein.

3.Purpose of Use

The Company will use the Specific Personal Information provided to us only for the purposes below:

• [1]Specific Personal Information of Customers and Suppliers of the Company:
• ・ To prepare payment records (Shiharai Chosho) with respect to real estate transactions; and
• ・ To prepare payment records (Shiharai Chosho) with respect to remuneration, fees, contract payments and rewards.
• [2]Specific Personal Information of Shareholders of the Company:
• ・ To prepare payment records (Shiharai Chosho) with respect to payment of dividends and distribution of surplus.
• [3]Specific Personal Information of the Employees and Other Staff of the Company:
• Tax-Related Issues:
• ・ To prepare income tax withholding slips (Gensen Choshu Hyo); and
• ・ To provide Specific Personal Information to the Employee Stock Ownership Plan Division to enable the said division to prepare payment records (Shiharai Chosho) for members of an Employee Stock Ownership Plan.
• Social Insurance-Related Issues:
• ・ To file necessary documents for, apply for or claim Employee Health Insurance (Kenko Hoken) or Welfare Pension Insurance (Kosei Nenkin Hoken); and
• ・ To file necessary documents for, apply for, claim or prepare certificates of proof regarding Employment Insurance (Koyo Hoken) or Industrial Injury Insurance (Rosai Hoken).
• [4]Specific Personal Information of a spouse or relatives of the Employees and Other Staff of the Company:
• Tax-Related Issues:
• ・ To prepare income tax withholding slips (Gensen Choshu Hyo).
• Social Insurance-Related Issues:
• ・ To file necessary documents for Employee Health Insurance (Kenko Hoken) or Welfare Pension Insurance (Kosei Nenkin Hoken).

4.Issues Related to Security Control Measures

The Company will comply with "Individual Number and Specific Personal Information Handling Regulations", to be formulated separately for the purposes of preventing divulgence, loss or destruction of Specific Personal Information and implementing appropriate management of the Individual Numbers.

5.Management of Outsourcing

The Company may outsource certain services, such as the management of Specific Personal Information, to a third party. In such cases, pursuant to provisions of the Individual Number Act and the Personal Information Protection Act, the Company will supervise and exert appropriate and necessary control over such third-party contractors.

6.Continual Improvement

The Company will commit to continual improvement of the handling process of Specific Personal Information.

7.Disclosure of Specific Personal Information

The Company may disclose personal data related to Specific Personal Information at the request of the information provider (the "Person") or his/her agent. The Company will honor the request without delay, unless the request falls under one of the following situations:

• ・ Such disclosure may lead to death, injury, damages to property or other impairment or destruction of rights or interests of the Person or a third party;
• ・ Such disclosure may result in the substantial obstruction of the regular business operations of the Company; or
• ・ Such disclosure contravenes applicable laws and regulations.

For further inquiries regarding the disclosure of Specific Personal Information, etc., please feel free to send an e-mail to:

AXELL CORPORATION
Management Department
Specific Personal Information Representatives
E-mail：privacy@axell.co.jp

8.Contact Information: Inquiries and Complaints

For inquiries or complaints related to the handling of Specific Personal Information, please contact us as follows:

AXELL CORPORATION
Management Department
Specific Personal Information Representatives
E-mail：privacy@axell.co.jp

May 30, 2017
AXELL CORPORATION
Kazunori Matsuura
President & Representative Director