Handling of Personal Information

Cloud CIRCUS, Inc. (hereinafter referred to as the “Company”) shall publicly announce rules for handling personal information prior to the handling thereof in accordance with the Personal Information Protection Policy.

1. Purpose of Use of Personal Information
The Company shall acquire and use personal information necessary for the Startia group’s business activities within the scope of purpose of use.

1) Purpose of use of personal information concerning the Company’s customers and business partners (including [potential] customers and business partners of the Company’s customers and business partners):

・Provision of information concerning products and services
・Sales and provision of products and services
・Information provision concerning products and services of alliance partners
・Introduction of seminars, exhibitions, and events
・Offering products and services-related support
・Handling of inquiries
・Provision of various membership services
・Various analyses, questionnaire surveys, and analyses for the purpose of product development, feature improvement, and service quality improvement
・Analysis of curiosity and interest of customers and business partners
・Fulfillment of a contract
・Business negotiations, meetings, and communications
・Control of access to the Company’s facilities
・Industry-university collaboration research

2) Purpose of use of personal information provided with respect to services entrusted by the entruster as a result of the Company’s acceptance of the entrusted services:

・Fulfillment of a contract with the entruster (on the condition of the use within the scope of purpose of use by the entruster)

3) Purpose of use of personal information of shareholders and those who consider purchasing shares:

・Exercise of rights and performance of obligations under the Companies Act
・Implementation of various shareholder-related measures including, but not limited to shareholder incentives
・Shareholder management
・Provision of IR information, etc.

4) Purpose of use of personal information concerning job applicants, employees, and retirees:

・Job applicants
　　Dissemination of recruitment information to job applicants and screening
　　Recruitment service management in the Company
・Employees and retirees
　　Personnel and labor management, and fulfillment of other obligations provided for in labor-related laws and regulations, tax-related laws and regulations, and social welfare-related laws and regulations

5) Others

・Purpose of use to which the individual concerned agreed

2. Acquisition of Personal Information
The Company acquires personal information and corporate information (the representative’s name, phone numbers, address, etc.) by utilizing direct inquiries from the individual concerned via a document, phone call, and website inquiry form; website access history; information published on a telephone directory and the internet; various information provision services, etc.

3. Management of Personal Information
The Company shall properly manage the acquired personal information in accordance with laws and regulations, other codes, guidelines, and internal rules. The Company shall also properly supervise its employees and entrustees.

4. Provision of Personal Information to Third Parties
The Company shall not provide the acquired personal information to any third party without obtaining the consent from the individual concerned, unless otherwise provided for by laws and regulations, etc.

5. Entrustment of Personal Information
The Company may entrust a third party with the personal information acquired within the scope of the purpose of use of personal information, limited to the personal information items which are minimally required for the performance of the services. In the case of entrusting personal information to a third party, the Company shall select an appropriate entrustee and supervise the entrustee on its own responsibility.

6. Joint use of Personal Information
The Company shall not, in principle, jointly use the personal data with others. Provided, however, that the Company may jointly use the personal data with respect to the following items only with the following group companies within the scope prescribed in 1. Purpose of Use of Personal Information:

1) Personal data items for joint use

・Name, company name, department name, phone numbers, FAX numbers, email address, etc.

2) Group companies eligible for the joint use

・Parent company
Startia Holdings, Inc. (joint use manager)

・Consolidated subsidiary companies
　Startia, Inc.
　　　　Cloud CIRCUS, Inc.
　 Startia Will, Inc.
　Startia Raise, Inc.
　　　　Startia Lead, Inc.
　 C-design Co., Ltd.
　BCMEDIA Co., Ltd.
　NOS Ltd.

7. Request for Personal Information Disclosure and Complaints
In the case of receiving a request, etc. for the notification of the purpose of use, disclosure, correction, suspension of use, deletion, or refusal of provision to third parties, etc. of the personal information which the Company manages, complaints or other inquiries, etc. from the individual concerned, the Company shall promptly take action within a reasonable extent according to the following procedures set forth by the Company.

1) Method of request for disclosure

A request for disclosure, etc. is accepted by mail only. Please make an inquiry using the inquiry form before sending such a request. After checking the details of a request, the Company will send a prescribed form. Please enter necessary information in the form and send it to the Personal Information Inquiry Desk together with a document for identity verification and a fee.

2) Identity verification document

A document for identity verification shall be limited to those valid at the time of acceptance by the Company or those prepared within three months therefrom. If the document for identity verification contains the individual number (My Number) and personal information requiring consideration, please make sure to black out the relevant area. If the document for identity verification which you sent to the Company contains the relevant information, the Company will black out the relevant information in accordance with laws and regulations.

・If requested by the individual concerned:
　A copy of either of the following documents for identity verification:

　　Driver’s license
　　Passport
　　My Number Card
　　Health insurance card (various types)
　　Pension booklet (various types)
　　Copy of resident record

・If requested by the agent:
　A power of attorney from the individual concerned and a copy of a resident card of the individual concerned, and a copy of either of the following documents for identity verification of the agent:

　　Driver’s license
　　Passport
　　My Number Card
　　Health insurance card (various types)
　　Pension booklet (various types)
　　Copy of resident record

3) Fees and collection method thereof

・The Company will collect a postal monetary order with fixed amount in the amount of 1,000 yen per case of filing a request for disclosure and the notification of the purpose of use, etc. (the issuance fee for a postal monetary order with fixed amount, etc. is to be borne by the individual concerned).
・This fee includes a registered mail fee to be charged when the Company mails the requested document to the individual concerned.
・If any other actual costs incur, such costs will be separately billed to the individual concerned.
・No fees will be charged for the correction, addition, deletion, and suspension of use of the personal information.

4) Personal Information Inquiry Desk

・Please send a request for disclosure, etc. to the Personal Information Inquiry Desk.
・Any complaints and consultations concerning the personal information protection management systems handling the personal information will be accepted at the Personal Information Inquiry Desk.
・Any other inquiries concerning services offered by the Company will be accepted at the respective inquiry desks.

[For Inquiries concerning personal information]

For inquiries: Personal Information Inquiry Desk

Personal Information Manager: Director

Email: email inquiry form

If you refuse to provide necessary information including personal information, the Company may not be able to respond to your inquiry.

Address: Shinjuku Monolith Building 19th Floor, 2-3-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 163-0919