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Personal Information Protection Policy

As a matter of our corporate philosophy, we aim to love people and the earth, treat them tenderly and honestly. We offer the latest nutritional therapy based on evidence for a better future in a society where the need for nutritional therapy is increasing, through various activities of manufacturing and selling food for nutritional therapy, food for swallowing difficulty, etc.

1. 1.Proper acquisition/use and provision of personal information

   If we acquire personal information, we clarify the purpose of its use. In addition, for use and provision of personal information, we take measures to use it within the scope of the purpose of use and not to use it for other purposes.

2. 2. Proper management method of personal information

   In terms of technologies and organizational systems, we take reasonable and safe management measures against leakage, loss, damage, etc. of personal information, and manage personal information correctly and properly concerning prevention and correction of risks involving personal information.

3. 3. Compliance with laws and regulations, and other guidelines

   In carrying out business to handle personal information, we comply with laws and regulations concerning personal information, “Requirements of Personal Information Protection Management System” (JIS Q 15001 2006), and the industry guideline, and act according to the matters/procedures specified in our “Personal Information Protection Rule.”

4. 4. Continual improvement of Personal Information Protection Management System

   Concerning our Personal Information Protection Management System about personal information protection, we review it according to changes in environments within and outside our company; operate the management cycle of formulation, system preparation, implementation, evaluation, and review; make continual improvement; and exert our utmost efforts to maintain proper management of personal information.

5. 5. Complaints/any other consultations concerning personal information

   We appoint a responsible person for the Complaint and Consultation Office and take proper actions for complaint and consultation concerning personal information from customers and other persons who have provided personal information (including our employees). In addition, if a person (including our employees) desires content confirmation, correction, deletion, etc. of personal information, we make quick arrangements within a reasonable scope.

Handling of personal information

We appoint a responsible person for the Complaint and Consultation Office and take proper actions for complaint and consultation concerning personal information from customers and other persons who have provided personal information (including our employees). In addition, if a person (including our employees) desires content confirmation, correction, deletion, etc. of personal information, we make quick arrangements within a reasonable scope.

1. 1. What is personal information?

   Personal information means information concerning a person which can identify the specific individual by name, address, telephone number, fax number, e-mail address, image, etc.

2. 2. Personal information that we acquire and the purpose of its use

   We use personal information of customers, etc. for the following purposes.

   Customer information	Dispatch of goods and response to inquiry; Related services after sales; Announcement of information concerning goods/services; Collection of questionnaire concerning goods/services, etc. and posting of collection results on advertisement/sales promotion goods; Selection of prizes for customer campaign, etc. and dispatch of the prizes to the winners; Posting of statistical analysis information which does not identify any individual on advertisement/sales promotion goods; and Reference information on good development and service development.
   Shareholder information	Information disclosure; and Liaison.
   Client information	Business of receiving/placing orders; Business of invoicing and payment; and Response to inquiry
   Employee information	Management of personnel and labor; Business management; and Health management.
   Customer information	Confirmation of the content of placed and received orders; Response to inquiry Security management.
   Job applicant information	Study and decision of employment
   Gift information	Dispatch of goods and response to inquiry

   * Acquisition of credit card information

   The purpose of our acquiring credit card information (card name/card number/valid term) from customers, the acquirer of credit information, the receiver of credit information, and details of information keeping are as follows:

   1. Purpose of use: To settle the cost of goods
   2. Acquirer of information: Nutri Co., Ltd.
   3. Receiver of information (settlement agency): SMBC Finance Service Co., Ltd.
   4. Information keeping: The above settlement agency keeps it for 93 days after completion of the purpose of use and the accompanying business.

3. 3. Protection and management of personal information

   Regardless of whether personal information that we keep is the data itself or constitutes a database, we keep/manage it properly and carefully and exert efforts to take reasonable safety measures in terms of both technology and management by giving thorough provision of company rules and training for our officers and employees in order to prevent such risks as unauthorized access to, loss of, destruction of, alteration of, and leakage of personal information. In addition, if improvement is found necessary as a result of internal audit, by an example of a security accident which occurs at another company, at the request of customers, etc., we will immediately correct it.

4. 4. Request of disclosure, correction/deletion, use suspension, etc.

   You may request us to disclose personal information of customers, etc. that we keep. In addition, you may request us to correct/delete personal information as a result of disclosure. If you, our customer, want us to disclose/correct/delete their own personal information, please contact our “Office for Complaint and Consultation concerning Handling of Personal Information” as below.

   In addition, please note that we may ask you to identify yourself when we take such procedures.

   We may also ask you to pay an actual amount as our commission to cover such work.

5. 5. Provision of personal information for a third party

   We will not provide a third party with personal information without obtaining a prior consent from the person. Please note, however, in advance that in the following cases we may provide a third party with personal information without obtaining prior consent of the person.

   1. If provision of personal information is based on laws and regulations;
   2. If it is urgently necessary to do so for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the person;
   3. If it is necessary in particular to do so to improve public health or to promote sound growth of children and it is difficult to obtain the consent of the person; and
   4. If it is necessary to cooperate with a state organ or a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations, and obtaining the consent of the person is likely to impede the execution of the affairs concerned.

   In addition, the following cases shall not fall under a third party for us to need to obtain the consent of a customer in providing personal information.

   1. If handling of personal information is wholly or partially entrusted within the scope necessary to achieve the purpose of use; and
   2. If personal information is provided due to business transfer by merger or any other affairs.

6. 6. Entrustment of handling of personal information

   We entrust a third party with a part of our business in business operation in order to provide our customers with better service. We may entrust personal information to sub-contractors. In this case, we select sub-contractors that we judge to handle personal information properly, decide necessary matters to prevent leakage of personal information of our customers by specifying proper management and confidentiality of personal information in contracts, etc., and have them carry out proper management of personal information.

7. 7. Voluntariness

   Whether or not you provide us with your personal information is voluntary. If you are unable to provide us with your personal information, we may fail to provide you with your desired information and service.