AGREEMENT Personal Information Disclosure Items Agreement

Organization: I-ne Co., Ltd.
Address: 8F Midosuji Daibiru, 4-1-2, Minami Kyuhojimachi, Chuo-ku, Osaka-shi,Osaka 5410058 JAPAN
Representative: Yohei Onishi, Chief Executive Officer
Personal Information Protection Manager: Hiroshi Sato
Contact: See “5. Inquiries and Grievances on Our Handling of Personal Information”

1. Purposes of Use of Personal Information

   We will use personal information within the scope necessary to achieve the following operations and purposes of use.

   1. １) Operations

      1. Planning, development, operation, manufacturing and sale of cosmetics, beauty appliances and other beauty-related products, and planning, administration and management of retail shops
      2. Planning, development, manufacturing and sale of toiletries and healthcare-related products
      3. E-commerce business

   2. ２) Purposes of Use

      We will use the personal information we acquire (referring to all information disclosed to us which enables the information provider to be directly or indirectly identified as an individual from that personal information when personal information has been provided; hereinafter the same) only for the following purposes.

      Type of Personal Information		Purposes of Use
      Information on visitors to websites operated by our company	Personal information of customers who have viewed or have considered purchasing products on the e-commerce sites operated by our company	To respond to inquiries To use postal mail, direct mail (including contact by e-mail or various social networking sites; hereinafter the same) or the telephone (including the use of SMS using your telephone number; hereinafter the same) to send catalogs and provide guidance on the products you have considered, and give notifications on information relating to various products and services, including new products To request your participation in various monitor programs and questionnaires To conduct marketing and sales promotions To prepare statistical data for product planning
      Information on product purchasers	Personal information of customers who have purchased our products	To send products To process payments To provide after-sales services To use postal mail, direct mail and the telephone to send catalogs, give guidance on the products you have purchased and the services you have used, and give notifications on information relating to various products and services, including new products To request your participation in various monitor programs and questionnaires To refer and register to an information sharing system for product guidance and re-sale prevention To conduct marketing and sales promotions To prepare statistical data for product planning
      Information on campaign applicants	Personal information of customers who have entered campaigns and contests held by our company	To confirm application eligibility, conduct lotteries, send prizes, and to fulfill the other purposes stated in the terms and conditions of the campaign To use postal mail, direct mail and the telephone to send catalogs, give guidance on the products you have purchased and the services you have used, and give notifications on information relating to various products and services, including new products To request your participation in various monitor programs and questionnaires To conduct marketing and sales promotions To prepare statistical data for product planning
      Information on e-mail newsletter subscribers and direct mail recipients	Personal information of customers who have applied to subscribe to our e-mail newsletter and customers who have consented to being sent our e-mail newsletter or direct mail	To send e-mail newsletters or direct mails To use postal mail, direct mail or the telephone to send catalogs, give guidance on the products you have purchased and the services you have used, and give notifications on information relating to various products and services, including new products To conduct marketing and sales promotions To prepare statistical data for product planning
      Inquiry information	Personal information of customers who have made an inquiry via our website, product sales pages or call center	To respond to inquiries To store the records of our response To request your participation in various monitor programs and questionnaires To improve the quality of products and services To give notifications on information relating to various products and services, including new products
      Information on members	Personal information of members (The applicable personal information of customers includes names, addresses, telephone numbers, dates of birth, ages, gender, e-mail addresses, occupations, credit card numbers and other credit card related information, history of purchasing our products, history of making inquiries and responses to various questionnaires, etc.)	To send our products and promotional materials To make a selection when you enter a contest To aggregate questionnaires to improve services To announce events and campaigns To request your participation in various monitor programs and questionnaires To verify your identity when disclosing, changing, adding or deleting registered information To conduct marketing and sales promotions To prepare statistical data for product planning To use postal mail, direct mail or the telephone to send catalogs, give guidance on the products you have purchased and the services you have used, give notifications on information relating to various products and services, including new products, and otherwise contact you within the scope necessary of our operations, etc.
      Information on our other customers	Personal information of customers who have participated in events planned and operated by our company	To manage and operate events To request your participation in various monitor programs and questionnaires To announce events and campaigns To use postal mail, direct mail or the telephone to send catalogs, give guidance on the products you have purchased and the services you have used, give notifications on information relating to various products and services, including new products, and otherwise contact you within the scope necessary of our operations, etc. To conduct marketing and sales promotions To prepare statistical data for product planning
      Information entrusted to us	Personal information entrusted to us for partial or complete processing by other business operators and organizations	To appropriately and smoothly execute the applicable operations entrusted to us *However, we will not allow personal information to be used beyond the scope of the purposes listed in this table.
      Information on business partners	Personal information of our business partners	To make contact and respond in operations and to manage contractual relationships To otherwise send guidance on our products and services
      Information on job applicants	Personal information of those who have applied to be hired by our company and those who have been referred to us by a staffing agency for the purpose of screening to be hired by us	To screen those seeking to be hired To prepare statistical data on personnel and hiring
      Information on employees	Personal information of our employees	To manage employment
      Information on former employees	Personal information of our former employees	To comply with labor-related laws and ordinances, fulfill labor contracts, and make contact in emergencies
      Information on shareholders	Personal information on shareholders	To perform shareholder management operations including exercising rights and fulfilling obligations based on the Companies Act, providing various benefits from our company in relation to your status as a shareholder, and preparing shareholder data according to prescribed standards based on various laws and ordinances
      Specific personal information	Specific personal information of employees, prospective employees in hiring activities, external experts and shareholders, etc.	To execute administrative work to enter the identity numbers of employees, prospective employees in hiring activities, external experts, shareholders and others based on laws and ordinances on documents such as earned income tax certificate slips, payment statements, and health insurance and welfare annuity insurance insured person qualification notifications, and to then submit those documents to administrative bodies, health insurance associations and other organizations

   3. ３) Use of Logs and Cookies

      When you access our website, we record information on your operations in the form of an access log. This log does not contain information which can identify individuals. Nevertheless, we collect this information to improve the convenience of the site in the future, investigate the causes when problems occur, and to prepare statistics on and analyze the usage status. We do not use that information for any other purpose.

      In addition, we may send information called cookies (including web beacons, UIDs, and other technologies; hereinafter simply “Cookies”) to your computer through a web browser to manage communications on the various e-commerce sites operated by our company (hereinafter “Our E-commerce Sites”). Cookies are necessary to maintain screen transitions and to allow you to perform operations such as shopping on Our E-commerce Sites. Please consent to the use of Cookies and register when using Our E-commerce Sites.

      Please note that you may not be able to use Our E-commerce Sites properly if you disable Cookies. We acquire the following information with Cookies.

      • Information on device identification of telecommunication terminals such as terminal IDs and mobile advertising identifiers
      • Information on the operating system of telecommunication terminals and information on connection to the Internet
      • Location information
      • Referrers
      • IP addresses
      • URLs you have viewed and timestamps on the time and date on which you viewed those URLs
      • Server log information other than the above
      • Information on products or services you have displayed or searched for

   4. ４) Use of Access Log Information

      We record and use your IP address and access log information on Our E-commerce Sites to grasp the usage situation of Our E-commerce Sites.

   5. ５) Our E-commerce Sites on Platforms Operated by Third Parties

      We promise to make every effort to protect your privacy on Our E-commerce Sites on platforms operated by third parties as well. However, please understand that the regulations stipulated by those platforms may take precedence. In addition, if you click on a link of a third party such as another company on an e-commerce site operated by our company, that linked site is outside the scope of our responsibility.

2. Measures Taken for Safety Management

   We take the necessary and appropriate measures to prevent the leak, loss and damage of the personal data we handle and to otherwise safely manage personal data (hereinafter “Safety Management Measures”) as following in compliance with the relevant laws, ordinances, guidelines and other norms.

   1. １) Formulation of a Basic Policy

      We have formulated a Privacy Policy (https://i-ne.co.jp/policy/privacy/). This is a basic policy to ensure the appropriate handling of personal data.

   2. 2) Establishment of Rules on the Handling of Personal Data

      We have formulated internal regulations stipulating how we handle personal data, the persons responsible for and in charge of handling personal data, and their roles.

   3. 3) Systematic Safety Management Measures

      We have appointed a Personal Information Protection Manager as the person responsible for the handling of personal information in our organizational structure. Under the Personal Information Protection Manager, we are developing our personal information protection management system and implementing controls on personal information protection within our company.

      In addition, we have established a structure in which we ensure employees (including contract employees and temporary employees) comply with our internal regulations on Safety Management Measures. In this structure, if someone learns of facts or sees signs of an employee violating laws or our internal regulations, that person can report and communicate those facts or signs to the persons responsible including the Personal Information Protection Manager.

      Furthermore, if we outsource operations involving the handling of personal information, we strictly supervise those subcontractors. We monitor subcontractors to ensure that they also strictly maintain Safety Management Measures for personal information.

   4. 4) Human Safety Management Measures

      We periodically provide education and training on the appropriate handling of personal information to our employees.

   5. 5) Physical and Technical Safety Management Measures

      We manage the entry and exit of employees and third parties in zones where we handle personal data. At the same time, we take measures to prevent the theft of documents, media and equipment containing personal information such as with locked storage.

      Moreover, we control access to personal data and the information systems which we use to handle personal data, take measures against computer viruses and malicious software, monitor information systems, and implement other measures. In addition, we use communications encrypted with a Secure Socket Layer (SSL) on pages where personal information is sent and received to take measures to ensure external third parties are unable to intercept communications containing your personal information.

   6. 6) Grasping of the External Environment

      We only store personal data in Japan.

3. Disclosure and Correction Procedures

   We accept requests from individuals for the disclosure, notification of the purposes of use, revision, suspension of use and suspension of provision to third parties (hereinafter “Disclosure etc.”) of the personal data we hold and third-party provision records. At such a time, we will confirm your identity based on the information you have registered with us.

   1. 1) Where to Request Disclosure Etc.

      1. Complaints & Inquiries Desk
      2. If you wish to request Disclosure etc. by postal mail, please attach the necessary documents to the prescribed request form and then send it to the address below.
         I-ne Complaints & Inquiries Desk
         6-1-21, Nakanoshima, Kita-ku, Osaka, 530-0005, Japan

   2. 2) What You Need to Submit

      1. Form to request the Disclosure etc. of personal information
      2. Documents to verify your identity (driver’s license, passport, My Number card (front), etc.)
      3. In the case of a legal representative, documents confirming legal authority of representation in addition to the documents in (2)
      4. In the case of a discretionary representative, power of attorney form as prescribed by our company and your registered seal certificate in addition to the documents in (2)

      *Please submit documents upon blotting out any sensitive information, such as your permanent domicile, stated on them. If we receive documents with such information that you have not blotted out, we will not acquire them by blotting out that information.

   3. 3) Handling Fee

      Please understand that we will charge a handling fee of 1,000 yen per request for disclosure of personal information or notification of purposes of use.

      If you make a request by postal mail, we will charge you the handling fee by bank transfer or similar means.

      *Please contact us using the information in “Where to Contact Us about Our Handling of Personal Information” below for the specific procedures to request Disclosure etc.

4. Shared Use of Personal Information

   We share the use of personal information as follows.

   1. 1) Items of Personal Information Used on a Shared Basis

      Names, addresses, dates of birth, telephone numbers, fax numbers, e-mail addresses, gender, purchase dates and product purchase information

   2. 2) Scope of Parties Using Personal Information on a Shared Basis

      Our group companies*

   3. 3) Purposes of Use for Parties Using Personal Information on a Shared Basis

      For “1. Purposes of Use of Personal Information”

   4. 4) Name of the Party with Responsibility for the Management of Personal Information Used on a Shared Basis

      I-ne Co., Ltd.

   5. 5) Method of Acquiring Personal Information

      Acquisition from individuals and from our systems

   *The following are our group companies which use personal information on a shared basis with our company.

   • Dr. Syuwan Co., Ltd.
   • Endeavour Co., Ltd.

5. Inquiries and Grievances on Our Handling of Personal Information

   Please contact us at the following desk to make inquiries and submit grievances on our handling of personal information.

   ■ Where to Contact Us about Our Handling of Personal Information

   I-ne Complaints & Inquiries Desk

   • TEL：0120-333-476
   • Hours we are available by telephone: 9 a.m. to 6 p.m. (excluding Saturdays, Sundays, public holidays, the year-end/New Year’s holiday period, summer holidays and company holidays)

   *You can also use the e-mail form below to contact us.
   https://i-ne.co.jp/contact/

   In addition, we are a member of the following personal information protection organization accredited by law. This organization accepts grievances and inquiries about our handling of personal information.

   ■ Name of the Accredited Personal Information Protection Organization and Where to Request Resolution of Grievances

   *This organization only accepts grievances on handling of personal information.

   Accredited Personal Information Protection Organization
   Japan Institute for Promotion of Economy and Community (JIPDEC)

   • Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo, 106-0032
   • 03-5860-7565／0120-700-779