Personal Information Protection Policy

Basic Policy on Protection of Personal Information

Risks around Personal Information and Preventive Measures

We, LEAD CREATE Inc., provide services for supporting companies to develop leadership skills and achieve organizational development. Since we acknowledge that the maintenance and management of personal information provided by you is one of our top management priorities, we continue to engage in organizational activities to protect the rights and interests of individuals.

In today’s era of information network, information is actively exchanged internally, externally, domestically and internationally. Such information exchange increases the risk of unauthorized access to information and other risks. We understand that it is indispensable to take measures to prevent such risks as an organization.

In compliance with the laws and regulations, directions and guidelines, we will establish and continue to improve the management system to realize the balanced protection of personal information from the point of view of confidentiality, availability and integrity based on the latest technical trends and other factors. We also educate all our employees regularly. Furthermore, the responsible person in each department examines the daily procedures for handling personal information regularly.

Protection and Availability of Personal Information

We will take security management measures so that all our employees fully understand the objective of the Act on the Protection of Personal Information, which is “to protect rights and interests of individuals”, and protect the personal information provided by you from the risk of leakage, damage, loss and other risks.

Inquiries about this Policy

For inquiries about the details of this Basic Policy on Protection of Personal Information, please reach out to the contact for complaints and inquiries listed below.

Procedures for Handling Personal Information

1Types of Personal Information Collected by Us and Purposes of Use

The personal information to be collected by us and purposes of use of such information are as follows:

Types of Personal Information	Purposes of Use of Personal Information
Personal information of employees and other related persons of our client companies, which is provided by our client companies for us when we provide corporate training, human resource assessment, consulting or other services	Operation of corporate training and human resource assessment; provision of consulting services; preparation of deliverables of such services; and research and development of new services
Personal information of applicants and participants for briefings, seminars and other events sponsored by us	Delivery of information on briefings, seminars and other events sponsored by us
Personal information of consultants who have signed a partnership agreement with us	Internal education for improving our services; delivery of information on briefings, seminars and other events sponsored by us; business communication; and provision of explanations and proposals for prospective client companies
Personal information of our employees	Employment management (such as payment of salaries and remuneration, tax declaration, social insurance, attendance management and health care); performance evaluation; assignment; business communication (such as communication with clients and partner companies, emergency communication and in-house newsletters); operation of IT equipment (such as personal computers and smartphones); system operation; advertisement of training, seminars and other events; and educational materials (movies and photographs)
Personal information of our job applicants	Communication regarding information on screening and selection results

We will disclose the purposes of use of personal information to an individual, collect personal information fairly and lawfully and use it only to the extent necessary to achieve such purposes of use. If we need to use the personal information for purposes other than those listed above, we will specify and publish such new purposes of use.

2Provision of Personal Information for Contractor

We may provide personal information for a contractor for the performance of our services. When we provide personal information to a contractor, we will supervise such contractor to manage such personal information in accordance the laws and regulations as well as standards established by us. Furthermore, when contracting for our services with a contractor ends, we will collect personal information from such contractor or confirm that such contractor has deleted personal information.

3Provision of Personal Information for Third Party

We will not provide personal information for a third party except when we:

• provide personal information subject to the prior consent of an individual;
• provide personal information in accordance with the laws and regulations; or
• are of the opinion that provision of personal information is necessary for the protection of life, body or property of an individual, public benefit or benefit of an individual.

4Transfer of Personal Information to Countries outside EEA

If we collect personal information of persons who reside in the European Economic Area consisting of the EU members states, Norway, Iceland and Liechtenstein (collectively, the “EEA”), we may transfer such personal information to a joint user or contractor, who reside in a country outside the EEA including Japan to allow such joint user or contractor to process such personal information to the extent necessary for the purposes of use in the event of joint use of personal information or contracting for our services. For your information, the European Commission has adopted its adequacy decision on Japan by acknowledging that the data protection act in Japan offers the same level of data protection as that in the EEA.

5Anonymously Processed Information

When we prepare anonymously processed information, we will publish the categories of information on individuals to be included in such anonymously processed information in accordance with the laws and regulations.

6Retention Period

We have the right to retain personal information until we no longer need to use such personal information for our services.

7Voluntary Disclosure of Personal Information and Effect of Non-Provision

Provision of personal information is voluntary. However, not providing personal information or providing wrong information may result in your inability to send inquiries to us or our inability to respond to your requests.
If you do not complete fields other than the required fields, we may not be able to provide you with information you desire.

Contact for Complaints and Inquiries regarding Personal Information

We will receive and promptly respond to your complaints and inquiries regarding the handling of personal information via the following contact information:

LEAD CREATE Inc.

Personal Information Protection Manager	Information Security Promotion Office
Address	8th Floor, Shibuya 3-chome Square Bldg., 3-5-16 Shibuya, Shibuya-ku, Tokyo 150-0002 Japan
E-Mail	lc.cpl@jp-leadcreate.com
Tel	+81(3)-5766-1940

Request for Disclosure of Personal Data in Our Possession

1Information on Disclosure Request Form

If you wish to request disclosure, correction, deletion, suspension of use, restriction of use, withdrawal of consent or data portability or make other requests regarding the personal data in our possession, please call us at the number below. We will send you information on a request form after verifying your identity.

Contact:

LEAD CREATE Inc.
8th Floor, Shibuya 3-chome Square Bldg., 3-5-16 Shibuya, Shibuya-ku, Tokyo 150-0002 Japan
Personal Information Protection Manager:Information Security Promotion Office
TEL: +81(3)-5766-1940

2Service Fee

A service fee of 1,000 yen (excluding taxes) may be charged for each request.