Without resting on our laurels of having obtained the information security certification, we will continue our ongoing effort to realize more appropriate information handling and further enhance information security.

We are a company that engages in the outsourced development business in the advanced information-communications society. In our effort to maintain our company, therefore, we must ensure the security of mission-critical information (all information assets our company holds and all information assets of customers entrusted to our care) by implementing thorough security measures and must never cause any information security incidents or accidents. Moreover, in an effort to further consolidate our long-accumulated trust relationships with customers and partners, each and every employee must realize and keep always in mind the significance of information security.

Our company’s Basic Policy is shown below:

1. Compliance with laws and regulations
   　We shall observe laws, regulations, and other restrictions as well as contractual requirements related to information security.
2. Establishment of security systems and clarification of responsibility
   　We shall appoint a person responsible for information security management in an effort to promote information security across the board. We shall also appoint information security committee members in each division to actively conduct security activities.
3. Protection and management of information assets
   As part of effort to implement basic policy, we shall develop internal rules and implement protection and management best suited for each information asset through organizational, human, physical, and technological measures. All employees (including executives and contract employees) shall abide by the internal rules.
4. Implementation of education and training
   We strive to develop and maintain our ability to protect and manage information assets while enhancing awareness of information security among all employees by providing information security education.
5. Outsourcing
   When outsourcing work related to information security to other companies or individuals, we shall select them based on their qualification regarding information security and exchange an appropriate agreement including nondisclosure clauses with consignees. We shall also give guidance to and manage consignees to ensure that they handle information in a proper manner in accordance with our Basic Policy and internal rules.
6. Implementation of audits
   We shall have an auditing system in place and systematically implement internal audits to ensure compliance with Basic Policy and internal rules.
7. Punitive measures against noncompliance
   We shall take disciplinary actions based on the rules of employment against employees who have violated the Basic Policy or internal rules.
8. Continuous improvement
   　　　 We shall conduct time to time monitoring to ensure proper handling and management of information and implement required corrective and preventive actions. We shall also assess risks in response to changes in environment and review and improve our Basic Policy on an ongoing basis.

Established on November 1, 2007
Revised on January 28, 2009



Makoto Tanimura President VORTECHS Corporation

Under the principle of respect for individuals, VORTECHS regards the proper handling of personal information as part of its social responsibility as a company and shall protect and respect personal information based on the following:

1. Personal information shall be used only for the informed or specified purpose or for the purpose explicitly apparent from the nature of information obtained, except in cases where you have agreed beforehand or it is allowed by laws and regulations.
2. We shall not disclose or supply your personal information to third parties except in cases where you have agreed beforehand or it is allowed by laws and regulations.
3. We shall manage personal information properly by providing education on the protection of personal information to executives and other employees on a regular basis and by appointing a person responsible for its protection in every division handling personal information.
4. In an effort to prevent the leakage of personal information, we shall ensure that personal information is managed safely and its security is secured, improved, and corrected appropriately.
5. We shall observe all laws, regulations, and national guidelines regarding the handling of personal information.
6. We shall respond promptly and appropriately to complaints about our handling of personal information and to your (or proxy’s) request to disclose your personal information, for which we have the right of disclosure.

We assume no responsibility whatsoever for any protection of personal information on websites of third parties linked to our website.

Purpose of use of personal information
We shall use personal information you have provided to us for the following purposes. Provided you have agreed to its use, we may also use it for other purposes within the scope of specified purposes:

1. Personal information of customers and partners
   For communication related to products, services, introduction and information of solutions, seminars, exhibitions, event invitations, and courses; marketing activities; and the implementation of questionnaires to improve our services.
2. Personal information provided by a consigner in relation to our consignment business.
   For the fulfillment of a contract with the consigner
3. Personal information of shareholders
   For the exercise of rights and fulfillment of obligations based on the Companies Act
   For the provision of services and implementation of measures for shareholders
   For the management of shareholders
4. Personal information of job applicants

For the transmission of employment information to successful applicants; for a recruitment selection process; and for our management of recruitment-related operations

Contact information regarding personal information:
For inquiries related to personal information, please contact the office you have submitted your personal information. If you are not sure of the office, please contact the following:
TEL: +81-3-5568-0123 Contact person: person responsible for personal information management
E-MAIL ： info@vortechs.jp

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