Basic Information Security Policy

We at Atsumaru Holdings Co., Ltd. collect job information from companies and publish jobs classifieds. We hereby establish this Basic Information Security Policy in order to facilitate measures to ensure the safety and reliability of information assets and prove ourselves worthy of the trust of our customers and society at large.

1. We will engage in safe and appropriate management and operations in order to prevent the unauthorized access to information assets and the loss, leakage, tampering, destruction and the like of such assets.

2. We will comply with the Act on the Protection of Personal Information as well as any other laws and ordinances, codes and guidelines relating to information security.

3. We will educate our employees about information security and ensure they use information assets in the proper manner.

4. We will endeavor to ensure information security by enacting information security management rules, continuously reviewing the content of those rules and conducting regular audits and making improvements.

April 1, 2006
Atsumaru Holdings Co., Ltd.
President Toshiro Shimada

Privacy Policy

There has been a growing awareness of the importance of protecting personal information in recent years as we become a more sophisticated information society. As a company engaged in the publication of jobs classifieds and the management of golf courses, we believe it is our social responsibility to protect all personal information provided for our business including our affiliated companies. We pledge to push forward with the protection of personal information by establishing this Privacy Policy, creating mechanisms for the protection of personal information and making all our employees aware of such mechanisms and indeed the importance of protecting personal information.

Article 1 Acquisition and Use of Personal Information
We will acquire personal information after first clarifying its purpose of use and will use personal information only within the scope of its purpose of use. The purpose of use of personal information will be clearly indicated in the personal information management ledger, and the personal information manager of each department handling personal information will be responsible for establishing and implementing confirmation procedures to ensure personal information is not used outside the scope of its purpose of use. We will also establish an in-house management system and safety management measures to ensure personal information is not used outside the scope of its purpose of use.
Article 2 Personal Information Management and Protection
We will strictly manage personal information and will never disclose or provide your personal information to any third party without your consent. We will also establish and implement safety management measures to prevent leakage, loss and damage to personal information. And in addition to establishing procedures to prevent the occurrence of problems, we will also promptly take corrective action to prevent the recurrence of any problems that should actually occur.
Article 3 Compliance with Laws, Ordinances and Codes
We will comply with laws and ordinances, national guidelines and other codes that are applicable to the handling of the personal information that we hold.
Article 4 Response to Complaints and Inquiries
We will establish a system and procedures for accepting and handling inquiries and complaints concerning the personal information that we hold, and we will promptly respond to such inquiries and complaints.
Article 5 Continuous Improvement of Personal Information Protection Management System and Mechanisms
We will continuously improve our management system and mechanisms relating to the protection of personal information.
Enacted: April 1, 2006
Revised: April 1, 2008
Atsumaru Holdings Co., Ltd.
President Toshiro Shimada
14 Koyaimamachi, Chuo-ku, Kumamoto City, Kumamoto Prefecture 860-0012
Tel: 096-322-6610