PrivacyMark System is a system set up to assess private enterprises that take appropriate measures to protect personal information. Such private enterprises are granted the right to display "PrivacyMark" in the course of their business activities. The System is in compliance with Japan Industrial Standards (JIS Q 15001:2006 [Personal Information Protection Management System - Requirements]).

Arc Communications Inc. (hereinafter referred to as "Arc") recognizes that protecting personal information of our customers, vendors, registered staff members, employees, etc. (hereinafter referred to as "the individual"), in carrying out our business of providing translation, website planning & design, temporary employment and employment placement services, shall be our social responsibility, and hereby establishes the Personal Information Protection Policy as described below, appoints a Personal Information Management Representative, and ensures that all employees are fully aware of the policy to provide adequate protection.

1. Collection of personal information
   When collecting personal information, Arc shall collect personal information through appropriate means and limit the collection of information to that which is necessary for conducting its operations. When collecting personal information, Arc shall clarify the purpose of collection and use, as well as the contact point for inquiries.
   
   
2. Prohibition on collection of certain personal information
   Arc shall not collect, use or provide personal information of sensitive nature that may lead to social discrimination. However, the same shall not apply in cases where otherwise specially directed by law, such action is necessary to comply with any judicial proceeding, or an explicit consent from the individual concerned is obtained in relation to collection, use or provision of such information.
   
   
3. Use of personal information
   Personal information shall be used only within the scope of the purpose of use, except where Arc is required by an order under the law to do otherwise. When the necessity arises to use personal information beyond the scope stipulated in this Privacy Policy, Arc shall obtain consent from the individual to the purpose intended, etc. Arc shall use the personal information in order to respond to inquiries; contact potential employees; contact those who may be contracted for translation, temporary employment, or SOHO work; send products; and provide useful information (by e-mail, fax, or phone) related to Arc's business activities. For the handling of personal information, Arc obliges our employees to carry out proper information management.
   
   
4. Provision and outsourcing of personal information
   When providing personal information to third parties, Arc shall provide and outsource information within the scope of the purpose of use for which consent has been obtained from the individual. Furthermore, Arc shall conclude necessary agreements with those to which personal information is provided, and take any other measures as required by law.
   
   
5. Implementation of security measures
   In order to ensure the accuracy and security of personal information, Arc shall strive for proper management of personal information, and take preventive and corrective measures against any unauthorized access to, loss of, destruction of, falsification of, and leakage of personal information.
   
   
6. Submission of optional fields
   Fields requiring the submission of private information are specified beforehand. The individual may refuse to submit personal information for optional fields. However, please be aware that not submitting the required fields may deny the individual the use of, or subscription to Arc’s services, etc.
   
   
7. Compliance with laws and regulations
   Arc shall comply with applicable laws, guidelines, principles and other standards established by Japan to ensure personal information is protected.
   
   
8. Use of information for purposes other than the original intent
   Arc shall not use personal information beyond the extent necessary for fulfilling the identified purpose of use, and take necessary measures to ensure this, build personal information protection management system in accordance with the Guideline for Personal Information Protection Management System prepared by our company, and appropriately handle information assets pertaining to collection, use, and provision of personal information.
   
   
9. Continuous improvement of personal information protection management system
   Arc shall continuously review and improve our personal information protection management system.

Contact Point regarding consultation and complaints:
Personal information protection manager, Arc Communications Inc.
Address: Moriden Building 7F, 3-9-9 Mita, Minato-ku, Tokyo, Japan 108-0073
Tel: +81-3-5730-6133／Fax: +81-3-5730-6134
E-mail: arc-c@arc-c.jp

Arc shall respond to any request made by the individual, during the period in which Arc retains the individual’s personal data, concerning disclosure, correction, and deletion of the retained personal data. Please direct all requests relating to disclosure, correction, and deletion of personal information to the contact point given above.

At the time of inquiry, Arc shall verify the identity of the individual or the authorized representative.

Please note that we are unable to comply with requests in the following cases:

• If an identity verification of the individual or the authorized representative cannot be completed;
• If information such as address, name, birth date, or telephone number is missing from the submitted personal information disclosure request form;
• If disclosure is likely to harm human life, body, property, or other rights or interests of the individual concerned or a third party;
• If disclosure is likely to seriously impede the proper execution of our business; or
• If disclosure violates other laws and regulations.

The collection methods and purpose of use regarding personal information acquired through means other than in writing.

Personal information type	Collection method	Purpose of use
Personal information of employees	Collected from the individual himself or herself via the website, by post, telephone and/or email.	Contacting for the purpose of job interviews as well as for conducting other equivalent business operations and employee related administration.
Personal information of temp staff	Collected from the individual himself or herself via the website, job portal, by post, telephone and/or email.	Contacting for the purpose of job interviews, for conducting other equivalent business operations as well as for post employment labor management.
Personal information of registered staff members for employment placement dispatching service	Collected from the individual himself or herself via the website, job portal, by post, telephone and/or email.	Contacting for the purpose of job interviews, for conducting other equivalent business operations.
Information regarding customers and vendors involved in the business operations of Arc	Collected from the individual himself or herself via the website, job portal, by telephone and/or email.	Used for the purpose of sales activities and customer related administration.

Arc has established a personal information protection management system that is in compliance with JIS Q 15001, appointed a Personal Information Management Representative for each department handling personal information, and set up a system to properly manage personal information. In March 2007, Arc obtained Privacy Mark accreditation, awarded by the Japan Information Processing Development Corporation (JIPDEC) to organizations that properly handle personal information.

Japan Information Processing Development Corporation (JIPDEC)
Personal Information Protection Consultation Service Office, Privacy Mark Promotion Center
TEL: +81-3-5776-1379