POLICY FOR PROTECTING PERSONAL INFORMATION

1. General Policy Statement

This specifies the policy for Wow inc. ("Company"), managing the distribution of download contents, operations of distribution, and Service related to the distribution and operations on an Internet site ("Service"), to handle customer personal information which the Company receives by the customer's use of the Service.

2. Definitions

In this policy "Personal Information," 1 "Personal Data," 2 and "Personal Data Held by Individual" 3 mean items set forth in each Section of Item 2 in "The Personal Information Protection Law" ("Personal Information Protection Law").

3. Collecting Personal Information

The Company will primarily collect the information listed below when providing the Service. However, the below listed are examples and may not fall under Personal Information designation depending on the concrete contents of the information:

（１）	Information Provided by Customer Name, address, phone numbers (including cell phone number and fax), e-mail address, cell phone e-mail address, company name/organization name, department name, position, title, work address, other contact information, nick name, date of birth, sex, credit card information, and any other information provided by customer. Personal information the Company received aside from the provision of the Service while following procedures specified by the Company.
（２）	Information Collected in Use of Service Information with respect to the transactions associated with the information identifying the customer, which becomes available to the Company when the said customer applies for reservation, purchase, gift, or other transaction with the Service provided by the Company. Information regarding purchase of mail magazine, and others from the Company. Information about statements or posting by a customer when the customer asks the Company questions, participates in a questionnaire or campaign, uses the bulletin board, or evaluates the Service, by phone call, e-mail, or other methods.
（３）	Information Automatically Collected in Service Access Information identifying equipment such as IP address, or cell phone equipment number when a customer accesses the Service. Information collected by accessing a web site operated by the Company, such as the type and version of browser software, device operating system, platform, web pages browsed by the customer (URL's), date and time of access, and goods or contents reviewed or searched. Besides the above, information automatically collected and stored every time the customer uses the Service, such as access information collected by using technologies like cookies or web beacons.

４．Purpose of Use of Personal Information

The Company will use the personal information for the purposes listed below ("Purpose of Use"). However, the address information of others specified by the customer will be used only for the purposes of (2) and (4), both listed below, without consent of the individual:

（１）	In a case that the customer uses the Service as a user Automatic display of the user information on each screen when the customer uses the Service as a user.
（２）	Transactions offered by the Company Information required to perform the transactions such as offering service, payment, response to the customer's inquiry, inquiry by the Company to the customer, related follow-up services, when the customer books or purchases services, applies for a gift, or applies for other transactions.
（３）	Advertisement or marketing of the Company Providing various mail magazines and others to the customer. Providing information about the Service by e-mail, mail, or telephone. Personalizing the contents or advertisements the customer views based on attributes of the customer such as sex, age, address, hobbies, tastes, purchase history, or browsing history on the web site the Company operates. Analyzing the Service the customer uses in order to develop a new service or improve the existing Service. Contact with the customer with respect to questionnaire, campaigns, bulletin board messages, information exchange, or diaries.
（４）	Response to customer inquiry Responding to inquiries made by the customer through e-mail, mail , or telephone.
（５）	Related to operations Necessary use to provide the Service regarding the above Sections (1) through (4).
（６）	Others The Company may use the personal information for a purpose not listed above in order to offer a service. The Company will notify the customer of the use of the personal information on the web site of each service.

５．Handling Personal Information

（１）	The Company will use the personal information pursuant to the Personal Information Protection Law.
（２）	In principle, the Company will not provide the customer personal data, that the Company collected, to the third party. However, the Company may provide the said personal data under the following circumstances: The Company assigns all or some of the Service operations to other business ("Assignee") and the Assignee requests the personal data the Company holds for conducting the said operations. If the Company judges that the said request is appropriate, the company may provide the personal data to the Assignee for use in the specific operations. The Company consigns all or some of the Service operations to other business ("Consignee") and the Consignee requests the personal data the Company holds for conducting the said operations. If the Company judges that the said request is appropriate, the company may provide the personal data to the Consignee for use in the specific operations.
（３）	The items of the personal data provided to the Assignee or the Consignee are the same as those listed in Item 3, Collecting Personal Information.
（４）	Notwithstanding the above, the Company will not provide the customer personal data to the Assignee or the Consignee if the customer requests not to release the said data in advance. If some of the said personal data have been provided to a third party but not the total data, the Company will terminate the provision of the remaining um-provided data based on a request from the customer.

６．Accuracy and Security of Data

（１）	The Company may request customer cooperation to assure the accuracy and applicability of the personal data of the customer.
（２）	The Company is using the SSL (Secure Sockets Layer) technology for the purpose of preventing the data from being intercepted, interfered, or tampered-with to enforce the data security when the customer enters important information.

７．Confirmation of Personal Data Held by Individual

（１）	A customer can apply the following procedures ("Confirmations") on their personal data on the web site of the Company: Confirmation of the data Correction, addition, and deletion of the data Suspension of use Suspension of the data provision to the Service provider, or third party
（２）	Please request the Company to confirm the data which cannot be confirmed by the procedures listed above, while following the confirmation procedure specified by the Company. The fees specified by the Company will apply to this confirmation. The Company may not respond to the request if restricted by the Personal Information Protection Law.
（３）	The Company may not respond to the request for deleting the data depending on their characteristics. In that case the Company will suspend the Service.
（４）	If the Company suspends the Service in order to respond to the deletion request, the customer may not be able to use all or some of the Service.
（５）	The Company may store back-up data in preparation for possible computer failure, other accidental forces, or data loss caused by human error. The back up data cannot be confirmed due to their nature.
（6）	The Company deems that the customer consents to this Item 7. Confirmation of Personal Data Held by Individual when using the Service.

８．Contact

Please contact the following Company representative in case of filing a complaint, inquiry, or confirmation on the handling of the personal information:

Contact:
Customer Personal Information Service Representative
Wow inc.
1-14-3 Jinnan, Shibuya-ku, Tokyo 150-0041, JAPAN
Phone: 03-5459-1100, E-mail: info@ w0w.co.jp

９．Others

The Company may go through procedures not specified as above in accordance with the Personal Information Protection Law.

Established on and effective beginning April 1, 2010.

Notes

※１	"Personal Information" means the information regarding an existing individual person and identifying the particular individual while contained in the data, such as a name, date of birth, or other descriptions (including those that can be easily verified and identifying the particular individual).
※２	"Personal Data" means the Personal Information constituting database of the Personal Information and others. The "database of the Personal Information and others" means the collective entity of the information including the Personal Information such as the following: a. An entity systematically organized to search for the Personal Information of the particular individual by a computer b. In addition to the above, an entity set forth by the law as systematically organized to search for the Personal Information of the particular individual by a computer
※３	"The Personal Data Held by Individual" means the Personal Data which the Company has the authority to disclose, correct, add, delete, suspend the use of, or suspend the provision of to the third party, EXCLUDING THE FOLLOWING: a. The Personal Data potentially endangering the life, body, or assets of the individual or the third party with the disclosure of the said Data's existence or non-existence b. The Personal Data potentially contributing to or potentially triggering wrongful or illegal acts with the disclosure of the said Data's existence or non-existence c. The Personal Data potentially endangering national security or close relationships with other nations or international organizations, or potentially creating disadvantages for negotiations with international organizations with the disclosure of the said Data's existence or non-existence d. The Personal Data potentially interfering with crime prevention, control of insurrection, a criminal investigation, or other public safety and public order with the disclosure of the said Data's existence or non-existence e. The Personal Data to be deleted within six (6) months