The Benesse Group
May 25, 1999
Last Revision: June 24, 2005
Benesse Corporation

The Benesse Group is committed to helping each individual achieve a life of well-being.

In such areas as education, learning, childcare, living and lifestyles, and nursing care, the Benesse Group provides products and services that support individuals in living fulfilling lives.

We will maintain a dialog with customers in the development of products, we will seek to achieve the highest level of specialization in each business segment, and we will actively use leading-edge technology to develop our business. Our ideal is to fully respect the human and individual contact needed in the choices people make related to learning and better living.

Our Foundation: Services and Trus

We at the Benesse Group express our guiding principles and responsibilities in the following manner.

• Individuals desire effective support so they can maximize their possibilities in learning and in lifestyle planning, and such needs are individualizing and diversifying. We are aware that these developments are bringing about important social changes.
• We are committed to understanding individual customers well and to providing products and services on education and lifestyle planning that will directly respond to individual needs, desires, and choices.
• To improve the quality of services and the means for their delivery, we will make use of leading-edge information and communications technology. At the same time, we will maintain regular individual contact with each customer.
• What is most important is to gain the understanding and the full confidence of customers regarding our guiding principles and activities.

Trust and Personal Information

We are fully aware that trust and respect for personal information are two sides of the same coin.
The reason we collect and make use of the personal information of customers is to support individual customers in their learning activities and in achieving better lives. To gain the trust of customers, it is essential that our use of the personal information of customers does not give rise to uncertainties.

It will be important for us to respect the thinking of customers on the use of personal information and for customers to understand what we specifically put into practice in the handling of their personal information.

This privacy statement does not apply to employment management, such as regarding staff.
Each Benesse Group company will independently draft and publicly announce their privacy statements.

Our Commitment to Customers

In the handling personal information, we pledge to strictly comply with this privacy statement, the obligations stipulated in the Law concerning the Protection of Personal Information and the various other applicable laws and regulations related to personal information protection, as well as the guidelines issued by the state minister in charge.

Based on the duties and social ethics to be observed by a business handling personal information, we will establish an internal organization and regulations for protecting personal information. We will comply with these regulations and work to protect the personal information of customers.

We promise that we will inform customers on how we handle personal information. We will implement the following commitment items on the handling of personal information as procedures necessary for customers and ourselves to feel confident in each other and to communicate with each other.

Note: "Personal information" is defined hereinafter as information relating to living individuals that can be used to identify specific individuals.

Acquisition and Use Based on Customer Expectations and Trust

We will obtain personal information that is needed to provide products and services meeting customer expectations.

We will obtain by lawful means information that is needed in providing services to customers and in corporate activities supporting customers.

We will obtain personal information such as on educational abilities, physical characteristics, and health to provide more effective products and services to customers. We will categorize and handle such information as sensitive information.

When we make use of sensitive information, we will do so under strict confidentiality protection regulations.

We will communicate the purposes of use for personal information to gain the trust of customers.

In obtaining information from customers, we shall, excluding cases provided by law as exceptions, either publicly announce in advance the purposes of use of the information or notify or publicly announce the purposes of use to the principal immediately after obtaining the information. When directly obtaining personal information from customers in writing or through our website, we will publicly announce the purposes of use beforehand to avoid misunderstandings by customers.

We will specify to the degree possible the purposes of use of the personal information, and will not make use of the information beyond the scope of the purposes of use (See "Public Statement Based on the Law concerning the Protection of Personal Information" below), excluding cases where the consent of the principal has been received in advance and cases provided by laws and regulations as exceptions.

When the personal information that has been obtained is to be retained, we will publicly announce its purposes of use (See "Public Statement Based on the Law concerning the Protection of Personal Information" below).

Note: "Principal" is defined hereinafter as the specific individual identified by the personal information.

Respect for the Personal Information of Customers

We will handle the personal information of customers from their perspective.

We will work to ensure that the personal information we handle as required in our work is as accurate and as up to date as possible within the scope of our abilities, and we will correct personal information when found to be in error.

We shall not, excluding cases provided by law as exceptions, provide personal data to third parties without receiving in advance the consent of the principal.

Note: "Personal data" is defined hereinafter as the personal information comprising a personal information database, etc. and "personal information database, etc." is defined hereinafter as a collection of information, including personal information, which is designated by government ordinance as something systematically structured so as to ensure easy retrievability of specific personal information, such as an electronic database or a Who's Who publication.

Information Management that Reassures Customers

Thorough information management will be implemented to protect the personal information of customers.

• Personal information regulations
  We will develop manuals on privacy and the protection of confidentiality for each job category handling the personal information of customers, from teachers scoring the answers of students to computer operators handling files. According to the rules of these manuals, access to the personal information of customers is limited to employees for which such information is essential in the provision of services, and all employees pledge that they will not access the personal information of customers for inappropriate reasons.
  
  When work including personal information is contracted out within the scope needed to provide products and services, we will insist that the employees of contractors will handle personal information in the same manner.
• Safety management policies (security measures)
  We will implement necessary and appropriate measures for safety management and will supervise employees and contractors.
  
  To protect the personal information of customers that we retain, both appropriate internal management and safety management measures to prevent infiltration from without will be essential. We will use the latest security technology to protect the personal information of customers.
• Supervision of employees
  We consider training on the protection of personal information to be essential for all employees. Employees are obliged to comply with and implement regulations on the protection of personal information, and major violations will be strictly dealt with in accordance with employment regulations.
• Supervision of contractors
  Contractors will be limited to companies that we can trust within the scope needed to provide products and services. We will regularly monitor and supervise these companies to ensure the appropriate handling of personal information.

Customer Rights

Customers may at any time inquire about their personal information.

Customers may request the disclosure of the information we retain on them. In such cases, we will disclose to customers the retained personal data following certain procedures and based on laws and regulations.
When there are errors in the personal information that is disclosed, customers may request their correction. We promise that we will promptly make corrections to ensure that retained personal information is accurate and up to date.
We will promptly and appropriately respond to complaints from the principal regarding the personal information we handle, and when is it is determined that there are errors or violations, we will implement necessary corrective measures. In addition, we shall endeavor to develop an in-house framework for that purpose. (See "Public Statement Based on the Law concerning the Protection of Personal Information" below for information on the contact point for complaints, requests for disclosure, or requests for corrections).

Note: "Retained personal data" is defined hereinafter as personal data for which we have the authority to disclose, correct, etc., excluding personal data that is designated by government ordinance as information which, if the existence or nonexistence of the said information were known, would threaten public (or other) welfare, and which is not designated by us for deletion within six months.

Offering Customers a Choice

We will respect the right of customers to choose how personal information is used.

It is the customer who decides whether or not to use the services we offer. We will provide procedures so customers receiving materials from us through the mail can ask to be removed from mailing lists or so customers can refuse to receive e-mail communication when not desired.

Through such measures, we will work to protect and safeguard the personal information of customers. To achieve such ends, we will assign a chief privacy officer to be responsible for supervising the implementation of regulations. The chief privacy officer will be responsible for preparing reports for submission to the president and the board of directors on the management of the privacy system, on responses to customer complaints, on the views of customers and other outside people regarding regulations, and on other matters.
We promise that we will periodically audit and review the system for protecting personal information and regularly work toward its improvement.

Benesse Corporation (hereinafter the "Company") hereby announces matters related to the purposes of use of personal information and retained personal data obtained by the Company, the provision to third parties of personal data, procedures regarding requests for disclosure etc. of retained personal data, and the reception of complaints regarding the handling of personal information based on the Law concerning the Protection of Personal Information, Basic Policy concerning the Protection of Personal Information (Cabinet decision), enforcement regulations for the Law concerning the Protection of Personal Information, guidelines established by the state minister in charge based on the Law concerning the Protection of Personal Information, and the rules of organizations we are affiliated with.

Personal information related to employment management, such as the personal information of the Company's employees and others, does not fall under the provisions of this public announcement.

PUBLIC STATEMENT ITEMS

1. Purposes of Use for Personal Information and Retained Personal Data
   1. The purposes of use of personal information obtained directly from the principal through a means other than writing (including websites), personal information obtained indirectly, and retained personal data are listed under b) in relation to the operations listed under a).
      1. Operations in Which the Information Will Be Used
         1. Shinkenzemi and other correspondent courses
         2. Learning support businesses based on e-learning through such means as the Internet
         3. The editing and sale of books and magazines, such as dictionaries, books on learning, or materials and magazines on learning
         4. Manufacture and sale of Pocket Challenge and other learning equipment or software
         5. Sale and implementation of Shinkenmoshi and other simulated examinations, diagnostic tests, or skills tests; consultation, guidance, counseling, and provision of information on career plans, educational plans, education matters, and learning; and the provision of information on job opportunities
         6. Sale of magazines and other products and services, and provision of information on childbirth, childcare, hobbies, homemaking, culture and arts, qualifications, and practical skills
         7. Management of lodging facilities, art museums, and other facilities
         8. Management of community sites and portal sites such as Benesse Women's Park, Internet service provider business, and other related Internet businesses
         9. Management of language, personal computer, and other learning classes
         10. Satellite broadcast services
         11. Travel and entertainment businesses
         12. Nursing care services
         13. Other related or supplementary businesses
      2. Purposes of Use
         1. To provide products and services in response to orders
         2. To provide information about company products and services
         3. To prepare questionnaires and surveys as well as statistical and marketing materials
         4. To use in research, planning, and development related to applicable operations
            To outsource duties, request cooperation in services and operations monitoring and others, or request part-time employees
         5. and others in the various processes, including the planning, development, production, marketing, sales promotion, sales, and delivery of products or services
         6. Other operations related to or incidental to the above items
      3. Notes:
         1. We shall, in principle, clearly state separately the purposes of use of personal information obtained directly from the principal in writing (including websites).
         2. The purposes of use for personal information and retained personal data regarding co-branded credit card services and educational loan services are publicized separately. They can be viewed at (http://www.benesse.co.jp/privacy/privacy2.html)
   2. We shall use the personal information provided (entrusted) by outsourcers accompanying our undertaking of such outsourced duties as simulated examination data processing only within the scope necessary for the achievement of the purposes of the contract with the said outsourcers.
2. Matters regarding Provision of Personal Data to Third Parties
   1. We shall properly control the personal data retained and shall not provide such personal data to third parties without receiving in advance the consent of the customer, with the exception of the following conditions.
      • When based on laws or regulations
      • When necessary for the preservation of life, limb, or property and when gaining the consent of the principal is difficult
      • When necessary in particular for the improvement of public health or promoting the sound development of children and when gaining the consent of the principal is difficult
      • When required to cooperate with national or local government institutions or contractors to such institutions in the performance of work prescribed by laws and regulations and when gaining the consent of the principal risks impeding the performance of this work
      • When the principal is notified beforehand about necessary matters or when they are publicized through our website in accordance with the Law concerning the Protection of Personal Information
   2. We shall, in the case of joint use of personal data with a specified third party, directly notify the principal or publicly announce by posting on our website the fact that the personal data will be used jointly by the specified party, the items of personal data that will be jointly used, the party who will be jointly using the data, the purposes of use by that party, and the title of the person responsible for control of the said personal data at that party.
3. Procedures for the Disclosure, Correction, Addition, or Deletion of Retained Personal Data
   Based on the Law concerning the Protection of Personal Information, we shall respond to requests by a principal or his or her agent for the disclosure, correction, addition, or deletion (hereinafter, "requests for disclosure, etc.") of retained personal data.
   1. Specification of Items That Are the Subject of Requests for Disclosure, Etc.
      The principal or his or her representative making requests for disclosure, etc. should specify the information for disclosure, correction, addition, or deletion using the retained personal data items listed in the designated request form.
   2. Submission of Requests for Disclosure, Etc.
      Please phone the contact point listed in D. 1. below to receive by mail the required forms for making requests for disclosure, etc.
   3. Forms (Format) to Be Submitted at Time of Request for Disclosure, Etc.
      When making requests for disclosure, etc., the designated request form we will send you by mail should be filled out in full and be returned by mail with a document identifying the principal. Documents to be returned by mail are a) and b) below.
      1. One designated request form
      2. Identification document
         • In the case of a driver's license, health insurance card, or other official document stating the principal's current address, one copy of that document should be enclosed with the request form.
         • In the case of a passport or other official document not stating the principal's current address, one copy of that document and one copy of the principal's certificate of residence should be enclosed with the request form.
   4. Requests for Disclosure, Etc. Made by a Representative
      In the case that the person making requests for disclosure, etc. is a legal representative of a minor or a ward who is of age or a proxy authorized by the principal to make requests for disclosure, etc., in addition to the request form specified in a) above, the documents listed in a) or b) below must also be enclosed.
      1. In the Case of a Legal Representative
         1. Document verifying the power of attorney of the legal representative
            • A family register or, in the case of a person with parental authority over a minor, a health insurance card on which are written the names of family dependents: One copy of that document
         2. Document identifying the identity of the legal representative
            • In the case of a driver's license or other official document stating the legal representative's current address: One copy of that document
            • In the case of a passport or other official document not stating the legal representative's current address: One copy of that document and one copy of the legal representative's certificate of residence
      2. In the Case of an Authorized Proxy
         1. Letter of attorney specified by the Company: One copy
         2. The principal's certificate of seal impression
         3. Document verifying the identity of the authorized proxy
            • In the case of a driver's license or other official document stating the authorized proxy's current address: One copy of that document
            • In the case of a passport or other official document not stating the authorized proxy's current address: One copy of that document and one copy of the authorized proxy's certificate of residence.
      3. Note: The copy of the certificate of residence and certificate of seal impression referred to in 3. and 4. above must have been issued within three months of the request date.
   5. Processing Fee and Method of Fee Collection
      Requests for disclosure are subject to following processing fee.
      (No processing fee is charged for requests for corrections, additions, or deletions.)
      Processing fee: ¥970 (including consumption tax, etc.) per request
      The processing fee should be paid through a financial institution designated by the Company. The handling fee of the financial institution is to be covered by the principal or representative requesting disclosure.
   6. Method of Responding to Requests for Disclosure, Etc.
      Responses are sent in writing to the address recorded in the request form.
   7. Purposes of Use for Personal Information Obtained via Requests for Disclosure, Etc.
      The personal information obtained via requests for disclosure, etc. shall be handled within the scope necessary to process the request for disclosure, etc. Documents submitted shall not be returned. Documents shall be retained for two years from the date of response to the request for disclosure, etc. and then destroyed.
   8. Notes
      1. We will contact you should the conditions below arise. Please note that if we do not receive an appropriate response within a certain period, we will conclude that a valid request for disclosure, etc. was not received. In such case, any fee already paid will be refunded.
         • When the designated documents are incomplete
         • When the principal cannot be verified, such as when the address recorded in the request form, the address recorded in the identification document, and the address in our records do not agree
         • When power of attorney cannot be verified regarding the request made by the representative
         • When the fee is not paid in full, or when the processing fee is not paid
      2. In the case that a request for disclosure, etc. falls under one of the following, the information shall not be disclosed. In the event of nondisclosure, we shall notify the principal or his or her representative of the same in writing and state the reason why compliance with such a request is not possible.
         The processing fee is charged and will not be refunded even in the case of nondisclosure.
         • In the case that the reason for requesting disclosure etc. does not fall under the reasons for requests for disclosure, etc. stipulated by the Law concerning the Protection of Personal Information
         • In the case that the information requested for disclosure does not fall under the category of retained personal data
         • When disclosure risks injuring the life, limb, property, or other rights or interests of the principal or a third party
         • When disclosure risks seriously impeding the appropriate execution of the Company's business
         • When in violation of other laws or orders
4. Contact Point regarding the Handling of Personal Information
   1. The Company's Contact Point
      Please address complaints regarding the handling of personal information, requests for information on the purposes of use for retained personal data, inquiries about procedures such as for requests for disclosure, etc. to the following:
      Personal Information Inquiry Desk
      Benesse corporation
      1-34 Ochiai, Tama-shi, Tokyo 206-8686 Japan
      
      Notes:
      1. No request made in person directly at the Company's offices shall be accepted.
      2. Separate regulations govern the matters provided in A. to C. in relation to executives and employees (including all position applicants and retired employees and executives) of the Company. Please inquire at the above contact point regarding the handling of such personal information.
      3. A separate contact point regarding the handling of personal information has been established for co-branded credit card services and educational loan services. For further information, refer to
         (http://www.benesse.co.jp/privacy/privacy2.html)
   2. Name of Authorized Personal Information Protection Organization
      The Company is not affiliated with a personal information protection organization at present.