Benesse Corporation advances its approach to the protection of personal information based on the following understandings.

Benesse Corporation views providing products and services that help our customers live fulfilling lives as part of our management philosophy.
Customers' personal information is essential for the provision of our services. We recognize the safe storage and handling of personal information as our greatest issue, and will ensure that all employees and other parties involved with our business activities thoroughly implement privacy protection measures.

Given the particular nature of Benesse Corporation's business, which requires the use of personal information in all activities, we recognize the importance of strictly complying with the letter and the spirit of all laws, regulations, and competent administrative organ guidelines concerning personal information and with the personal information rules of associations that we are a member of, and we will strictly comply with all such laws, regulations, guidelines, and rules.

We will thoroughly inform our employees and officers about our internal personal information protection compliance program. We strive to implement, maintain, periodically review, and continuously improve this program.

1. Parsonal Information Management

   Benesse Corporation will handle personal information in accordance with the following policy.

   1. When we collect, use, and provide personal information as appropriate considering the business contents and scale, we will clarify the purposes of use for which the information is being collected and will not use the collected personal information for any other purposes.
   2. We will strive to protect personal information by implementing the following appropriate management policies.
      • Clarify the locus of responsibility by appointing a personal information manager
      • Implement strict personal information security countermeasures to prevent leakage, loss, destruction, tampering, misuse, illegal access, etc.
      • Continuously work to improve security measures implementation, corrective measures for optimization, and personal information protection and management systems
      • Restrict access to personal information databases to ensure management under a safe environment
      • Implement thorough employee education on the protection of personal information
      • Establish an emergency response system, determine the causes of problems that occur, and implement improvement and corrective measures to prevent reoccurrence
   3. We will not disclose personal information to any third parties, except as required by law and for outsourcing duties to contractors to implement the purpose of use.
   4. When outsourcing duties to contractors to implement the purpose of use, we will monitor and supervise said contractors to ensure the appropriate handling of personal information.
2. Procedures for Data Correction and Cessation of Use
   1. To ensure that the customer personal information stored in our personal information database is as accurate, complete, and up-to-date as possible, we will promptly amend said information, when so requested by customers, in accordance with separately stipulated rules.
   2. We will implement procedures to cease sending information via postal mail and e-mail to individuals who ask us to stop sending such information.
   3. We will accept inquiries regarding our handling and management of personal information at the following point of contact.

   *NOTE:
   We may make written or sound recordings of the contents of customer telephone calls regarding inquiries and transactions, and the information gained will be used to promptly and accurately reply to the customer's request, etc.

   Personal Information Inquiry Desk
   Benesse corpotation
   1-34 Ochiai, Tama-shi, Tokyo 206-8686 Japan

3. This Personal Information Protection Policy is subject to change in accordance with the enactment, revision, or abolition of applicable laws, regulations, or other rules.

   Last Revision: Oct. 25, 2005

   Benesse Corporation
   August 20, 2005
   Benesse Privacy Statement