Basic Policy on Protection of Personal Information

1. BENA, Ltd. (“BENA”) will stipulate provisions concerning the protection of personal information, and ensure that its executives and employees are well informed of those provisions. In addition, BENA will request its transaction partners, etc. be compliance with the laws and regulations with regard to the handling of personal information, as well as supervise, guide or consult therewith when necessary.

2. BENA will appoint a Personal Information Manager, and make security management system effective for handling of personal information and the like.

3. BENA will take measures necessary for personnel and technical aspects in order to prevent alteration, leaks of or unauthorized access to personal information or the like.

4. When BENA receives a request for disclosure, correction, deletion or suspension of use of personal data in its possession by the person himself/herself that provided the relevant information, as soon as the identification of the person is confirmed, BENA will endeavor to deal with the matter swiftly in accordance with the laws and regulations based on the principle of speedy processing.

5. Concerning rules and operation manuals with regard to security management, etc. of personal information formulated by BENA, it will ensure that its employees, etc. are well informed thereof so that they will continue to be effective, and will strive to maintain a security management system by reviewing or taking other measures as needed.
Please note that handling of personal information used for the purpose for news report or the purpose for literary work as set forth in Article 50, Paragraph 1 of the Act on the Protection of Personal Information shall not be the target of this Basic Policy.

Basic Policy on Protection of Personal Information
Concerning the stance on protection of personal information in the use of and other individual official websites for magazines and books published by BENA

BENA respects the privacy of readers and on the official websites of BENA (the “BENA Websites”) it will handle the personal information of users that is acquired via the website in accordance with the following policies.

Protection of personal information
BENA will strive to prevent leaks, loss, destruction of or unauthorized access to all personal information provided by users who access the BENA Websites by appropriate protection and safety measures. Moreover, for request by users for confirmation of the purpose of use, as well as confirmation and correction of the contents of registration, etc. with respect to the personal information, BENA will deal with such requests using proper methods. Furthermore, it will comply with the related laws and regulations and other codes with respect to the handling of personal information, as well as strive to review and improve the Privacy Policy on a continuous basis.

On the use of personal information
BENA will not provide to or share with a third party the personal information provided by users who access the BENA Websites without the consent of the user himself/herself. However, in the following cases, BENA may provide information regarding the user without the consent of the user within the minimum necessary scope.

– When provided in the form of statistical information by which an individual cannot be identified for the purpose of research and analysis of trends of use of websites aiming at improvement of offered services
– When necessary for the protection of life, health, assets and rights, etc. of users who access the websites and besides it is difficult to obtain the consent of the user
– When a national agency or local municipality request cooperation to execute operations set forth in the laws or regulations

When using the information by which an individual user can be identified as a part of services for the convenience of the user, with the consent of the user, BENA will treat such information only in the following events:

– For services or functions provided by the BENA Websites, for the purpose of transmission of email notices that are distributed to users who desire, when users fill in answers to questionnaires or forms for confirmation of intent to purchase products offered, for the purpose of shipping premiums for application for gifts or products, etc., and for the purpose of communication or confirmation for the abovementioned operations or for inquiries of all sorts
– In addition, in the case where a user desires to participate in events promoted and announced on the BENA Websites, or in the case of complimentary event invitation program, etc., if it is necessary to enter multiple participants on one application, concerning services, etc. such as sending messages to persons who desire to apply for the program, BENA may request provision of information on the names or contact addresses, etc. of the friends of the user who participate together with the user (only when the applicant user can obtain the consent of the person who accompanies the user)
– When it is judged necessary in operations relating to the abovementioned shipping or communications, BENA may outsource the relevant operations to a third party that has executed a nondisclosure agreement with BENA for the purpose of protection of personal information.

(When a customer does not desire to provide information by which an individual can be identified, there is no particular problem in viewing web screens; however, there may be cases where the customer cannot participate in the services provided by the BENA Websites or by promotion and advertising relating thereto, or where the customer is unable to receive product information.)

Data retention period
The BENA’s websites do not retain personal information of users in excess of the period necessary for the purposes of collecting the information such as questionnaires or applications for gifts, or in excess of the period stipulated under the governing laws or related laws and regulations. If the information is kept as record for information related to questionnaires, it will be handled as statistical information, after excluding personal information.

On the use of Cookies
On the BENA Websites we may use Cookies. A Cookie contains a small amount of information sent by the web server to the browser of the person who accesses the BENA Websites. The main purpose of use of Cookies is to make it possible to provide services efficiently to customers who visit BENA Websites repeatedly, by reading on the part of the BENA Websites the Cookie saved on the PC of the person who accesses the Websites. Note that individual customers cannot be distinguished by Cookies. The purposes of using Cookies are as follows.

– In order to distinguish the PC used by the accessing person by the type of OS or browser, or IP address, etc., and ascertaining information on which pages were previously viewed by the relevant PC
– In order to process information obtained by the use of Cookies (not distinguishing individuals) statistically and using these as materials for provision of more effective information services

By changing the settings of your browser, it is possible to refuse to receive Cookies or have a warning be displayed when receiving a Cookie. Please not in advance that, although most of the services on the BENA Websites can be used even if the browser does not accept Cookies, without Cookies, there may be restrictions such as improper functioning of services that the user can use, or significant decline of reaction speed, and furthermore, there may be cases where the user becomes unable to use the service itself.

Personal Information Manager
BENA will assume managerial responsibility for collected personal information.

On the scope of responsibility under Privacy Policy
At BENA, we consider it extremely important to ensure the safety of all user related information by which identification of individuals is possible, and pay strict attention when receiving personal information sent from the computer of the user who accesses our websites to the web server of BENA using industry-standard SSL encryption technologies. However, unfortunately, it is difficult to guarantee 100% safe data transmission via the Internet. Therefore, BENA cannot completely guarantee technically the safety of the information transmitted by users at their responsibility or information received at Online Services of BENA at the present stage.

When a user uses the official websites of BENA, the user shall be deemed to have consented to the Privacy Policy of BENA. If the user cannot consent to this Privacy Policy, the user should refrain from using the BENA Websites. In addition, BENA shall retain the right to change the Privacy Policy when necessary. Furthermore, although the BENA Websites may include links to websites of third parties, such websites of third parties are beyond the scope of management by BENA, and this Privacy Policy shall not be applicable. Including those websites of third parties, when viewing websites, we will recommend that you should check the Privacy Policy of the applicable website.

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