Information that can distinguish individuals, namely personal information, starting with customers who have a connection with the Company, is an asset of immense value to the Company. Furthermore, society demands the protection of the privacy and the correct and secure handling of this precious personal information. In response to this social duty, based on the spirit of the H.I.S. Corporate Behavior Charter, the Company strictly complies with laws and ordinances relating to the protection of personal information, and will formulate a compliance program that includes the following matters, and will carry out said in all earnestness.

1. Clarification of Purpose of Use of Personal Information
   When the Company is to receive personal information, the company declares the purpose of use. In addition, we make sure that the personal information provided will not be used outside the purpose of use without permission from the individual.
2. Collection of personal information
   Personal information is voluntarily provided. Even when the Company requests personal information such as names, telephone and fax numbers, addresses, and ID numbers, the Company asks the individuals themselves to decide whether or not the Company is to receive this sort of personal information.
3. Management of personal information
   When the Company receives personal information, even in the form of raw data or even in the case of database creation, the Company carries out appropriate and discrete storage and management. For the purpose of preventing risks such as improper access, loss, destruction, corruption, divulgement, etc. of the personal information received, the Company has strict internal regulations and education for its officers and employees, and strives to execute a security strategy that is appropriate and realistic from both technological and management aspects. Additionally, when there is a need for improvements arising from the results of internal audits conducted due to security incidents arising elsewhere, customer requests, etc., the Company expedites such improvements.
4. Disclosure of personal information to third parties
   The Company does not disclose to third parties the personal information provided by an individual, except in the following cases:
   
   1. When the individual agrees to the disclosure of personal information.
   2. When disclosure is demanded under laws and ordinances.
   3. In the case of disclosure to companies, etc. that have executed non-disclosure contracts (service outsourcing partners such as airline companies, local booking companies) with the Company in advance concerning limited information judged necessary by the Company for the offering of products and services to customers.
5. Inquiries about personal information
   When an individual requests to view and correct personal information that has been provided, the Company verifies the person’s
6. Compliance with laws and ordinances and standards for personal information
   For the purpose of realizing complete protection of personal information, the Company strictly complies with laws and ordinances, standards, and its internal regulations with regard to personal information.
7. Continuing improvement of the Company’s compliance program for personal information
   Through such things as internal audits and re-examination of the business by the Company’s chief executive, the compliance program for personal information is being improved continuously and maintained in a constantly ideal state.