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Privacy Policy

Torindo Co., Ltd. (“Torindo”) defines the personal information of its customers and external collaborators as follows, and takes meticulous care in the handling of personal information. Torindo’s policy on the protection of personal information with respect to its collection and handling is explained in this Privacy Policy.

1. Definition of personal information
   Torindo defines Personal information as all information and resources by which the individual can be identified, such as name, address, work place, school, position, e-mail address, telephone number, fax number, and the resumes and work histories of its translators or applicants for staff positions.
2. Collection of personal information
   Torindo may collect personal information during inquiries from customers or external collaborators, or during application for staff recruitment. Torindo only collects personal information by appropriate and fair means.
   
   Access log
   Torindo records simple access logs on this Torindo website (“website”). The access logs include IP addresses, and access dates, etc., of persons accessing the website. Individuals cannot be identified by the use of IP addresses. Access logs recorded on the website are only used for statistical analysis regarding the status of use of the website, and for diagnosis in the case of problems with Torindo’s server, and will not be used for any other purpose. Torindo uses statistical analysis for reference in future management of the website.
   
   Cookies
   Cookies are not used on the website.
3. Use of personal information
   Torindo uses and stores the personal information you provide within the scope of its activities, and only for the following “purposes of provision of personal information”:
   
   1. communication, notification with respect to registration in Torindo’s database, sending of related documents, and registration in the database;
   2. replies to inquiries from customers and collaborators;
   3. guidance, communication, notification with respect to information provision on Torindo’s translation services, and on translation requests, and sending of related documents,
   4. judgment on appropriateness of applicants (translators and employees), and registrations.
   Moreover, Torindo will never intentionally disclose personal information to any third party or jointly use it with any third party, except for in the cases shown in “4. Provision and disclosure of personal information to third parties” as below. If Torindo discloses personal information to a third party, or jointly use it with a third party, Torindo will conduct a strict investigation of the relevant third party and perform proper supervision concerning confidentiality.
4. Provision and disclosure of personal information to third parties
   Torindo will not provide or intentionally disclose your personal information to any third party or jointly use it with any third party, except for in the following cases where:
   
   1. disclosure is legally requested by a court, the police, or other authorized public organizations (upon request with legal grounds relevant to forcible investigation of such matters as act of fraud, debt collection, etc.);
   2. Torindo’s personal information protection manager jointly uses the personal information within the scope necessary for the performance of the relevant duties with the persons in charge of the relevant duties (translation coordinators, external collaborators, DTP operators, etc.), or
   3. Torindo has the prior consent of the provider of the personal information concerning the disclosure of the relevant information.
5. Management of personal information
   Torindo maintains the accuracy of personal information and safeguard it. Torindo will maintain appropriate information security measures against unauthorized access, or computer viruses, etc. to protect your personal information from loss, destruction, alteration, and leakage, etc. Torindo takes reasonable measures so as not to leak personal information by removing or transmitting personal information to the outside.
6. Disclosure, correction, suspension of use, and deletion of personal information
   Torindo confirms that persons reserve the right to request disclosure, correction, suspension of use, and deletion, etc. with regard to their own personal information and if there is such a request Torindo will handle it promptly without objection.
7. Organization and system
   Torindo will assign responsibility for protection of your personal information to a designated personal information protection manager, and ensure appropriate management of personal information.
   Torindo carries out training about protection and appropriate management methods for personal information for all executives and employees to raise their consciousness of the importance of personal information. Torindo provides thorough implementation of appropriate handling of personal information in daily operations, and pays the utmost attention to information management. Moreover, for strict internal management to avoid improper use, Torindo limits access permissions to the personal information protection manager alone.
8. Formulation, implementation, maintenance, and improvement of personal information compliance program
   In order to carry out this Privacy Policy, Torindo will formulate a Personal Information Protection Compliance Program (which includes this Privacy Policy, other rules, regulations, and detailed regulations), and thoroughly familiarize its employees and other related parties therewith, and maintain and regularly improve it.

Change of Privacy Policy

When Torindo changes its Privacy Policy, Torindo will make disclosure on the website. When the Privacy Policy has been changed, Torindo will place a notice of change on the top page of the website to attract attention of users. When changes are disclosed on the website, after disclosure the user is deemed to have agreed to the Privacy Policy following changes as of the time the user accesses and uses the website.

Confidentiality

Torindo will never disclose to any third party any business information of customers that Torindo acquire through inquiries, irrespective of whether the form be written, electronic data, or oral provision. However, if legally requested by a court, the police or other authorized public organizations, Torindo will disclose information in response to such request. Torindo strictly manages data and materials we receive internally and take the following measures to avoid leakage to outside parties:

• Ensure compliance with confidentiality rules by all employees.
• Ensure submission of confidentiality agreements affixed with signatures and seals from external collaborators when entering business contracts.
• Ensure conclusion of confidentiality agreements between customers who use Torindo’s translation services and Torindo.
• Ensure the handling, protection, and management of confidential documents (shredder disposal, and deletion of electronic data of important documents, including confidential company documents, and documents provided and designated as confidential by customers).

We will regularly review the handling of personal information of customers and external collaborators for a further improved and enhanced system.

If you have questions or concerns about this Privacy Policy, please contact us.

Effective as of January 17, 2008