【Basic Policies on Protecting Personal Information】
November 30, 2006
Eiji Kazama
President and Representative Director, Infoseed Corporation

Infoseed Corporation declares to be aware that protecting personal information with care is an important social mission, the applicable laws and regulations concerning personal information protection being complied with by the corporate officers and all employees, to establish a Compliance Program, to keep focusing attention on the transition of social demand, and to work on the continuous improvement of the management system for personal information protection across the board in order to embody the following basic policies of Infoseed Corporation.

1. Formulation of the Compliance Program on Personal Information Protection
Infoseed Corporation is aware of such risks as the unauthorized access to personal information, loss, destruction, modification, and leakage of personal information, and devises countermeasures to prevent and correct them. In addition, Infoseed Corporation formulates and executes a Compliance Program that stipulates standards, rules, and procedures for handling and managing personal information in appropriate manners.

2. Organizational Activities for Personal Information Protection
Infoseed Corporation performs the following activities to implement basic policies specifically.
(i) Corporate officers and all employees comply with the applicable laws and regulations.
(ii) A Chief Privacy Officer (CPO) is appointed to be responsible and given authorization for the implementation and management of the Compliance Program, and is made to perform the work.
(iii) A Chief Audit Officer (CAO) is appointed to put personal information protection in practice and to perform internal audit on the management condition.
(iv) Infoseed Corporation asks the customer’s partner companies and individuals for cooperation concerning personal information protection.
(v) Basic policies are always available for inspection by anyone, being posted and displayed on the website of Infoseed (http://infoseed.co.jp).
(vi) The Compliance Program is duly reviewed and improved continuously.

3. Handling of Personal Information Protection
(i) Respect for Individual Rights
Infoseed Corporation respects individual rights concerning personal information, and any request to disclose, correct, or delete one’s own personal information is responded to without undue delay and within reasonable bounds.
(ii) Collecting, Using, and Offering Personal Information
Infoseed Corporation clarifies the purpose of collection for individuals on collecting, using and offering personal information, limiting the range of usage of, and dealing with, collected personal information properly.
(iii) Executing Security Measures
Infoseed Corporation maintains the internal administrative provision in order not to cause trouble, such as external leakage and unauthorized modification of personal information, devising and implementing rational security measures.



                   【Privacy Policy】

                                  November 30, 2006

Inforseed Corporation respects the privacy of the users of AsianShip, and pays careful attention to the management of personal information of the users.

1. Personal Information
Personal information means information including a first and last name, birth date, age, gender, a home address and phone number, a family structure, personal interests, preference, an email address, ID, a place of employment, affiliation, a business address and phone number, credit card numbers, bank account numbers, the information of websites visited, the information of consultancy or inquiry, etc., one or more of which enable to identify an individual.

2. Purpose of Use of Personal Information
Infoseed Corporation uses acquired personal information for the following purposes.
(i) Offering the services of AsianShip
(ii) Correspondence, etc. with users
(iii) Charging the users of pay services with utilization fee
(iv) Customizing information, services and advertisement delivery on the pages of AsianShip in accordance with the age, occupation, gender, personal interests, preference, etc. of the users.
(v) Preparing statistical data processed into a format that is impossible to identify an individual with for AsianShip.

3. Restriction by the Purpose of Utilization
Infoseed Corporation deals with acquired personal information within the bounds for the achievement of the purpose of use. When personal information is handled outside the scope of purpose(s) of use, Infoseed Corporation obtains consent from the users themselves. Provided, however, that the following cases are exceptions.
(i) Cases in which the handling of personal information is based on laws and regulations
(ii) Cases in which the handling of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person
(iii) Cases in which the handling of personal information is specially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person
(iv) Cases in which the handling of personal information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned

4. Acquisition of Information
(i) Infoseed Corporation acquires personal information in a legitimate and judicial manner, and doesn't acquire it by wrongful means against the users' will.
(ii) Infoseed Corporation confirms if the offer has obtained personal information from the person properly in obtaining personal information indirectly.

5. Notice of the Purpose of Utilization at the Time of Acquisition, etc.
Infoseed Corporation notifies or publicly announces the purpose of use in advance in obtaining personal information. When the purpose of use is modified, the users are also notified or publicly announced.

6. Proper Protection of Personal Information
Infoseed Corporation implements the proper measures to make the users’ personal information correct and latest. In addition, the personal information of the users is managed properly and securely.

7. Supervision of Trustees
There are some cases when Infoseed Corporation entrusts an individual or a business operator with the handling of personal information. In such cases, Infoseed Corporation enters into such necessary contracts as basic contracts concerning the deposit of personal information, and exercises necessary and appropriate supervision over the trustee.

8. Provision to a Third Party
Infoseed Corporation doesn’t provide personal information to a third party without obtaining the prior consent of the person in principle. Infoseed provides personal information only when the users’ consent is obtained after the third party to provide personal information for and the content of provision are specified. Provided, however, that the following cases are exceptions.
(i) Cases in which the trustee of Inforseed Corporation’s service provides information or service by way of direct mails, e-mails and other means
(ii) Cases in which the trustee of Infoseed Corporation’s service needs personal information to provide specific service such as after-sales service on behalf of Infoseed Corporation
(iii) Cases in which Infoseed Corporation collects or analyzes specific personal information, processes it into a format that is impossible to identify an individual, and discloses the statistical data
(iv) Cases in which Infoseed Corporation entrusts personal information of the users using pay service of payment system companies, credit companies and banks which have entered into confidentiality agreement as the trustee of Infoseed Corporation’s service for the purpose of charging the users of pay service with utilization fee
(v) Cases in which Infoseed Corporation provides the personal information of the users with delivery companies for the purpose of the delivery of gifts, commercial products, etc.
(vi) Cases in which discloser or provision of personal information is permitted by laws and regulations

9. Disclosure of Personal Information
Infoseed Corporation responds to the cases in which the users themselves demand discloser of personal information without delay. Provided, however, that there are some cases in which all or part of personal information is not disclosed.
(i) Cases in which the life, body, property, or other interests of the users themselves can be harmed
(ii) Cases in which significant impediment can take place against the proper implementation of Inforseed Corporation’s business
(iii) Cases in which other laws or regulations can be infringed

10. Procedures for Correction, Discontinuance of the Use, etc.
Infoseed Corporation responds to the cases in which the users themselves demand correction, addition, deletion, or discontinuance or cancellation of the use after confirming that such requests are made by the users themselves, without undue delay.

11. Immunity
Infoseed Corporation isn’t responsible for the acquisition of personal information executed by a third party in the following cases.
(i) Cases in which the users themselves clarify their personal information to a third party by way of the function of AsianShip or other means
(ii) Cases in which the identification of the specific individual is enabled because of the information, etc. entered on AsianShip by the users

12. Use of Statistical Data
Infoseed Corporation may prepare statistical data processed into a format that is impossible to identify an individual with based on the obtained personal information of the users. As for statistical data that is impossible to identify an individual with, Infoseed Corporation can use such data without any restriction.

13. Use of Cookies, etc.
(i) Infoseed Corporation automatically receives IP addresses of the users, cookie information, advertisements and pages visited by the users, the utilization environment of the users, etc. from the users’ browsers and records them on the server, when the users utilize the services or visit the pages of Infoseed Corporation or its business partners, etc.
(ii) There are some cases in which Infoseed Corporation uses the information on the users, such as the gender, occupation, age, pages and advertisements visited, utilization time of day, utilization methods, and utilization environment of the users to inspect new services and make the content of the conventional services and .advertisement more suitable for the users.
(iii) There are some cases in which Infoseed Corporation analyzes the information on the users and extract the target of questionnaire for analysis, in order to analyze what kind of advertisements, information, services, etc. is effective for advertisers, information providers, service providers, etc. to display or provide, and in order to provide such analysis for them. In addition, such information as is possible to identify an individual with is not included in the result of analysis.

14. Revision of Privacy Policy
Infoseed Corporation may revise all or part of Privacy Policy. In cases in which any important revision takes place, it is informed of on the website.

15. Inquiries
Here is the contact for the inquiry on personal information.


                                              End