Privacy Policy

This English version of terms of conditions is prepared for convenience only. In the event of any conflict or inconsistency between the Japanese and English versions, the Japanese version shall prevail. EWEL, Inc (the"Company") is entrusted by corporations and organizations to provide welfare services and other services to the employees and members of such corporations and organizations (collectively, the "Members") . The Company undertakes the heavy responsibility of providing a range of welfare services and health support services, including the Company's contracted (allied) leisure facilities and sports facilities, or self-development, child care, elderly care and health programs, and the operation and management of so-called cafeteria plan. Our management philosophy is to "create, propose, and realize new value for working styles and lifestyles of the Members as their best partner." In the recognition that thorough protection of the personal information of the Members and all other persons who are involved with the Company is our important social responsibility, we have formed a management system for personal information protection compliant with JISQ15001, and all of the Company's executive officers and employees pledge to undertake continual improvement of our personal information protection management system based on constant attention to social changes.
Established      :    January 15, 2005
Last Revised    :    April 1, 2015
EWEL, Inc.
Shohei Kimura, President and Representative Director

Formation of Personal Information Protection Management System

The Company will form and put into operation a personal information protection management system that prevents unauthorized access to
personal information, and risks of leakage, destruction and damage to personal information, and prescribes standards, rules, and procedures
for proper handling and use of personal information.

Corporate Activities

The Company will put the basic policy into actual practice by engaging in the following activities.

1. The Company's executive officers and all employees will comply with all laws and regulations, and guidelines and other standards
established by Japan in regard to handling of personal information.
2. The Company will appoint a manager of personal information protection, invest the manager with the responsibility and authority to put
into operation and manage the personal information protection management system, and require the manager to perform these tasks.
3. The Company will appoint a person responsible for inspecting the personal information protection system, who will carry out internal
inspections of the state of practice and management of protection of personal information.
4. The Company will request business enterprises and individuals it is associated with to cooperate in the effort to protect personal
information.
5. The Company will post the basic policy on personal information protection on its website and so forth, so that anyone can view the basic
policy at any time.
6. The Company will review as required and continually improve the personal information protection management system.

Personal Information Protection Efforts

1. Acquisition, Use, and Provision of Personal Information

The Company will make clear the purposes for acquisition, use, and provision of personal information, limit use of the personal
information obtained to the extent necessary to achieve the purposes for which it was obtained, and will properly handle the personal
information. Also, the Company will develop management rules and take reasonable measures to prevent handling of personal
information beyond the scope necessary to achieve the specified purposes of use.

2. Respect for Rights of Individuals

The Company will respect the rights of individuals in respect to personal information, and will respond within a reasonable period of time and within reasonable limits to requests by the person concerned for notification or disclosure of the purposes for use of the personal
information, for revision, addition, or deletion of the content of the personal information, or for suspension of use, deletion, and
suspension of provision to third parties of the personal information ("Disclosure, etc.").

3. Implementation of Safety Measures

The Company will formulate and implement internal management rules and regulations and reasonable safety measures, and also take
appropriate corrective measures so that trouble does not arise in connection with unauthorized access to personal information, or
leakage, destruction, and damage to personal information.

4. Response to Complaints and Inquiries

The Company appoints a manager of personal information protection who is responsible for promoting thorough protection of personal
information.
The Company also establishes a Contact for Personal Information Inquiries to receive and respond to inquiries, consultations, and
complaints concerning personal information.

Contact for Personal Information Inquiries

Contact for Personal Information Inquiries
EWEL, Inc.
3-6, Kioicho, Chiyoda-ku, Tokyo 102-0094 Japan
E-mailF

Handling of Personal Information

In January 2006, the Company was approved by the Japan Information Processing Development Corporation (JIPDEC) to be given the
PrivacyMark, which signifies a corporate enterprise which appropriately handles personal information.
privacy mark

Purposes for Use of Personal Information

The Company uses personal information for the following purposes.
(1). Purposes for use of personal information obtained in writing directly from the person concerned.
1. Purposes for use of personal information in the WELBOX services and Reflet's Club.

ETo provide the WELBOX and Reflet's Club services (including intermediation and shipment of the services), contact the customers concerned regarding the content of the services applied for by customers, and charge and collect fees, etc.

ETo grant privileges including WELCOINS, send presents, respond to inquiries, manage usage history and provide campaign information.

ETo create and analyze statistical information, and improve existing services and develop new services based on the analysis of questionnaires.

2. Purposes for use of personal information in seminars and events.

ETo hold seminars and events (including shipment of seminar admission tickets), contact the customers concerned regarding the content of the services applied for by customers, and charge and collect fees, etc.

ETo respond to inquiries and provide campaign information.

ETo create and analyze statistical information, and improve existing services and develop new services based on the analysis of questionnaires.

3. Purposes for use of personal information in hiring activities.

ETo perform the duties involved in hiring, including provision of information to and contact persons who apply for employment.

4. Purposes for use of personal information of the Company's employees, etc.

ETo manage human resources and welfare and health programs for employees.

5. Purposes for use of personal information concerning shareholders.

ETo hold and operate shareholders meetings, and manage shareholders.

6. Purposes for use of personal information in business.

ETo manage and contact business partners.

(2). Purposes for use of personal information obtained by the methods other than in writing directly from the person concerned.
1. Purposes for use of personal information obtained by telephone.

ETo achieve the purposes described in (1) 1 through 6 above.

2. Purposes for use of personal information obtained by cameras, video cameras and IC recorders, etc. in seminars and events.

ETo post personal information on the Companyfs website and so forth.

3. Purposes for use of personal information in the services with which the Company is entrusted.

ETo perform the duties, including the operation and management of the services with which the Company is entrusted, and the response to inquiries concerning the services.

4. Purposes for use of personal information obtained by security cameras.

ETo prevent crimes.

Information Collection on Website

We use portable terminal individual identification numbers, and cookies and web beacons on our website to obtain information that enables us to identify customersf computers. Information obtained from these sources is used for access log collection, to analyze statistical information, and to improve our services. If cookies are deactivated, it may be impossible to use some of our services. Information obtained by portable terminal individual identification numbers, and cookies and web beacons make it possible to identify a customerfs computer or portable terminal, but it is impossible to identify individual customers unless they enter personal information.

*The portable terminal individual identification number is the number sent by the customerfs portable terminal to websites and applications for portable terminals (including smart phones) to enable identification of the portable terminal.
* Cookie refers to a small piece of information that our web server sends to a customerfs browser. This information is stored on the computer from which the website was accessed. Even if one leaves the website, it is possible for the web server to identify the computer when the website is accessed again from that computer by reading the information stored on the computer.
* A web beacon is a digital image embedded in items such as websites and makes it possible to ascertain access from the customersf computer; however, we do not gather personal information on customers using web beacons.

Joint Use of Personal Information

The Company does not engage in joint use of personal information.

Provision of Personal Information to Third Parties

The personal information of customers may be provided to third parties with prior consent of the customers concerned, unless
otherwise prescribed by law. At the request of the person concerned, the Company will suspend provision of the person's personal
information.

* Parties receiving personal information
Business enterprises and organizations to which customers belong that have concluded an agreement with the Company in regard to the WELBOX service. Business enterprises that provide the WELBOX services applied for by customers and have concluded an agreement with the Company in regard to handling of personal information.
Instructors of seminars and events, and cooperating companies and supporting companies.
* Content of personal information provided
The membership number, address, name, age, date of birth, telephone number, fax number, e-mail address, and any other personal
information to the extent necessary to achieve the purposes for use of personal information described in (1) 1 and 2 and (2) 1 and 2 above.
* Methods of provision
In writing, by telephone, fax, e-mail,or through our website.
When customers use the WELBOX services, the Company will receive the provision of the results of the use of the services from third parties including companies and facilities that provide the services.

Entrustment of Personal Information

The Company outsources part of the services associated with personal information in order to provide better services.
The Company may outsource handling of personal information to outsourcing contractors. In such cases, the Company will select
outsourcing contractors whose management of personal information is acknowledged to be appropriate, conclude agreements and
arrangements with the outsourcing contractors prescribing matters such as proper management and confidentiality of personal
information, and confirm at regular intervals the state of management of personal information protection by the outsourcing contractors, thereby ensuring that personal information is being managed appropriately.

Voluntariness of Information Provision

Provision of personal information by customers is voluntary. Please be aware, however, that if you do not provide the personal
information required, you may not be able to use the services provided by the Company in some cases.

Procedure for Disclosure, etc., of Personal Information

In regard to personal information subject to disclosure which is retained by the Company, a customer or the customer's representative must follow the procedure described below to request notification or disclosure of the purposes for use of the personal information, or
revision, addition or deletion of the content of the personal information, or suspension or disqualification of use, or suspension of
provision to third parties of the personal information ("Request for Disclosure, etc.").
However, the part of a person's personal information that the Company has obtained from the member corporation or organization is
not subject to the Request for Disclosure, etc.
1. Procedure for Request for Disclosure, etc. of Personal Information by the person concerned
When a customer requests Disclosure, etc. of personal information, the customer should request document 1 below from the
Company's Contact for Personal Information Inquiries, fill in the required information, affix the personal seal, and enclose it along with
document 2 and reply envelope 3 in an envelope mailed to the Contact for Personal Information Inquiries.
When requesting "disclosure" or "notification of purposes for use" of personal information, please enclose a postal money order of
1,000 yen for each request.
1. Application for Disclosure, etc. of personal information

2. Document for Verification of Identity iany one of the following documentsj
Name of Document Condition for Submission
Copy of the driver's license Must not be expired
Copy of the health insurance card Must not be expired
Copy of the passport Must not be expired
Copy of the certificate of residence Issued within the last 3 months
Copy of the certificate of alien registration Issued within the last 3 months
Certificate of seal impression Issued within the last 3 months
* Black out the information concerning the legal domicile before submitting a document.
3. Reply Envelope
Enclose the reply envelope sent by the Company addressed with a return address and name where the reply is to be sent.
The cost of mailing the response will be borne by the Company.
2. Request for Disclosure, etc. of personal information by the representative of the person concerned
When the legal representative of the person concerned is entrusted to make a request for Disclosure, etc. of personal information, the
legal representative should request documents [1] and [2] listed below from the Company's Contact for Personal Information Inquiries,
fill in the required information, affix the personal seal, and enclose the documents along with documents [3] and [4], postal money orders [5] as required, and the reply envelope [6] in an envelope mailed to the Contact for Personal Information Inquiries.
1. Application for Disclosure, etc. of personal information.
2. Authorization letter for Disclosure, etc. of personal information.
3. Documents required to confirm the identity of the representative (documents 1 and 2 above).
4. The certificate of seal impression for the seal of the person concerned that is affixed to the authorization letter (issued within the
last three months).
5. A postal money order of 1,000 yen for each request for "disclosure" or "notification of purposes for use" of personal information.
6. The reply envelope sent by the Company (addressed with a return address and name where the reply is to be sent).
3. Method of response to request for Disclosure, etc. of personal information
Responses will be made in writing and sent in the self-addressed reply envelope that is enclosed with the request.
4. Purposes for use of personal information obtained in connection with requests for Disclosure, etc.
Personal information obtained in connection with the Request for Disclosure, etc. will be used only to the extent required in connection
with the Request for Disclosure, etc.
Documents submitted will not be returned. After a response is made to the Request for Disclosure, etc., the documents will be
appropriately managed and disposed of.
5. When personal information cannot be disclosed
Please be aware that the Company is unable to disclose personal information in the following cases.
1. When the identity of the person concerned or the person's legal representative cannot be confirmed (for example, when the current
address differs from the address on the certificate of residence).
2. When disclosure is likely to harm the life, body, property, or other rights or interests of the person concerned or a third party.
3. When disclosure violates any laws or regulations.
4. When the personal information subject to the disclosure request cannot be identified from the content of the information on the
application form.
5. When any of the prescribed documents are not submitted.
6. When disclosure is likely to seriously impede the proper execution of the Company's business.

Personal Information Protection Manager

The Company has appointed the person below to serve as the manager of personal information protection.
General Manager of Corporate Division,
EWEL, Inc.