Fundamental Principles

In order to respond to information security needs accompanying the spread of cloud services and to ensure the security of our cloud services ("our Services") as a provider to domestic and international customers, WingArc1st Inc. ("WingArc1st") has developed this policy setting out the security measures we take for the safety of information in the cloud. These measures include:

• cloud-based security measures
• measures relating to the offices from which WingArc1st's personnel are engaged in ensuring the operational stability of our services
• processes for maintaining WingArc1st's information security rules
• a systematic approach to continuous improvement.

Information assets, including the valuable customer information that WingArc1st handles in the course of its work, are extremely important and forms the very foundation of our business. WingArc1st recognizes the importance of protecting information assets from the risk of leakage, damage, and loss, and all of WingArc1st's employees, including its directors, will comply with this policy, and conduct themselves so as to maintain information security, and maintain the confidentiality, integrity, and availability of information assets.

Fundamental Policies

1. Protection of information assets
   To protect information assets, WingArc1st will develop an information security policy and act in accordance with it. WingArc1st will also comply with laws, regulations and other norms related to information security, as well as with contracts with customers.
2. Regular review of information security measures to protect information assets
   WingArc1st will conduct regular risk assessments, as well as analyze the potential risks of leakage, damage, or loss of information assets, clarify its standards of risk evaluation, and establish a systematic risk assessment method. In addition, based on the results of these assessments, WingArc1st will implement the necessary and appropriate information security measures.
3. Appropriate handling of information assets
   WingArc1st will establish an information security system centered on its designated directors, and will clarify the authority and responsibilities related to information security. In addition, WingArc1st will provide regular education, training, and awareness programs to ensure that all employees are aware of the importance of information security and how to handle information assets appropriately.
4. Regular review of manuals and procedures for the proper handling of information assets WingArc1st will regularly inspect and audit the status of its compliance with information security policies and its handling of information assets, and will take prompt corrective action should it find any deficiencies or areas for improvement.
5. Prevention of damage to information security
   Should any event or incident relating to information security occur, WingArc1st will take immediate action to prevent potential damage. In the unlikely event that damage does occur, WingArc1st will have response procedures established in advance to minimize the damage, and in the event of an emergency, WingArc1st will respond promptly and take the proper corrective measures. In addition, WingArc1st will conduct recovery tests and reviews of incidents related to the interruption of our Services.
6. Establishment of an information security management system
   To realize the fundamental principles of the policy, WingArc1st will establish, implement, and continuously review and improve an information security management system, cloud-specific risk measures, and personal information protection measures on the cloud.

Declaration dated 14/Mar/2018
WingArc1st Inc.
Ko Shimazawa, Executive Officer and CTO

Thank you for using the websites owned and managed by WingArc1st Inc. (hereinafter referred to as the "WingArc1st") (including but not limited to http://www.wingarc.com/, https://customer.wingarc.com/support/, and WARP (https://warp.wingarc-support.com/, hereinafter referred to as the "this website"). The purpose of these WingArc1st-operated websites is to provide necessary and useful information for clients using or reviewing products and services provided by WingArc1st.

WingArc1st shall handle the personal information of clients in compliance with relevant laws and ordinances and the relevant policy on the protection of personal information. Furthermore, WingArc1st shall not disclose or provide information that could be used to identify a person (hereinafter "User") (including name, electronic mail address, postal address, or telephone number) to a third party without permission from the relevant User. For the purposes of this website, personal information of a User shall be defined as the personal information obtained from user registration and surveys forms as voluntarily submitted upon participation of the User at a seminar or exhibition (hereinafter collectively referred to as "Event"). By registering for participation in an Event or submitting a survey, the User shall be deemed to have agreed to the terms and conditions as specified on this website by WingArc1st.

WingArc1st either owns the copyright to the documents, figures, photographs, or other content appearing on this website or has obtained permission to post such content on this website from the person to whom the copyright therein belongs. Certain company names, logos, or product names on this website may constitute trademarks or registered trademarks of the respective companies to which they belong. Links to other websites may be included on this website. The site policy of WingArc1st applies only to information collected through and appearing on this website. WingArc1st shall not be liable in any way for the privacy statement or operations of any other website. Users are urged to verify the privacy statements of other companies on their respective websites in advance.

The reprinting, distribution, or modification of the information on this website, in whole or in part, without the permission of WingArc1st is strictly prohibited. Be aware that the information on this website is subject to change without notice as required. WingArc1st shall assume no liability for any damage resulting from the use of the information or services provided through this website, any disruption of this website, or the use of a service provided through this website.

WingArc1st (hereinafter referred to as the "Company") has the following corporate philosophy: "Information is a source of value creation. We will contribute to corporations and society by providing innovative software services for the purpose of information utilization." We are striving to be aware of the value (importance) of information and to thoroughly and appropriately manage and protect it. The Company is aware of the serious duty to properly protect the personal information used to provide services to customers or personal information retained in the course of operations and shall fulfill this duty by handling such information according to the following policy:

1. The Company shall comply with relevant laws and ordinances and other standards for the protection of personal information.
2. The Company shall improve the appropriate management and protection of personal information by ongoing reviews and improvements to employee education, internal controls, and system security in connection with the appropriate handling of personal information.
3. When collecting personal information, the Company shall identify and either provide a notification or make a declaration as to the purpose of use and will then handle personal information according to the purpose of use.
4. The Company shall take reasonable precautions as required to protect the accuracy and safety of personal information and will work to prevent leakage, loss, alteration, or improper access.
5. The Company shall establish a channel of communication for accepting requests from customers about the personal information in the possession of the Company, including requests to have such information disclosed, corrected, updated, deleted, or its use discontinued; the Company shall receive and accommodate such requests appropriately.

Jun Tanaka
President
WingArc1st Inc.

Specifically, personal information shall be obtained as follows:

Personal information in the possession of WingArc1st Inc.

1. Personal information obtained through the exchange of business cards with Company employees;
2. Personal information of persons who have applied to participate in seminars or exhibitions that are hosted or co-hosted by the Company and persons who have responded to surveys at exhibition venues;
3. Personal information of persons who have responded to surveys at the time of applying for services, such as a request for materials or an outputting of forms on a trial basis, through the Company website;
4. Personal information of persons who have submitted applications for Chohyo NOW and other forms of email news from the Company;
5. Personal information obtained or retained through operational processes or contractual agreements with customers.
6. Applicant information for the company 's recruitment activities
7. Personal imformation of the company 's employees

Access log

In order to ascertain customers' use trends and measure the effects of advertisements on the Company's website, we use cookies and other technology for collecting anonymous information, and record information about customers who accessed the website in the form of an access log. The access log includes URLs that were accessed, IP addresses, types of web browsers, and domain names. In addition, in some cases the Company records the histories of customers' clicks on URLs stated in e-mails and histories of opening image data, etc.

Ordinarily, these are not matters that include information by which it is possible to identify individuals, but in some cases the Company uses the access log as information about customers. Such information will be used only for the purposes stated in "Purposes of use of personal information" below.

Cookies

On the Company's website, there are pages that use cookies and other technology for collecting anonymous information, for the purpose of effectively guiding customers by confirming whether or not customers have visited the page in the past. Cookies refer to small-scale forms of data that are sent from a web server to a customer's browser, and in some cases, they will be stored as a file on the customer's disc. However, ordinarily cookies cannot identify customers. The Company also does not use cookies to identify individuals, but on the Company's website an access log is sometimes used as information about customers. Such information will be used only for the purposes stated in "Purposes of use of personal information" below. Please note that it is possible for customers to voluntarily deactivate cookies' functions, but in some cases that will cause displays or browsing on the Company's website to not function normally.

Purposes of Use

We shall use the personal information of customers for the following purposes and for the benefit of customers:

1. Operational communications;
2. Execution of contractual agreements (for products and services);
3. Introduction of information about products and services (through news issued through email communications) and public relations;
4. Introduction of seminars and exhibitions (hosted independently or organized jointly) by the Company;
5. Requesting questionnaire surveys on different types of operations;
6. Accommodating inquiries or requests from customers ;
7. Implementation of other types of operations as well as other purposes agreed to by customers .

We shall use the personal information of recruiters, job applicants, and employees for the following purposes.

1. Selection of new employees, notification to applicants, and procedures for joining the Company at the time of employment
2. Management of personnel and labor affairs

* While personal information may be provided to the extent necessary to a third party to whom certain operations have been outsourced as a means of facilitating operations, the Company shall conclude contractual agreements on the handling of personal information with the outsourcees and provide the appropriate oversight.

Joint use of personal information

For personal information of persons who have applied to participate in things such as seminars or exhibitions that the Company co-hosted and persons who have responded to surveys at exhibition venues, the personal information may be jointly used among the co-hosting companies as stated below.

1. Matters of personal information
   Name, information related to work (company name, postal code, address, telephone number, FAX number, e-mail address), and other information that was stated in the application, etc.
2. Scope of companies that will conduct joint use
   Companies that co-hosted with the Company events such as seminars and exhibitions where people made applications or responded to surveys, etc. (Because the co-hosting companies are different for each seminar, etc., we will inform people of names of those co-hosting companies when we obtain personal information from them.)
3. Purposes of use
   The same as the "Purposes of use of personal information" above
4. Person responsible for personal information management
   WingArc1st's officers in charge of management

Anonymously processed information

1. When the Company will create anonymously processed information, in order to ensure that it will not be possible to identify specific individuals or restore personal information used in that creation, it will follow the stipulations of personal information protection laws and other related laws and ordinances, and the Company will set processing standards and process the relevant personal information according to those standards.
2. If the Company will create anonymously processed information, it will not have people other than the Company's person responsible for protecting and managing personal information, the on-site managers of each department that creates the relevant anonymously processed information, and the work managers designated by the on-site managers come in contact with statements and symbols that identify individuals and that were deleted from personal information used in that creation, or information related to the specifically-selected processing method, and the person responsible for protecting and managing personal information will take the necessary measures to ensure this.
3. When the Company will create anonymously processed information, it will publicly announce the matters of information related to individuals that will be included in the relevant anonymously processed information, and when it will provide it to a third party, it will publicly announce the matters of information related to individuals that will be included in the anonymously processed information that will be provided to the third party and that method of provision, respectively.
4. If the Company will create or use anonymously processed information, it will not cross-check that anonymously processed information with other information or identify individuals related to personal information that was used in the creation of that anonymously processed information.

Disclosure or provision of personal information to third parties

The Company shall not disclose or provide personal information to third parties except as follows:

1. The agreement of the customer is obtained;
2. Statistical data or other examples of information are disclosed or provided in a format that does not enable individuals to be identified;
3. A request for disclosure is received in accordance with a relevant statute or ordinance;
4. Disclosure is necessary for the protection of the life, body, or property of an individual and the situation is one in which it would be difficult to obtain the consent of the customer;
5. Cooperation is necessary to enable the national or a local government to carry out public affairs and there is a risk that the execution of such affairs might be impeded by having to obtain the consent of a customer.

Disclosure

Where a customer wishes to have personal information disclosed, a response shall be provided within a reasonable period of time and to the extent considered reasonable upon verifying that the requesting party is the person to whom the personal information in question pertains (or a representative thereof).

Corrections and deletions

Where a customer wishes to have personal information corrected, supplemented, or deleted and where the personal information currently in the possession of the Company is inaccurate, the relevant information shall be corrected, supplemented, or deleted within a reasonable period of time and to the extent considered reasonable upon verifying that the requesting party is the person to whom the personal information in question pertains (or a representative thereof).

Discontinuation of use

Where a customer wishes to have the use of personal information discontinued or expunged, such use of the relevant information shall be discontinued or expunged within a reasonable period of time and to the extent considered reasonable upon verifying that the requesting party is the person to whom the personal information in question pertains (or a representative thereof)　with relevant laws and regulations.

To those who wish to change the mail magazine destination information or stop distribution

We distributes several types of mail magazines, and each mail magazine has a different method of stopping delivery.
Multiple mail magazines cannot be stopped simultaneously.
Please take the necessary steps to stop distribution for each e-mail magazine. The method of stopping delivery is described at the end of each e-mail magazine.

If you wish to change the destination information for the e-mail magazine distributed via the web, please contact the e-mail magazine inquiry desk at the end of the received e-mail magazine.

* Customers who have My Account on our web support site can also set up a stop of mail delivery on the My Account page on our web support site.

* The above "Mail Magazine" does not include any information sent as part of the maintenance support or any contact regarding the maintenance agreement.

【Click here】 if you wish to discontinue the use of personal information held by us.

If you discontinue the use of personal information, you may not be able to provide services in accordance with your request, which may result in your inadvertent failure. Your understanding should be appreciated.

Personal information inquiries

Any request or inquiry for disclosing, correcting, suspending the use of, or deleting personal information should be directed to the contact as set forth below.

Contact for Inquiries Concerning the Handling of Personal Information

WingArc1st Inc.
E-mail for Inquiries Regarding the Handling of Personal Information * It is possible that a request or inquiry may not be accommodated if it is not possible to verify that the requesting or inquiring party is the customer to whom the relevant information pertains or a representative thereof, if the request or inquiry has not been submitted through the proper channel for the handling of personal information or if the request or inquiry corresponds to information held in accordance with a relevant statute or ordinance.

WingArc1st Inc.: http://www.wingarc.com/en/
TEL: +81-3-5962-7300 FAX: +81-3-5962-7301

WingArc1st shall appropriately handle personal numbers and other specific personal information (hereinafter referred to as "Specific Personal Information") under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter referred to as "Numbers Act") in accordance with a basic policy as set forth below:

1. Name of business
   WingArc1st Inc.
2. Compliance with relevant laws, ordinances, and guidelines
   The Company shall comply with laws, ordinances, guidelines, and other standards and provisions for Specific Personal Information.
3. Matters concerning safety-management measures
   The Company shall implement safety-management precautions as necessary and appropriate to prevent being leaked, misplaced, or damaged and to otherwise manage Specific Personal Information. Employees and third parties (including outsourcees) handling Specific Personal Information shall be subject to appropriate supervision. Safety-management precautions applicable to Specific Personal Information are governed by provisions separately prescribed in the Regulations Governing the Protection of Specific Personal Information.
4. Channel of communications for fielding questions and complaints
   Questions and complaints concerning the handling of Specific Personal Information by the Company shall be appropriately and properly handled in good faith and promptly by the following contact:

Channel of communications for receiving inquiries on the handling of personal information

WingArc1st Inc.
Tel.: +81-3-5962-7400
E-mail

In recognizing that the conservation of the global environment is the most critical issue currently facing humanity, the First Group shall strike a balance between sustainable economic growth and the global environment in all aspects of corporate activities and will accordingly focus on the following:

1. Environmentally friendly software and services
   The Company shall provide environmentally friendly software and services.
2. An environmentally friendly approach to product development and planning
   The Company shall endeavor to take an environmentally friendly approach and reduce the environmental burden of product development and planning.
3. Prevention of pollution
   The Company shall work to prevent global pollution by minimizing the use of hazardous chemicals and other considerations.
4. Green procurement
   The Company shall focus on environmental action from the time equipment and products are purchased and procure raw materials by prioritizing items that have a small ecological footprint.
5. Operational streamlining
   The Company shall promote environmental conservation by streamlining operations, saving resources, implementing energy-saving initiatives, adopting recycling policies, and making operations more efficient.
6. Compliance with statutes and ordinances
   The Company shall comply with relevant statutes and ordinances as well as other such requirements that relate to the environment.
7. Social contributions
   The Company shall contribute to local communities.
8. Information disclosure
   The Company shall publicly disclose information on environmental-conservation activities.
9. Dissemination
   Dissemination shall be undertaken to raise the level of environmental awareness on the part of every employee.
10. Establish a system of environmental management
    The Company shall establish a system of environmental management and continuously improve the system by defining and regularly reviewing environmental goals and targets.

The Company shall disseminate this environmental policy to all employees and board members as well as make this environmental policy available to the public.

WingArc1st Inc.

The Company categorically rejects any involvement with antisocial forces and shall refrain from any conduct that would promote such interaction. As a matter of policy, the Company is committed to confronting such forces with a resolute stance and shall adhere to the policy as follows:

1. The Company will mobilize the entire organization to deal with antisocial forces and make sure that our employees are safe from antisocial forces;
2. The Company will establish close links of coordination with outside specialized agencies in order to prevent damage and harm caused by antisocial forces;
3. The Company will have no relationships, business relationships or otherwise, with antisocial forces;
4. The Company will reject improper requests made by antisocial forces;
5. Where required, the Company will implement legal measures in response to improper requests from antisocial forces;
6. The Company will refrain from backroom deals and providing funds to antisocial forces.

When submitting an inquiry, include the following:

1. name of the customer (if the inquiring party is a representative of a customer, the names of both the customer and the representative),
2. contact information, and
3. contents of the request or inquiry.