This Basic Policy applies to personal data held by Dynabook Inc. in Japan. Concerning the privacy policies of Dynabook's affiliates in Japan or overseas subsidiaries, please find the websites of these companies.

Privacy Policy

Dynabook Inc. (hereinafter referred to as Our Company), in accordance with its Basic Commitment and Standards of Conduct, engages in business activities that contribute to society, while endeavoring to earn the trust of all customers.
Our Company protects personal data obtained from its stakeholders in the course of business activities appropriately in accordance with the following Basic Policy, recognizing that personal data is an important asset of each stakeholder and also an important asset for Our Company, leading to creation of new value.

１．Basic Policy

1. 1) Our Company strictly observes the Act on the Protection of Personal Information and relevant laws, guidelines established by the government and other regulations. Our Company has established the Personal Data Protection Program (the "Program"), which Our Company carefully implements and maintains, while striving to continuously improve the personal data protection management system.
2. 2) Our Company has established a management framework to protect personal data assigning a person in charge at each of its relevant divisions and ensures that all officers and employees recognize the importance of the Program and comply with it.
3. 3) Our Company utilizes personal data within the scope of the intended use that is clearly communicated to customers, and takes measures not to be used beyond the scope. Our Company does not disclose or provide personal data provided by customers to third parties except with the consent of the customer from whom the personal data was obtained or when there is a legitimate reason.
4. While maintaining the accuracy and up-to-dateness of personal data, Our Company strives to prevent unauthorized access to personal data or the leakage, loss, or damage of personal data and continually enhances and remediates information security management.
5. Our Company responds to inquiries from customers concerning personal data or requests from customers for disclosure of personal data sincerely and without delay.

Established: April 1, 2016
Kiyofumi Kakudo
Representative Director, President ＆ CEO
Dynabook Inc.

２．Intended Use of Personal Data

Our Company clearly indicates in advance the purpose for which the personal data is intended to be used. Our Company uses the information within the scope of the stated purpose of use. When the need to use a customer's personal data for any purpose that goes beyond the stated purpose of use arises, Our Company notifies the customer to that effect and obtains the customer’s consent before using the information for such purpose. Our Company uses personal data which are contracted from other companies within the scope of the contract with the company.

３．Provision of Personal Data

1. 1) Our Company does not disclose customers' personal data to third parties except in the following cases.
   1. (1) When the customer has given a prior consent to the disclosure
   2. (2) When complying with laws and regulations
   3. (3) When disclosure is necessary for the protection of human life, human health or property and it is difficult to obtain the consent of the customer
   4. (4) When Our Company consigns the handling of personal data to a third party within the scope necessary to achieve the purpose of use
   5. (5) When another entity succeeds to the business of Our Company due to a merger, corporate separation, transfer of business or otherwise
2. 2) When it is deemed that an inquiry from a customer concerning products, repairs, or service can be more appropriately dealt with by an Our Company affiliate or distributor, we may provide the customer's name, address, telephone number and other information to the affiliate or distributor on the basis of consent of the customer.

４．Procedures for Requests for Disclosure

Our Company complies with the following requests from customers concerning the customer's personal data held by Our Company : 1) Request for disclosure ; 2) Request for notification of the intended purpose ; 3) Request for correction; 4) Request for addition; 5) Request for deletion; and 6) Request for cessation of use or cessation of disclosure to third parties. Please refer to Procedures concerning Requests for Disclosure etc. by Documents for details of request procedures. Please note that there is a fee charged for requests for disclosure and requests for notification of the intended use.

５．Inquiries Concerning Personal Data

1. Customers should direct inquiries or complaints concerning their personal data to the window of products and services with which they have registered the information (Product Inquiries).

Our Company may record phone calls that we accurately understand comments or requests from customers.

６．Request to Children under 16 years

When children under 16 years provide their personal data to Our Company, they should provide them only after obtaining the consent of a parent or guardian.

７．Notice regarding websites of Our Company

1. 1) Notice for Use of Services
   Please note that some services provided by Our Company (including services offered on websites operated by Our Company) may not be available if the customer does not provide personal data.
2. 2) Encryption of Transmission
   In case Our Company receives personal data from customers, the website uses encryption technology such as SSL (Secure Sockets Layer) and the personal data of customers is protected. It may not be possible to access the page from browsers that do not support SSL or other technologies.
3. 3) Use of Cookies and Web Beacons
   Our Company uses cookies and web beacons to provide better services on its websites. For details, please refer to Use of Cookies, Web Beacons and Other Technologies.
4. 4) Notes for Links
   Our Company disclaims any responsibility for the security of customers' personal data used on third parties' websites that are linked from Our Company websites. Please confirm the privacy policies of the linked websites of third parties.

８．Information on important changes and notices

When important changes and notices on personal data arise, Our Company will post it to Information.