PRONEXUS handles the personal information provided by its clients appropriately based on its Privacy Policy.
The Privacy Policy and the Purpose of Use of Personal Information are defined as follows.

PRONEXUS Inc. Privacy Policy

PRONEXUS provides support services for corporate disclosure and investor relations activities. We recognize that the protection of personal information is the basis of our business as well as an important social responsibility. In order to appropriately handle personal information, we have established a personal information protection management system, implemented as follows.

  1. We will strive to protect personal information by adhering to laws, regulations and rules governing personal information, designating an administrator for managing personal information in each department, and requiring these administrators to follow appropriate management practices.
  2. We will obtain, use, and provide personal information by fair and lawful means, and take concrete measures to prevent usage other than the intended purpose of use.
  3. We will manage personal information safely and accurately, and take measures to prevent the unlawful access, loss, damage, falsification, and leakage of personal information, as well as promptly implement countermeasures in case of the above.
  4. We will not provide personal information to a third party without the consent of the person involved. In addition, when the handling of personal information is outsourced to an external party, we will require the external party to follow the same handling practices through a contract.
  5. The following contact office will promptly address complaints and inquiries on personal information and our personal information protection management system.
  6. We will continuously review our personal information protection management system in striving for its improvement.

Established: March 8, 2005
Revised: September 1, 2009
Revised: June 7, 2010

PRONEXUS Inc.
Takeshi Ueno
President and Representative Director

Inquiries about Our Privacy Policy  President's Office
Tel: +81-3-5777-3145  E-Mail: asp@pronexus.co.jp

PRONEXUS Inc. Handling of Personal Information

1. Name of Business and Administrator of Personal Information Protection

PRONEXUS Inc.
Administrator of Personal Information Protection   Yasuhiro Ogawa, Director and Managing Executive Officer

2. Purpose of use

The purpose of use of personal information obtained directly in writing will be specified clearly in advance.
The purpose of use of personal information other than those obtained directly in writing (such as through the telephone), or obtained indirectly from published information (phone directory, list or the Internet), will be as follows.

(1) Outsourced (received via consignment) information

  • Limited to the purposes designated by the outsourcer

(2) Information obtained from published information (securities report, official journal, website, commercially available registry, etc.)

  • For selling our products and services including corporate information databases
  • For providing information on our company and our company's products and services

(3) Personnel information obtained from our group companies

  • For business communication between group companies

(4) Information obtained directly from the party concerned not in writing, but verbally or via the telephone, etc.

  • For providing information on our company, and the Company's products and services

3. Information provision to a third party

PRONEXUS maintains corporate information databases that include personal information intended for provision to third parties.

(1) Personal information subject to provision to a third party

  • 1. Personal information recorded on disclosure documents submitted to securities exchanges (including overseas) and submitted under the law
  • Business contact name: title, name
  • Representative director name: title, name
  • Individual stockholders: name, shareholdings
  • Corporate executive officers: title, name, birth date, background summary, shareholdings
  • Auditor: name of auditing firm, name of company audited, name
  • 2. Personal information recorded on commercially available registries
  • Name and title of executive officers including representative director recorded on the registered list

(2) Means or methods of provision to a third party

Publication on the Internet and electronic media

(3) Provision of personal data listed under (1) above to a third party will cease based on request of the party concerned. Please contact the office below.


Moreover, prior consent from the party concerned will be obtained whenever providing personal information other than those listed above to a third party.

4. Partially outsourced services

In order to achieve the purpose of use, a part of our services may be outsourced. A contract is entered into in ensuring that the same level of personal information management is implemented by the outsourcing company.

5. Contact office for request of disclosure and complaints

The following contact office will address any of the requests listed below and complaints.

Contact Office
5th Floor, Shiodome Building, 1-2-20, Kaigan, Minato-ku, Tokyo 105-0022, Japan
General Manager, President's Office, Personal Information Protection Contact Office, PRONEXUS Inc.
Tel: +81-3-5777-3145  E-mail: asp@pronexus.co.jp

Request items:

  • Notification on purpose of use of personal information subject to disclosure
  • Disclosure of personal information subject to disclosure
  • Revision, addition and deletion of personal information subject to disclosure
  • Suspension of usage or provision of personal information subject to disclosure
  • Complaints and inquiries

Please note that we do not accept or handle the above requests in person. For detailed procedures, refer to Procedures on Personal Information Disclosure below.
PRONEXUS belongs to the following authorized personal information protection organization. Complaints concerning PRONEXUS' handling of personal information can also be directed to this organization.

Name of authorized personal information protection organization:
   Japan Institute for Promotion of Digital Economy and Community

Submit complaints to:
   Personal Information Protection Consultation Service Office
   Kikai-Shinko-Kaikan Bldg., Shibakoen 3-5-8, Minato-ku, Tokyo, 105-0011 Japan
   Tel. +81-3-5776-1379 or 0120-700-779 from within Japan

6. Voluntariness of provision

PRONEXUS will use personal information for the purposes described in item "2. Purpose of use," above. As the provision of personal information is voluntary, if the provision of information was not agreed upon, then a part of, or the entire intended purpose of use described above may not be executed for that information.

7. Obtaining personal information by ways in which the individual cannot be easily recognized

PRONEXUS does not use applications such as Cookies to obtain personal information from the Internet-based services it provides.

PRONEXUS Inc. Procedures on Personal Information Disclosure

Our company will respond to requests from the party concerned, or his/her proxy for notification on purpose of use, information content revision, additions and deletions, termination of use, deletions and stoppage of provision to a third party (hereafter "changes") as well as disclosure.

I Procedure to request personal information disclosure

1. Contact office

To file a request for a disclosure, contact the Personal Information Protection Contact Office (refer to Handling of Personal Information) by telephone to request a "Request Form for Disclosure of Personal Information." Documents will be sent for you to fill out and submit.

2. Required documents and submission location

(1) A completed request form we have sent you with all items filled out

(2) A copy of your health insurance card, or official ID that can be used to verify your name and address (if there is detailed information such as your legal domicile, please ensure they are blacked out from the photocopy. Documents you submit will be appropriately handled as personal information).

(3) A 2,000-yen postage stamp as a processing fee (refer to item 4. below)

Enclose the above in the same envelope and send by post to our Personal Information Protection Contact Office. Please write "Request Form Enclosed" in red ink on the front of the envelope.

3. Request by proxy

If the person making the disclosure request is a minor, legal representative of ward of age, or proxy authorized by the person whom the information requested for disclosure is concerned, then please also enclose either (1) or (2) listed below in addition to the documents listed above.

(1) For legal representatives

  • Document that can verify the validity of legal representation
    (copy of family register, copy of health insurance card with the name of dependent included is acceptable for the parent of a minor) 1 copy
  • Document that can verify the identity of the legal representative of a minor of ward of age
    (copy of an official document such as driver's license or passport of the legal representative) 1 copy

(2) For authorized proxy

  • Letter of authorization 1 copy
  • Seal registration certificate of the person concerned 1 copy

4. Processing fees and payment method

We charge a processing fee of 2,000 yen for every request to disclose personal data we maintain. Please enclose a 2,000-yen postage stamp with the request form.
We may contact you if there is a shortage in the processing fee, or a missing processing fee with your request. However, if the processing fee is not paid within the designated period, the request for disclosure will be deemed invalid.

* Cases when retained personal data will not be disclosed
The disclosure request will not be performed under the following conditions. When the non-performance of disclosure is determined, the decision and reason will be notified in writing. However, the processing fee will not be refunded even in case of non-performance.

  • When the person concerned cannot be verified (when there is a discrepancy between the address written on the request form, document for verifying the identity of the person concerned and that in the Company's registered personal information)
  • When the power of attorney cannot be verified in case a request is made by proxy
  • When there is a mistake in the designated request form that was not properly corrected
  • When the target of the disclosure request does not exist in the retained personal data
  • When the disclosure puts the life, body, property or other rights of the person concerned or a third party at risk
  • When the disclosure has the potential of causing significant hindrance to the proper execution of our business
  • When it constitutes a violation of the law

II Procedure for making changes to personal information

1. Contact office

To make changes to personal information (notification on purpose of use, information content revisions, additions, and deletions, termination of use, deletions and stoppage of provision to a third party), contact the Personal Information Protection Contact Office by telephone to request a "Personal Information Changes and Usage Stoppage Request Form," or contact your account manager within the Company directly.

2. Required documents and submission location

Complete all items on the request form we have sent out and return it with the following document to our Personal Information Protection Contact Office by post (documents you submit will be handled appropriately as personal information).

  • A copy of your health insurance card, or official ID that can be used to verify your name and address (if there is detailed information such as your legal domicile, please ensure they are blacked out from the photocopy).

If a request is made to your account manager, once the identity of the client is verified, your account manager will proceed to complete the required procedures.

3. Request by proxy

Same as Procedure 3 for requesting personal information disclosure.

4. Processing fees and payment method

There is no processing fee for making changes.