Oct. 1, 2007
Gen Mishiba, President, CEO, and COO

LAC Holdings, Inc. (the Company) takes seriously society’s views on the privacy of personal information and recognizes the importance of protecting personal information. The Company will protect the privacy of personal information as vigorously as possible.

Privacy Policy

In undertaking to keep personal information strictly confidential, the Company has set the following privacy policy, established obligatory privacy measures, and strengthened its personal information management.

1. Policy on the appropriate collection, use, and disclosure of personal information

1. (1) Collection of personal information
   • The Company collects personal information only with the consent of the individual and shall collect information in a legal and fair manner.
   • The Company collects personal information as appropriate for the scope and objective of the applicable business.
   • The uses and purposes of disclosure of collected personal information shall be identified by the Company. Furthermore, the collection of personal information shall be limited to that which is necessary for the purposes identified by the Company.
2. (2) Use and disclosure of personal information
   • The use and disclosure of personal information shall be limited to the purposes to which the individual has consented.

2. Policy on the appropriate management of personal information

1. (1) Assurance of the accuracy of personal information
   • Collected information shall be maintained in an accurate and up-to-date condition. Furthermore, the Company shall respond without delay to requests from an individual concerning the disclosure, revision, or deletion of his or her personal information.
2. (2) Secure management of personal information
   • The Company shall recognize the risks in all aspects of handling personal information including, among others, improper disclosure, loss, defamation, and violations of applicable laws or statutes, and shall ensure all necessary measures are taken to minimize these risks.
   • The Company shall establish frameworks and implement prompt and correct remedies in the unlikely occurrence of a security breach of personal information as mentioned above.
3. (3) Principle on the outsourcing of personal-information processing
   • Where it is necessary to outsource to a third party the processing of personal information, the Company shall select the outsourcing contractor in reference to the Company’s standards, shall bind the outsourcing contractor with a confidentiality agreement, and shall manage and monitor appropriately the handling of personal information.

3. Policy on legal compliance

The Company shall abide by laws related to the handling of personal information, guidelines formulated by Japan, and other regulations.

4. Policy on responding to inquiries and consultations on personal information

The Company shall designate a privacy coordinator to respond to inquiries and consultations on personal information in an appropriate and prompt manner.

5. Policy on inspections

The Company shall perform on a regular basis validations and audits on the operation of personal information protection mechanisms to verify such mechanisms are operated appropriately.

6. Policy on continuous improvement

The Company shall periodically revise and continuously improve its personal information protection mechanisms based on situational changes, social developments, and other circumstances.