Rozetta Corporation ("we", "us") develops and sells automatic translation machines. In order to appropriately handle all personal information used for our business, we have established this Personal Information Protection Policy as a code of conduct to be observed by all our employees and will strive to ensure that all employees comply with it.

We comply with laws and regulations concerning the handling of personal information, guidelines and other norms established by the government. For this reason, we design and operate a personal information protection management system that conforms to the Japanese industrial standard "Personal Information Protection Management System-Requirements" (JIS Q 15001).

We acquire, use, and provide appropriate personal information according to the content and scale of our business. This includes not handling personal information beyond the scope necessary for the achievement of the specified purpose of use and taking measures to that end.

In the event the handling of personal information is entrusted in whole or in part, we shall conduct necessary and appropriate supervision of the entrusted party in order to ensure the safety management of the entrusted personal information.

We will not provide personal information to any third party except with the consent of the person in question or in accordance with laws and regulations.

We will take measures to prevent and rectify the leakage, loss, or damage of personal information.

We will strive to respond appropriately and promptly to complaints and consultations regarding the handling of personal information. In addition, we will accept requests for disclosure of personal data in our possession (notification of the purpose of use, disclosure, correction, addition or deletion, stop of use or provision). Please contact the following "Personal Information Complaints and Consultation Desk" regarding procedures for requests.

We continually improve our personal information protection management system.

Rozetta Complaint Consultation Desk

privacy@rozetta.jp

Date of enactment: November 30, 2007 Revision date: February 1, 2020 Rozetta Co., Ltd. Junichi Goishi, Representative Director

Handling of personal information

(Published under the Personal Information Protection Act and JIS, made readily available to the individual.)

■ The personal information you enter will only be used for the following purposes:

Personal information about the customer 1.1 Sales, provision, and delivery of products and services, introduction of sales and service contact points, information on events such as seminars and exhibitions, information on products and services, and provision of promotional materials, etc. 1.2 Surveys and analysis to develop better products and services, etc. 1.3 Providing maintenance and support, etc. 1.4 Contact, cooperate, negotiate, fulfill the contract, request fulfillment, etc.

Personal information provided by suppliers 2.1 For the fulfillment of contracts with suppliers

Personal information about registered translators, registered interpreters, registered instructors, and interns at home 3.1 Implementation and operation of operations, etc. 3.2 Contact with registrants, etc. 3.3 Surveys and analysis to improve recruitment, operation, etc.

Personal information of those who wish to join us 4.1 Communication, Provision of Information, and Recruitment Selection 4.2 Surveys and analysis to improve recruitment, operation, etc.

Personal Information obtained indirectly or obtained by means other than writing 5.1 Personal information commissioned by customers 5.1.1 Translated manuscripts: To carry out commissioned translation work 5.2 Personal information obtained indirectly from suppliers 5.2.1 Customer information: For use in sales activities 5.2.2 Employee information of group companies: To carry out consignment work such as personnel management, health management, and salary calculation 5.3 Curriculum vitae and resume from recruitment agencies 5.3.1 For the purpose of providing communication, information, recruitment selection, recruitment, investigation, and analysis to improve business operations

※ In addition, in the event the Purpose of Use is explicitly or notified individually, the use of Personal Information shall be in accordance with the agreement.

■ Contact the following "Complaints and Consultation Desks for Personal Information" for the purpose of use of all Retained Personal Data, procedures for requests for disclosure, etc., and other matters related to Retained Personal Data. The request will be responded in timely manner.

■ Personal information obtained may be outsourced. In this case, we will select an outsource with a high level of personal information protection, enter into an agreement for proper management and confidentiality of personal information, and ensure that appropriate management is implemented.

■ In the event of a request for disclosure (notification of the purpose of use, disclosure, correction, addition or deletion of the contents, stop or deletion of use, or suspension of provision to a third party) of the acquired personal information, the following contact person shall respond without delay.

■ Registration of personal information is voluntary. However, if you did not register the required items, the above objectives may not be achieved.

■ We do not acquire personal data by cookies (Cookie) or other methods that are difficult for you to recognize.

Rozetta Complaint Consultation Desk

Email: privacy@rozetta.jp

Management of confidential information

In our translation operation and automated translation services, the handled personal information of the customers, the received translation manuscripts, the data that is sent by the customer through automated translation, and other personal information of the customer, are processed as confidential information, and we have established a strict control system.

Privacy Mark

We have obtained a privacy mark as part of our confidential information management system.

The Privacy Mark is granted by the Japan Information Processing Institute (JIPDEC) to a business entity that has established a system to take appropriate protective measures for personal information in accordance with the Japanese Industrial Standards "JIS Q 15001 Personal Information Protection Management System-Requirements."

As we have obtained the Privacy Mark, in case our customer also obtained the Privacy Mark, we have the obligation to supervise our subcontractors that the information is handled in secured manner.

Security Measures

We limit the number of employees who can handle information, provide education and guidance on security to raise employee awareness.

In order to protect customer information from interception by third parties and to securely send and receive customer information, encrypted communication (Secure Sockets Layer protocol (SSL)) is being used.

The server we use is manned 24 hours a day, 365 days a year at our ISMS certified facility to protect against unauthorized external human, physical, and technical access.

Basic Information Security Policy

Rozetta Co., Ltd. and each of our group companies (hereinafter referred to as the "Rozetta Group") establish, implement, and promote an information security management system.

The Rozetta Group will comply with information security laws, national guidelines, and other norms.

The Rozetta Group will establish an appropriate organizational, human, technical and physical structure for information security.

The Rozetta Group will educate its executives and all employees on information security on an ongoing basis and will strive to recognize the importance of information assets and ensure that they are used appropriately.

The Rozetta Group will strive to prevent the occurrence of incidents related to information security. In addition, in the unlikely event that a problem occurs, the Rozetta Group will respond promptly to minimize the damage and strive to prevent the recurrence of such incidents.

The Rozetta Group will regularly analyze and evaluate the status of the implementation of information security measures and strive for continuous improvement in order to maintain and build an appropriate management system.