• Benesse Privacy Statement
• Public Statement Regarding Protection of Personal Information

Benesse Privacy Statement

The Benesse Group
May 25, 1999
Last Revision: Oct 16, 2007
Soichiro Fukutake
Director, Chairman

Benesse: To support "Benesse = well-being" for each individual

The Benesse Group is committed to helping each individual achieve a life of well-being.

In such areas as education, learning, childcare, living and lifestyles, and nursing care, the Benesse Group provides products and services that support individuals in living fulfilling lives.

We will maintain a dialog with customers in the development of products, we will seek to achieve the highest level of specialization in each business segment, and we will actively use leading-edge technology to develop our business. Our ideal is to fully respect the human and individual contact needed in the choices people make related to learning and better living.

Our Foundation: Services and Trust

We at the Benesse Group express our guiding principles and responsibilities in the following manner.

• Individuals desire effective support so they can maximize their possibilities in learning and in lifestyle planning, and such needs are individualizing and diversifying. We are aware that these developments are bringing about important social changes.
• We are committed to understanding individual customers well and to providing products and services on education and lifestyle planning that will directly respond to individual needs, desires, and choices.
• To improve the quality of services and the means for their delivery, we will make use of leading-edge information and communications technology. At the same time, we will maintain regular individual contact with each customer.
• What is most important is to gain the understanding and the full confidence of customers regarding our guiding principles and activities.

Trust and Personal Information

We are fully aware that trust and respect for personal information are two sides of the same coin.
The reason we collect and make use of the personal information of customers is to support individual customers in their learning activities and in achieving better lives. To gain the trust of customers, it is essential that our use of the personal information of customers does not give rise to uncertainties.

It will be important for us to respect the thinking of customers on the use of personal information and for customers to understand what we specifically put into practice in the handling of their personal information.

This privacy statement does not apply to employment management, such as regarding staff.
Each Benesse Group company will independently draft and publicly announce their privacy statements.

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Public Statement Regarding Protection of Personal Information

Personal Information Handling Business
Benesse Holdings, Inc.
October 1, 2009
Tamotsu Fukushima
Representative Director and President

Benesse Holdings, Inc. (hereinafter the "Company") hereby announces matters related to the use of personal information and retained personal data obtained by the Company, the provision to third parties of personal data, procedures regarding requests for disclosure etc. of retained personal data, and the reception of complaints regarding the handling of personal information based on the Law Concerning the Protection of Personal Information, Basic Policy Concerning the Protection of Personal Information (Cabinet decision), enforcement regulations for the Law Concerning the Protection of Personal Information and guidelines established by the state minister in charge based on the Law Concerning the Protection of Personal Information.
Personal information related to employment management, such as the personal information of the Company's employees and others, does not fall under the provisions of this public announcement.

PUBLIC STATEMENT ITEMS

I. Purposes of Use for Personal Information and Retained Personal Data

Personal information obtained by the Company is used for the following purposes:

We shall, in principle, clearly state separately the purposes of use of personal information obtained directly from the principal* in writing (including websites).

In addition, personal information obtained directly from the principal by means other than in writing (or websites), or personal information obtained indirectly, will be used only for the purposes detailed below:

* "Principal" is defined hereinafter as the specific individual identified by the personal information.

Type of personal information	Purposes of use
Shareholders` personal information	(1) To exercise rights and fulfill obligations based on the Companies Act (2) To provide services of benefit commensurate with shareholders` standing (3) To implement policies for promoting smooth relations between the Company and its shareholders from the perspective of both the corporation itself, and its members (4) To maintain the shareholder database, including compiling data prescribed by various laws and regulations (5) Other purposes related to or incidental to the above items
Management of lodging facilities, art museums, and other facilities	(1) To provide products and services in response to orders (2) To provide information about company products and services (3) To provide information about cultural and artistic activities and community revitalization initiatives related to these businesses. (4) To prepare questionnaires and surveys as well as statistical and marketing materials (5) To use in planning and development related to these operations (6) To outsource operations or request feedback from monitors in the various processes, including the planning, development, sales promotion, sales and delivery of products or services (7) Other purposes related to or incidental to the above items
Personal information of prospective candidates for employment	(1) To select and contact prospective candidates (2) Other purposes related to or incidental to the above items

II. Matters regarding Provision of Personal Data to Third Parties

We shall properly control the personal data retained and shall not provide such personal data to third parties without receiving in advance the consent of the principal, with the exception of the following conditions:

• When based on laws or regulations
• When necessary for the preservation of life, limb, or property and when gaining the consent of the principal is difficult
• When necessary in particular for the improvement of public health or promoting the sound development of children and when gaining the consent of the principal is difficult
• When required to cooperate with national or local government institutions or contractors to such institutions in the performance of work prescribed by laws and regulations and when gaining the consent of the principal risks impeding the performance of this work

III. Procedures for the Disclosure, Correction, Addition, or Deletion of Retained Personal Data

Based on the Law Concerning the Protection of Personal Information, we shall respond to requests by a principal or his or her agent for the disclosure, correction, addition, or deletion (hereinafter, "requests for disclosure, etc.") of retained personal data. However, related laws and regulations sometimes prevent us from responding to such requests.

1. Specification of Items That Are Subject to Requests for Disclosure, Etc.
   The principal or his or her representative making requests for disclosure, etc. should specify the information for disclosure, correction, addition, or deletion using the retained personal data items listed in the designated request form.
2. Submission of Requests for Disclosure, Etc.
   Please phone the contact point listed in IV. below to receive by mail the required forms for making requests for disclosure, etc.
3. Forms (Format) to Be Submitted at Time of Request for Disclosure, Etc.
   When making requests for disclosure, etc., the designated request form we will send you by mail should be filled out in full and returned by mail with a document identifying the principal. Documents to be returned by mail are a) and b) below.
   1. One designated request form
   2. Identification document
      • In the case of a driver's license, health insurance card, or other official document stating the principal's current address, one copy of the document should be enclosed with the request form.
      • In the case of a passport or other official document not stating the principal's current address, one copy of the document and one copy of the principal's certificate of residence should be enclosed with the request form.
4. Requests for Disclosure, Etc. Made by a Representative
   If the person making requests for disclosure, etc. is a legal representative of a minor or an adult ward or a proxy authorized by the principal to make requests for disclosure, etc., in addition to the request form specified in a) above, the documents listed in a) or b) below must also be enclosed.
   1. In the Case of a Legal Representative
      1. (1) Document verifying the power of attorney of the legal representative
         • A family register or, in the case of a person with parental authority over a minor, one copy of a health insurance card on which are written the names of family dependents
      2. (2) Document verifying the identity of the legal representative
         • In the case of a driver's license or other official document stating the legal representative's current address, one copy of the document should be enclosed
         • In the case of a passport or other official document not stating the legal representative's current address, one copy of the document and one copy of the legal representative's certificate of residence should be enclosed
   2. In the Case of an Authorized Proxy
      1. (1) One copy of a letter of attorney specified by the Company
      2. (2) One copy of the principal's certificate of seal impression
      3. (3) Document verifying the identity of the authorized proxy
         • In the case of a driver's license or other official document stating the authorized proxy's current address, one copy of the document should be enclosed
         • In the case of a passport or other official document not stating the authorized proxy's current address, one copy of the document and one copy of the authorized proxy's certificate of residence should be enclosed

   Note: The copy of the certificate of residence and certificate of seal impression referred to in 3. and 4. above must have been issued within three months of the request date.

5. Processing Fee and Method of Fee Collection
   Requests for disclosure are subject to the following processing fee.
   (No processing fee is charged for requests for corrections, additions, or deletions.)
   Processing fee: ¥970 (including consumption tax, etc.) per request
   The processing fee should be paid through a financial institution designated by the Company. The handling fee of the financial institution is to be covered by the principal or representative requesting disclosure.
6. Method of Responding to Requests for Disclosure, Etc.
   Responses are sent in writing to the address recorded in the request form.
7. Purposes of Use for Personal Information Obtained via Requests for Disclosure, Etc.
   The personal information obtained via requests for disclosure, etc. shall be used only to process the relevant request. Documents submitted shall not be returned. Documents shall be retained for two years from the date of response to the request for disclosure, etc., and then destroyed.
8. Notes
   1. We will contact you should the conditions below arise. Please note that if we do not receive an appropriate response within a certain period, we will conclude that a valid request for disclosure, etc. was not received. In such case, any fee already paid will be refunded.
      • When the designated documents are incomplete
      • When the principal cannot be verified, such as when the address recorded in the request form, the address recorded in the identification document, and the address in our records do not agree
      • When power of attorney cannot be verified regarding the request made by the representative
      • When the processing fee is not paid, or is not paid in full
   2. If a request for disclosure, etc. falls under one of the following, the information shall not be disclosed. In the event of nondisclosure, we shall notify the principal or his or her representative of the same in writing and state the reason why compliance with such a request is not possible. The processing fee will be refunded.
      • When disclosure risks injuring the life, limb, property, or other rights or interests of the principal or a third party
      • When disclosure risks seriously impeding the appropriate execution of the Company's business
      • When in violation of other laws or regulations

IV. Personal Information Inquiry Desk

Inquiries

1. No request made in person directly at the Company's offices shall be accepted.
2. Separate regulations govern the matters provided in I. to III. in relation to executives and employees (including retired employees and executives) of the Company. Please inquire at the above contact point regarding the handling of such personal information.