PRIVACY POLICY

DECLARATION OF PROPER MANAGEMENT AND PROTECTION OF PERSONAL INFORMATION

At Xaephyr Reliance Group Inc.(XRG), we believe that it is one of our social responsibilities to safeguard the personal information of our employees and clients in order to continue operating a successful business. For this purpose, we have established the following guidelines for protecting personal information. All of us at XRG will comply with these policies, make our best efforts to prevent the loss, falsification, tampering or leakage of personal information, take immediate and appropriate actions in cases that such accidents do occur, and strive for proper handling, management and maintenance of personal information.

1. On Obtaining Personal information

XRG will obtain personal information by legally acceptable and fair methods through our registration Web site, personal interviews, etc. The personal information that XRG will obtain includes, but is not limited to, such contact information (names, contact info, etc.) as required to enable us to identify particular individuals for our employment or as clients. The following is the methods of obtaining, and purpose of using, personal information that is acquired by methods other than directly from the person in documents. • Types of, and methods of acquiring, personal information: such personal information as acquired from magazines and on the Internet. • Purpose of using the information: To contact the person for initial sales inquiries and perform related tasks. The provision of the information is voluntary; when providing us with your personal information, please ensure that you read our privacy policy and understand its contents beforehand. If you decide not to provide us with necessary personal information, then please understand that such deed may cause hindrance to our provision of executive search services to you and/or our hiring of you as an employee at XRG.

2. On Using Personal information

XRG will use personal information for the provision of sales and services and for the proper management of our employees. XRG shall not use personal information for any other purposes.

3. On Providing Personal information

XRG will not provide any third party with personal information without prior approval obtained from the candidate to whom the personal information belongs to, unless otherwise stated in the laws and regulations of Japan or unless we have already obtained the consent of the candidate.

4. On Properly Managing the Safety of Personal information

XRG will always safeguard and keep the personal information thus obtained accurate by constant updating. We take reasonable information security measures against illegal access and invasion of computer viruses, in order to protect the information against loss, destruction, falsification, leakage, etc. Should such incidents occur, XRG shall take appropriate actions in a most timely manner, according to our policies and countermeasures for emergencies regarding personal information.

5. On Disclosing and Making Corrections etc. to Personal information

XRG understands that candidates have the right to request disclosure, correction, change, deletion, etc. of the registered data which belongs to themselves, and, when those requests be made, XRG shall respond within a reasonable time frame to such requests which are legitimate. Please contact us at the address below if you would like the disclosure, correction, etc. of your personal information. In such cases, we reserve the right to verify your identify. However, in the following cases, XRG might not take the above action: cases in which disclosure might harm the life, body, property and other rights and interests of the person or the third party; cases in which disclosure might noticeably impede the proper execution of the operations of the business entity concerned; cases in which disclosure violates laws. Where disclosure is regulated by laws and other regulations, we shall take appropriate actions according to the applicable laws.

6. On Our Organizational Structure to Safeguard Personal information

XRG has established an internal organizational structure to ensure proper management of personal information, by such measures as nominating a Personal Information Protection Officer and other personnel involved in management of personal information, and so on. XRG will train our employees on how to manage and handle personal information in a proper way for their daily business activities, in order to prevent, in advance, unauthorized disclosure of personal information and other illegal actions, as well as to enhance the proper handling structure of personal information with the company.

7. On Complying with Laws, Guidelines and Other Codes Stipulated by the Japanese Government

XRG shall comply with all laws, guidelines and regulations concerning the protection of personal information, specifically stipulated by the Japanese government, as related to our businesses.

8. On Formulating, Implementing and Complying with the Personal Information Protection Management System

XRG shall formulate a personal information protection management system for the protection of personal information, as well as various other laws and regulations regarding the handling of personal information. XRG shall thoroughly implement and maintain this system for the entire company. Additionally, XRG shall consider, analyze and discuss opinions and requests from within and outside of the company to update and improve the system on a regular and continuous basis.

DETAILED INFORMATION ON THE PROVISION OF PERSONAL INFORMATION

Information to be provided to third parties:

Of all personal information obtained, as for personal information for identification, XRG will use it for identifying and contacting relevant individuals when providing executive search services to our clients and when hiring employees. As for other types of personal information, XRG will use it for matching the needs of client companies who are in need to executives and professionals, on one hand, and skills and qualifications of the candidates, for the purpose of introducing the latter to the former.

Methods of providing personal information:

When providing the above personal information to third parties, XRG shall mainly use e-mails to send the information to them. In doing so, XRG shall employ appropriate measures regarding sending and receiving of personal information, in order to ensure security of the information handled. Types of recipients to whom we provide personal information: XRG shall provide personal information to client companies who look for and wish to hire executives and professional personnel.

Agreements on properly handling personal information:

On the agreement contracts that XRG signs with the client companies to which we provide personal information, it is set forth that neither party is allowed to disclose any confidential information (including personal information) obtained from the other party and that the above prohibition will remain in effect even after the above agreement expires.

Please contact us below if you have any complaints or would like to consult, express opinions or ask questions regarding personal information. Personal Information Customer Service Xaephyr Reliance Group Inc. Tokyo JAPAN Email: