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Personal Information Protection Policy

SEISA Gear, Ltd. (hereinafter referred to as “the Company”) recognizes it the important obligation to protect personal information. The followings outline the Company’s privacy policy regarding the handling and protection of personal information provided by customers, shareholders, venders and officers and employees of the Company.

The Company utilizes fair and appropriate methods to collect personal information, and retains such information
in an accurate manner, and manages such information safely.

The Company will not utilize personal information for purposes outside the scope specified at the time such
information is collected.

The Company will not provide personal information to any third party without the prior consent of the owner of
such information, unless prescribed by law.

In case the Company outsources a third-party to manage personal information, the Company will limit the scope of
the information to the minimum necessary, and will enter into a contract to ensure the protection of this personal
information. Furthermore, the Company will monitor the activities of the third party in an appropriate manner.

The Company uses reasonable and appropriate information security countermeasures to prevent personal
   information from being lost,destroyed, tampered with, and leaked to outside parties. In addition, other
   countermeasures are implemented to reduce the risk of unauthorized access to personal information by third
   parties.

The Company will attempt to quickly resolve any matter regarding the disclosure, revision, termination of use, or
deletion of personal information to a reasonable degree, at the request of the owner of such information.

The Company is thoroughly committed to ensuring that its officers and employees handle personal information in
   an appropriate manner on a daily basis. To this end, the Company provides training to its officers and employees
   on this personal information protection policy and other internal rules regarding the handling and management of
   personal information.

The Company has appointed a Personal Information Protection Manager who is responsible for managing the
Company's personal information protection policy and for reviewing, maintaining, and improving the policy on a
continuous basis.

March, 2005
SEISA Gear, Ltd