Groovenauts, Inc. (hereafter referred to as “the Company”) deals with its customers’ information
assets based upon the Basic Information Security Policy below.

Basic Information Security Policy

In order to maintain the trust of its clients and competitiveness, it is necessary to employ a safety system to appropriately protect information assets against loss, theft, and misuse. This “Basic Information Security Policy” is the basic safety plan of the Company and is stipulated in order for the operation of adequate protective measures to secure the information assets maintained by the Company. All of the officers and the employees seek to understand the aforementioned intent and comply with the Basic Information Security Policy, and continually improve upon it.

  1. The Company keeps safety measures in place furnished with the necessary management systems and equipment to handle the information assets in its possession in terms of confidentiality, safety and availability, and the Company also protects such assets.
  2. The Company creates a suitable environment by providing education and training to ensure that all of its full-time and contract employees, as well as external contractors, and all parties related to the Company’s information assets, understand the Company’s “Basic Information Security Policy,” and operate in accordance with related laws and rules.
  3. Of the full-time managing directors, one individual holds an information security supervisor post, acting as a general manger of information security.
  4. Employees are to operate in accordance with the regulations set forth for information security measures. Employees violating the regulations will be punished as stipulated in the rules of employment.
  5. The Company reviews the information security measures timely by considering the status of their implementation and changes both inside and outside of the Company.

Saishu Eihiro, President and CEO, Groovenauts, Inc. April 1, 2012