J-STAR Corporation (hereinafter referred to as “The Company”) has established the following privacy policy as our policy regarding personal information and personal numbers (hereinafter referred to as “Personal Information, etc.”) of our customers, and will comply with it and take all possible measures to protect Personal Information, etc.

The Company complies with the provisions in the privacy laws and regulations, including the “Act on the Protection of Personal Information” (hereinafter, “Personal Information Protection Act)”, the “Act on the Use of Numbers to identify a Specific Individual in Administrative Procedures “(hereinafter, “Personal Number Act”), and other laws, regulations, and ordinances of the competent minister. Other laws, regulations, guidelines of competent ministers, and guidelines of authorized personal information protection organizations. The Company will take all possible measures to properly handle Personal Information in accordance with this Privacy Policy.

We will not acquire personal information by illegal means and will acquire Personal Information in a lawful and fair manner to the extent necessary for the performance of our business. When obtaining personal information, etc. from third parties, we will not unreasonably infringe on the interests of the person concerned.

We will use Personal Information obtained in the course of our business within the scope necessary for the following operations and purposes of use. We will not use Personal Information for any other purposes, except for the cases described in section 4 below, such as when required by law.

(1) Scope of Business

a. Investment advisory services pursuant to Article 28, Paragraph 6 of the Financial Instruments and Exchange Act and related services

b. Specially Permitted Services for qualified institutional investors (operation and management of investment funds) under Article 63 of the Financial Instruments and Exchange Act and other related business

c. Other business that we may engage in pursuant to laws and regulations, as well as business incidental to such business (including new business that we will be permitted in the future).

(2) Purpose

a. To perform administrative work related to the provision of investment advisory services.

b. To solicit and explain investment partnerships or investment limited partnerships, etc. (hereinafter referred to as “investment fund”), and to make various proposals for related services.

c. To confirm the identity of an investor in an investment fund or the identity of an agent of the investor

d. To perform administrative work related to the structuring and management of investment funds and post transaction management.

e. To identify prospective companies for investment and to consider and decide whether to invest in them.

f. To provide information on, implement, and perform administrative work related to services provided by the Company and external support companies in order to enhance the value of portfolio companies.

g. To exercise rights and fulfill obligations pursuant to contracts with customers, laws and regulations, etc.

h. To provide necessary information, such as the receipt and delivery of various types of requests for information materials and information on seminars, etc. sponsored by the Company.

i. For recruiting and employment management

j. For appropriate and smooth performance of other transactions with customers

We will not use Personal Information beyond the scope of the purposes of use described in 3.2(2) above, except in the following cases.

(1) Prior consent of the identifiable person.

(2) Cases based on laws and regulations.

(3) Cases in which there is a need to protect the life, wellbeing, or property of an individual, and it is difficult to obtain the consent of the identifiable person.

(4) Cases in which there is a special need to improve public wellbeing or promote healthy child development, and it is difficult to obtain the consent of the identifiable person.

(5) Cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations, and obtaining the consent of the identifiable person is likely to interfere with the performance of those functions.

(6) Cases in which personal data is provided to an academic research institution or the equivalent, and they need to handle the personal data for academic research purposes (including cases in which a part of the purpose of handling the personal data is for academic research purposes, and excluding cases in which there is a risk of unjustly infringing on individual rights and interests)

We will not use the personal numbers (specified Personal Information) of our customers and employees obtained by us for any purposes beyond those stipulated in Article 9 of the Personal Number Act. If personal numbers are acquired from another business due to a merger or other reasons, the Company will not use personal numbers beyond the scope of the purposes of use before the merger or succession.

Upon acquisition of Personal Information, etc., the Company will promptly notify the person of the purpose of use or publicly announce the purpose of use, except in cases where the purpose of use has been publicly announced in advance. In addition, when obtaining Personal Information from a person in a contract or other written document in connection with the conclusion of a contract, etc., the Company will clearly state the purpose of use in advance.

We will not acquire, use, or provide to third parties “Sensitive Information” except in the following cases. Sensitive information” is defined as “Personal Information that requires special consideration (race, creed, social status, medical history, criminal record, fact that a person has been harmed by a crime, or other information that requires special consideration in handling so as not to cause unjust discrimination, prejudice, or other disadvantage to the person) as defined in Article 2, Paragraph 3 of the Personal Information Protection Act and information concerning membership in labor unions, family origin, legal domicile, healthcare, and sex life

(1) Cases based on laws and regulations

(2) Cases in which there is a need to protect the life, wellbeing, or property of an individual

(3) Cases in which there is a special need to improve public wellbeing or promote healthy child development

(4) Cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations

(5) Cases of acquiring sensitive information in the cases listed in Article 20, Paragraph 2, Item 6 of the Personal Information Protection Act, cases of using sensitive information in the cases listed in Article 18, Paragraph 3, Item 6 of the Personal Information Protection Act, or cases providing sensitive information to a third party in the cases listed in Article 27, Paragraph 1, Item 7 of the Personal Information Protection Act.

(6) Cases in which the Company acquires, uses or provides to a third-party Sensitive Information of employees, etc. concerning their membership or affiliation with political, religious or other organizations or labor unions, to the extent necessary for the performance of Withholding procedures.

(7) Cases acquiring, using, or providing to a third-party Sensitive Information to the extent necessary for the performance of transferring rights and obligations through inheritance procedures.

(8)  Cases in which the Company acquires, uses, or provides to a third-party Sensitive Information to the extent necessary for the performance of its business operations based on the consent of the individual to whom the Sensitive Information pertains, out of necessity to ensure the proper operation of its business

(9) Cases in which biometric authentication information that falls under the category of sensitive information is used to verify the identity of an individual based on the consent of the individual.

We will endeavor to keep personal data accurate and up to date to the extent necessary to achieve the purpose of use. When personal data in our possession is no longer needed, we will endeavor to erase it without delay, except in cases where a retention period is stipulated by law or regulations.

The Measures we take for the safe management of personal data are as follows.

(1) In order to prevent loss, leakage, loss, damage, etc. of personal data, the Company shall implement necessary safety control measures in accordance with the risks and take appropriate information security measures such as measures against unauthorized access and computer viruses.

(2) When outsourcing all or part of the handling of personal data, the Company shall establish selection criteria and select an outsourcing partner to ensure the safe management of personal data, conclude a contract that includes security requirements, and provide necessary and appropriate supervision to the outsourcing partner.

(3) We will ensure that our officers and employees are aware of the importance of personal data protection and provide necessary and appropriate education and supervision.

We will not disclose or provide personal data (excluding personal numbers) obtained without the prior consent of the individual to any third party, except in the following cases.

(1) Cases based on laws and regulations.

(2) Cases in which there is a need to protect the life, wellbeing, or property of an individual, and it is difficult to obtain the consent of the identifiable person.

(3) Cases in which there is a special need to improve public wellbeing or promote healthy child development, and it is difficult to obtain the consent of the identifiable person.

(4) Cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations, and obtaining the consent of the identifiable person is likely to interfere with the performance of those functions.

(5) Cases in which personal data is provided to an academic research institution or the equivalent, and they need to handle the personal data for academic research purposes (including cases in which a part of the purpose of handling the personal data is for academic research purposes, and excluding cases in which there is a risk of unjustly infringing on individual rights and interests

We will not provide Personal Number to third parties, except as stipulated by the Personal Number Act.

We may share personal data (excluding personal numbers) with third parties within the scope of the purposes of use as follows.

(1) Items of Personal Data to be shared.

a. Information about customers such as name, address, date of birth, telephone number and other contact information, occupation, transaction needs, etc.

b. Information related to customer transactions, such as transaction details, transaction balances, etc.

(2) Scope of Joint Users

a. The Company

b. Partners of Investment Funds in which the Company is involved.

c. External support companies such as securities firms that work with the Company to support the enhancement of the value of portfolio companies.

(3) Purposes of use by the Joint Users

Same as our company’s purpose of use described in 3.(2) above

(4) Party responsible for the management of such personal data

J-STAR Corporation

Rokuro Hara, Representative Director

Dai-ichi Life Hibiya First 18F

1-13-2 Yurakucho, Chiyoda-ku, Tokyo Japan 100-0006

Requests for notification of purpose of use, disclosure, correction, addition or deletion, suspension of use or elimination, suspension of provision to a third party, or disclosure of records of provision to a third party (hereinafter referred to as “disclosure, etc.”) by customers regarding retained personal data under the Personal Information Protection Act shall be handled as follows. Please find our Contact information listed in section 14 below.

(1) Procedure for disclosure request

Please contact us listed 14 below, indicating the items of retained personal data subject to the request and the category of the request. When making a request, please present or attach a copy of the following documents, as we will confirm that the person making the request is the true holder or the agent of the true holder of the information requested.

a. In case of self-request

Personal number card, driver’s license, passport, or health insurance card and resident certificate

b. In case of agent

A copy of the identification document described in a. above.

A letter or attorney attesting that the applicant is the agent of the principal person.
(the letter of attorney must bear the principal person’s seal) and a certificate of seal impression of the principal.

Identity verification documents as described in a. above for the agent.

(2) Method of response

We will respond without delay by any of the following requested methods: mailing a written document to the address provided by the person in question, handing it over at our storefront, or saving an electromagnetic record on a medium and sending the medium by mail. In cases where disclosure by such methods requires a large amount of money or it is difficult to disclose by such methods, we will respond by delivering a written document by mail.

(3) Fee

There is no charge for this service, in principle. However, please note that there may be cases in which a fee will be charged in consideration of actual costs.

(4) Purpose of Use of Personal Information Obtained in Disclosure

Personal information obtained in connection with the Procedure for Requesting Disclosure, etc. will be used for the purpose of investigation, identification of the person in question and his/her agent, collection of fees (only when fees are charged), and response to such Request for Disclosure, etc.

(5) Cases in which disclosure, etc. cannot be made

Please note that we will not be able to disclose the information in the following cases. If we decide not to disclose the information, we will notify you to that effect with the reason.

a. When the identity of the customer cannot be confirmed.

b. When we are unable to confirm the authority of representation of an agent

c. When there is a deficiency in the required documents such as the details of the request

d. If the requested disclosure item does not fall under the category of retained personal data.

e. If there is a risk of harm to the life, body, property, or other rights or interests of the customer or a third party.

f. If there is a risk of causing significant hindrance to the proper conduct of our business.

g. If it would violate other laws and regulations.

We will endeavor to respond sincerely and promptly to inquiries and complaints regarding the handling of Personal Information, etc. Please contact the following for inquiries and consultations regarding the Company’s handling of Personal Information, etc. and retained personal data.

J-STAR Corporation
Compliance Officer
Address	Dai-ichi Life Hibiya First 18F, 1-13-2 Yurakucho, Chiyoda-ku, Tokyo Japan 100-0006
Telephone	03-6269-9701
FAX	03-6269-9710
Hours	Monday to Friday: 9 a.m. to 5:30 p.m. Excl. National Holidays, Dec.29 to Jan.3

The Company is a member of the Japan Investment Advisers Association (JIAA), which is certified by the Personal Information Protection Commission as an Accredited Personal Information Protection Organization. JIAA established a help desk to offer consultation with regard to complaints has been engaged in various activities which help protect Personal Information.

Japan Investment Advisers Association Help Desk

Address;  1-5-8 Nihonbashi-Kayabacho, Chuo-ku, Tokyo 103-0025

(7^th Floor of Tokyo Shoken Kaikan)

Phone;  81-3-3663-0505     FAX:　03-366-0510

Hours:　Monday to Friday (excl. National Holiday) 9 a.m. to 5 p.m.