Personal Information Protection Policy (Privacy Policy)

1．Basic Policy on the Protection of Personal Information

The Investment Corporation fully recognizes the importance of protecting Personal Information and will comply with the Personal Information Protection Act, other laws and regulations relating to the protection of Personal Information, and guidelines and other rules issued by the competent authorities. The Investment Corporation will not use Personal Information for purposes other than those specified, will appropriately address complaints and other matters concerning Personal Information, and will endeavor to handle and protect Personal Information properly.

In handling Personal Information, the Investment Corporation will comply with the following:

1. It will not acquire Personal Information through deception or other improper means.
2. Except as permitted by applicable laws and regulations, it will not acquire Special Care-Required Personal Information without obtaining the prior consent of the relevant individual.
3. Except as permitted by applicable laws and regulations, it will not handle acquired Personal Information beyond the scope necessary to achieve the Purpose of Use specified in advance without obtaining the consent of the relevant individual.
4. Except as permitted by applicable laws and regulations, it will not provide acquired Personal Data to any third party without obtaining the prior consent of the relevant individual.
5. It will endeavor to keep acquired Personal Data accurate and up to date to the extent necessary to achieve the Purpose of Use and to delete such Personal Data without delay when its use is no longer necessary.
6. It will implement necessary and appropriate measures to prevent the leakage, loss or damage of acquired Personal Data and otherwise ensure its secure management.
7. It will not use Personal Information in a manner that may facilitate or induce unlawful or improper conduct.

2．Acquisition of Personal Information

When acquiring Personal Information, the Investment Corporation will do so by lawful and proper means and only to the extent necessary to achieve the Purposes of Use set forth in Section 3 below. Before acquiring Personal Information, the Investment Corporation will publicly announce the applicable Purpose of Use on its website or by other means. When Personal Information is provided directly by the relevant individual in writing, through a website interface or by other similar means, the Investment Corporation will specify the Purpose of Use in advance.
However, the Investment Corporation may omit such specification where the Purpose of Use is evident from the circumstances of the acquisition or where otherwise permitted by applicable laws and regulations.

3．Purposes of Use of Personal Information

Except where the relevant individual has given prior consent or where otherwise permitted by applicable laws and regulations, the Investment Corporation will handle Personal Information only to the extent necessary to achieve the following Purposes of Use.
If the Investment Corporation changes any Purpose of Use, it will promptly announce the details of the change on its website or by other means.

1. To exercise rights and perform obligations under the Act on Investment Trusts and Investment Corporations (the “Investment Trust Act”) and other laws, regulations and rules applicable to the Investment Corporation.
2. To conduct operations relating to the acquisition or disposition of investment assets by the Investment Corporation and other operations carried out under the Investment Trust Act, including financing activities, as well as related information gathering, investigations, analyses and reviews, including identity verification, credit checks and investigations of legal rights and interests.
3. To provide Unitholders of the Investment Corporation (“Unitholders”) with information concerning the operation and management of the Investment Corporation.
4. To perform operations relating to the exercise of rights by Unitholders and the performance of obligations by the Investment Corporation under applicable laws, regulations and rules, including the delivery of asset management reports, notices of convocation of general meetings of Unitholders and notices of distribution payments, and otherwise to respond to Unitholders.
5. To manage information concerning Unitholders using data contained in the register of Unitholders and other records prepared pursuant to the Investment Trust Act and other laws, regulations and rules applicable to the Investment Corporation.
6. To prepare and submit filings, reports and other documents of the Investment Corporation or the Asset Managers under the Investment Trust Act, the Financial Instruments and Exchange Act and other applicable laws, regulations and rules. For purposes of this policy, JAMP Fund Management Co., Ltd., to which the Investment Corporation has entrusted the management of its assets, and HiJoJo Partners Inc., to which JAMP Fund Management Co., Ltd. has sub-delegated all authority relating to the management of such assets, are collectively referred to as the “Asset Managers.”
7. To respond to inquiries concerning the Investment Corporation and requests for materials or information.
8. To carry out operations relating to the issuance of Investment Units, investment corporation bonds and investment unit acquisition rights, borrowings and other financing activities, and investor relations activities.
9. To conduct financial closing procedures and other accounting and tax-related operations of the Investment Corporation.
10. To implement measures intended to facilitate smooth relations between Unitholders and the Investment Corporation.
11. To appropriately and efficiently perform general administrative operations and other related operations of the Investment Corporation.
12. To perform operations incidental or related to any of the foregoing Purposes of Use.

Notwithstanding the foregoing, Specific Personal Information will be handled only where necessary for procedures involving Individual Numbers as prescribed by the My Number Act, other related administrative procedures, or other purposes permitted by applicable laws and regulations.

4．Provision of Personal Data to Third Parties

The Investment Corporation will not provide Personal Data held by it to any third party without obtaining the prior written consent of the relevant individual, including consent by electromagnetic record, except in any of the following cases:

1. Where required by applicable laws and regulations.
2. Where provision is necessary to protect the life, body or property of a person and it is difficult to obtain the consent of the relevant individual.
3. Where provision is particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the consent of the relevant individual.
4. Where it is necessary to cooperate with a national government agency, local public body or a person entrusted by either of them in performing duties prescribed by applicable laws and regulations, and obtaining the consent of the relevant individual may impede the performance of those duties.
5. Where Personal Data is provided to a university or another institution or organization established for academic research purposes, or to a person affiliated with such an institution or organization (collectively, an “Academic Research Institution, etc.”), and the Academic Research Institution, etc. needs to handle the Personal Data for academic research purposes, including where academic research is only one of the purposes for which the Personal Data is handled, except where such handling may unjustly infringe the rights or interests of an individual.

Notwithstanding the foregoing, Specific Personal Information collected, used or retained under the My Number Act will not be provided to any third party, regardless of whether the relevant individual has given consent, except where permitted by applicable laws and regulations.

5．Proper Management of Personal Information

The Investment Corporation will endeavor to keep acquired Personal Information as accurate and up to date as reasonably possible and will implement necessary and appropriate measures to prevent leakage, loss, damage, destruction, misuse, alteration or other incidents involving Personal Information and otherwise ensure its proper and secure management. The Investment Corporation may outsource all or part of the handling of acquired Personal Information to the extent necessary to achieve the applicable Purpose of Use. In such cases, the Investment Corporation will exercise due care in selecting the relevant service provider and will conduct necessary and appropriate supervision of that service provider, including endeavoring to require the service provider to implement strict Security Control Measures to prevent leakage, loss, damage, destruction, misuse, alteration or other incidents involving Personal Information.

6．Security Control Measures

The Investment Corporation has entrusted asset management and related operations to the Asset Managers and requires the Asset Managers to implement necessary and appropriate Security Control Measures and properly manage Personal Data. The Asset Managers have implemented the following measures:

1. Establishment of a Basic Policy
   The Asset Managers have established a personal information protection policy to ensure that the proper handling of Personal Data is addressed on an organizational basis.
2. Establishment of Rules for the Handling of Personal Data
   The Asset Managers have established rules governing the handling of Personal Data, including handling procedures and the persons responsible for such handling.
3. Organizational Security Control Measures
   The Asset Managers have appointed persons responsible for the handling of Personal Data and clearly defined their responsibilities. Personal Data is handled in accordance with the applicable rules. The persons responsible inspect the status of handling and confirm that a reporting and communication system is in place for reporting leakage and other incidents.
4. Personnel Security Control Measures
   The Asset Managers regularly provide officers and employees with training and other instruction regarding matters requiring attention in the handling of Personal Data.
5. Physical Security Control Measures
   In areas where Personal Data is handled, the Asset Managers control the entry and exit of officers and employees and restrict devices and other items that may be brought into those areas. The Asset Managers also implement measures to prevent the theft of devices, electronic media and other items used to handle Personal Data and protect Personal Data through encryption, passwords and other means. In addition, the Asset Managers have established systems to ensure that Personal Data is appropriately processed when it is deleted or when devices, electronic media or other items are disposed of, including by using methods that make restoration difficult.
6. Technical Security Control Measures
   The Asset Managers apply appropriate access controls to information systems used to handle Personal Data and identify officers and employees who use those systems through user IDs and passwords. The Asset Managers also confirm that appropriate security measures against unauthorized access and information leakage are applied to those information systems.

7．Requests for Notification of Purposes of Use and Requests for Disclosure, etc. of Retained Personal Data

When the relevant individual makes a request concerning Retained Personal Data, the Investment Corporation will verify the identity of the requesting individual in accordance with its prescribed procedures and will accept requests, as provided by applicable laws and regulations, for notification of the applicable Purpose of Use, Disclosure (including Disclosure by providing an electromagnetic record or by other means), Correction, Addition, Deletion, Suspension of Use, Erasure, or Cessation of Provision to Third Parties (collectively, “Disclosure, etc.”).

To request notification of the Purpose of Use of Retained Personal Data or Disclosure, etc., please contact the inquiry points listed in Section 8 below. No fee will be charged for a request for Disclosure, etc. The same procedures apply to requests for Disclosure of records relating to the provision or receipt of Personal Data by or from third parties.

8．Contact Information

(1) For questions or complaints concerning the handling of Personal Information, or requests for notification of the Purpose of Use of Retained Personal Data or Disclosure, etc., please contact either of the following. Information concerning the required procedures will be provided.

(2) Inquiries concerning matters recorded in the register of Unitholders should be directed to the following Administrator of the Register of Unitholders of the Investment Corporation:

9．Continuous Improvement of the Personal Information Protection Framework

In addition to reviewing this Personal Information Protection Policy in response to amendments to applicable laws and regulations, the Investment Corporation will review it as necessary and endeavor to strengthen and improve its initiatives for the protection of Personal Information.