Personal Information Protection Policy

As a company engaged in investment partnership management business, Polaris Capital Group Co., Ltd. (hereinafter referred to as the “Company”) may acquire, use and manage personal information.
In so doing, the Company believes that it has a social responsibility to comply with laws, regulations and guidelines such as the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"), protect personal information and handle personal information by respecting the wishes of the person concerned as much as possible, and thus has formulated the following personal information protection policy (hereinafter referred to as this "Policy") and handles personal information properly in accordance with this Policy. The meanings of the terms used in this Policy shall be in accordance with the Personal Information Protection Act.

1.Protection of Personal Information

  • The Company shall comply with laws, regulations, and guidelines such as the Personal Information Protection Act.
  • The Company shall always be keenly aware that there are risks such as unauthorized access to or leakage of the personal information it holds and shall take appropriate measures for managing the security of personal information to prevent such risks.
  • The Company shall endeavor to continually improve the operation of this Policy and other internal rules, considering the revision of laws and regulations, changes in social conditions, and the results of audits.

2.Handling of Personal Information

  • Acquisition and Use of Personal Information

    The Company may acquire personal information such as names, addresses, and telephone numbers for business needs. The Company shall acquire personal information by appropriate means and, upon acquiring the information, promptly notify the person concerned of, or publicly announce, the purpose of use unless such purpose has already been publicly announced. If the Company acquires personal information directly from the person concerned in writing or otherwise, it shall expressly notify the purpose of use to the person concerned in advance.
  • Purpose of Use of Personal Information

    The Company shall use the personal information it has obtained for the following purposes.
    • Business related to the acquisition and holding of securities
      • To identify prospective investees
      • To consider investing in prospective investees
      • To perform services (including consulting) to be provided by the Company with the aim of improving the value of investees and to conduct related affairs
      • To implement the capital policy of investees and conduct related affairs
      • To exercise rights or perform obligations under laws and regulations or contracts, or conduct other affairs related to investment
      • In addition to the above, to provide information required by investees
    • Business concerning the management and administration of the property of investment business partnerships
      • To carry out affairs related to the formation and operation of investment business partnerships
      • To confirm that the person is in fact the investor of the investment business partnership or an agent of the investor
      • To provide necessary information to investors in an investment business partnership
    • To make decisions regarding recruitment at the Company
    • To manage employment at the Company
    • In addition to the above, to perform affairs necessary for the business of the Company and the Company's subsidiaries and affiliates appropriately and smoothly
  • Provision to Third Parties

    Except in the cases set forth in ① through ⑤ below, the Company shall not provide personal data (meaning personal information compiled in a personal information database or the equivalent; hereinafter the same applies) to any third party without obtaining the prior consent of the person concerned.
    • Personal data is handled in accordance with laws and regulations
    • It is necessary for the protection of the life, person, or property of an individual and it is difficult to obtain the consent of the person concerned
    • It is especially necessary to improve public health or promote the healthy development of children, and it is difficult to obtain the consent of the person concerned
    • It is necessary to cooperate with a national government body, local government or a person commissioned by either of the foregoing in executing the affairs prescribed by laws and regulations, and obtaining the consent of the person concerned is likely to impede the execution of such affairs
    • The third party is an academic research institution, etc. and the third party needs to handle personal data for academic purposes
    To facilitate business operations, the Company may provide personal data to outsourcees when outsourcing a part of its operations. In outsourcing operations to a third party, the Company shall select an outsourcee who can comply with this Policy and shall exercise necessary and appropriate supervision over the outsourcee.
  • Mesures for Managing the Security of Personal Information

    The Company shall formulate this Policy, develop internal rules concerning the handling of personal data, establish organizational frameworks, supervise employees and outsourcees, and take other necessary and appropriate measures for managing the security of personal data including preventing the leakage, loss or damage of the personal data it handles.
  • Procedures for Requesting Disclosure, etc.

    If you wish to request disclosure, correction, etc., or cessation of use in relation to the personal data the Company holds, please contact us at the following address. We will respond to your request to the extent permitted by the Personal Information Protection Act only if we conduct the necessary investigation from the viewpoint of preventing leakage and ensuring the accuracy of information and verify that the request was made by the person concerned.
  • Contact details for inquiries about the handling of personal information

    Polaris Capital Group Co., Ltd.
    GranTokyo North Tower 38F, 9-1, Marunouchi 1-chome, Chiyoda-ku, Tokyo 101-0061
    Phone: 03-5223-6780 (weekdays 9:00 ~ 17:00)

3.Procedure for Amending this Personal Information Protection Policy

The Company may amend this Personal Information Protection Policy. In such case, the amended version will be posted on the Company’s website(https://polaris-cg.com).

Established on February 1, 2024

GranTokyo North Tower 38F, 9-1, Marunouchi 1-chome, Chiyoda-ku, Tokyo 101-0061
Polaris Capital Group Co., Ltd.
President and CEO Yuji Kimura

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