Personal Data Handling Agreement

Agreement for Management of Personal Information

SPARX Investment co., Ltd.(the "Company") will manage the personal information listed and entered on this enquiry form, in line with the details described below. Please confirm all the below items, and if in agreement check the [Agree] box and click on Review.

Management of Personal Information

• We will acquire personal information in accordance with laws and regulations and strive to keep the acquired information accurate and up-to-date.
• Personal information shall not be used beyond the scope of the purpose of use without consent from the individual or otherwise permitted by laws and regulations. In addition, we will not disclose or provide personal information to third parties without consent from the individual unless there are justifiable grounds such as legal obligations to disclose personal information.
• We will thoroughly educate our officers and employees in order to prevent leaks and unauthorized use of personal information. In addition, we will appoint a responsible person in charge of management and inspections, and establish an appropriate management system.
• In the event that personal information is handled by an outside agency, we will be responsible for supervising the outside agency to make sure that the protection of personal information is ensured.
• We will disclose, correct and suspend the use of personal information upon request from the individual in accordance with laws and regulations. In this case, we may charge a prescribed fee.
• To ensure the proper handling of personal information, we will review this policy as appropriate and make continuous improvements.

Purpose of use of Personal Information

We will obtain or use personal information for the following purposes in the course of implementing the Specially Permitted Businesses for Qualified Institutional Investors and business activities incidental thereto and subsidiary business, the buying and selling, leasing, management, intermediacy, operation and other business transactions related to land and buildings, as well as business that we may conduct under laws and regulations, and business activities incidental thereto. The Individual Number, in particular, will only be used in accordance with relevant laws and regulations.

• To solicit or sell the products and services of the Company, as well as providing information about services related to them.
• To introduce the group companies of the Company (the parent company of the Company and consolidated subsidiaries stated in its annual securities report thereof) to customers.
• To determine the appropriateness of providing products and services in light of the principle of suitability and other factors.
• To confirm the identity of a customer or a customer's representative.
• To report to a customer the status of management activities, and the like.
• To carry out administrative tasks related to a transaction with a customer or a party to a transaction.
• To execute rights or fulfill duties based on a contract with a customer or laws and regulations.
• To research or develop financial products or services by implementing market research, data analysis, questionnaires, and the like.
• To appropriately execute entrusted businesses when, for example, the Company is entrusted with processing all or part of Personal Information, Etc. and the like from another business entity or similar party.
• Other matters in order to appropriately and smoothly fulfill transactions with a customer or a party to a transaction.
• To carry out the Company's business management or internal controls.
• Personal Information, Etc. related to the Company's officers, employees, and the like shall be used for employment management, for executing businesses based on each relevant law and regulation, and for promoting business activities.

Provision of personal data to third parties

The Company shall not provide the personal data of an individual to any third parties, except in the following cases:

• when the individual agrees to such provision;
• when the Company delegates any business externally, within the scope necessary to achieve the purposes of use; or
• when there is otherwise a basis in laws and regulations, etc. to do so.

If the Company delegates the handling of personal data to an outside service provider (processor), the Company will conduct the necessary and appropriate supervision over such outside service provider (processor) to ensure the security control of such personal data.

Provision of personal data to third parties in foreign countries

The Company may provide personal data to a third party in a foreign country for the purpose stated above. In such case, the Company will provide personal data to a third party in a foreign country on the grounds that such third party has established a system recognized to have equivalent standards to those prescribed in the Enforcement Rules for the Act on the Protection of Personal Information as a system necessary for continuously taking action equivalent to the one that a personal information handling business operator shall take in accordance with the provisions of Chapter 4, Section 2 of the Personal Information Protection Act regarding the handling of personal data, except when the Company provides personal data to a third party in a foreign country which has established a personal information protection system recognized to have equivalent standards to that in Japan in regard to the protection of an individual's rights and interests. For customers who wish to be provided with information relating to the foregoing, please contact the consultation desks for Personal Information, Etc. below.

Joint use

The Company may jointly use personal data with its group companies in order to jointly execute the businesses that the Company is permitted to engage in and any businesses incidental thereto.

1. Items of personal data to be jointly used

   In addition to names, addresses, dates of birth, and telephone numbers, information related to customers such as transaction needs shall be jointly used, but the Company will limit the items of personal data to the minimum extent necessary.

2. Scope of joint users

   SPARX Group Co., Ltd., which is the holding company of the Company, and its consolidated subsidiaries stated in its annual securities report.

3. Purpose of use
   • To solicit or sell the products and services of the Company such as securities, investment advisor contracts, and discretionary investment contracts under the Financial Instruments and Exchange Act, or to introduce services related thereto.
   • To introduce the group companies of the Company to customers.
   • To determine the appropriateness of providing products and services in light of the principle of suitability and other factors.
   • To confirm the identity of a customer or a customer's representative.
   • To report to a customer the results of a transaction, the balance of an account, the status of management activities, and the like.
   • To execute rights or fulfill duties based on a contract with a customer or laws and regulations.
   • To research or develop financial products or services by implementing market research, data analysis, questionnaires, and the like.
   • To appropriately and smoothly fulfill transactions with a customer or a party to a transaction.
   • To manage compliance risks and carry out other business management and internal controls of the group companies of the Company.
   • Personal Information, Etc. related to the Company's officers, employees, and the like shall be used for employment management, for executing businesses based on each relevant law and regulation, and for promoting business activities.
4. Person responsible for the management of such personal data

   SPARX Group Co., Ltd.
   President：Shuhei Abe
   Address：Shinagawa Season Terrace 6F, 1-2-70 Konan, Minato-ku, Tokyo 108-0075 JAPAN

Security control measures

The Company takes appropriate measures at all times to keep the personal data of each individual accurate and up-to-date. In addition, the Company will take the following security control measures in accordance with laws and regulations.

• Formulation of basic policies: to ensure the proper handling of personal information, the Company will form basic policies regarding "compliance with related laws, regulations, guidelines, and the like," a "desk for handling questions and complaints," and the like.
• Preparation of regulations related to the handling of personal information : For each step of acquiring, using, storing, providing, deleting, disposing, and the like of personal information, the Company will form handling regulations for personal information regarding handling methods, persons responsible, persons in charge, the duties of such persons, and the like.
• Organizational security control measures: The Company will assign persons responsible for the handling of personal information and clarify the employees who will handle personal information and the scope of the personal information such employees will handle, and prepare a reporting and communicating system to the persons responsible if any fact or indication of a violation of any laws or handling regulations is ascertained.
• Human security control measures: The Company will conduct regular training for employees for important matters regarding the handling of personal information.
• Physical security control measures: In areas where personal information will be handled, the Company will manage the employees' access of rooms and limit devices and the like that could be brought into those rooms, and take measures to prevent persons who do not have the authority to do so from accessing personal information. The Company will take measures to prevent the theft, loss, and the like of devices, electronic media, documents, and the like which process or deal with personal information and take measures so that personal information cannot be easily identified when carrying such devices, electronic media, and the like (including moving the foregoing inside the office).
• Technical security control measures: The Company will limit the number of persons in charge and the scope of personal information databases, etc. to be handled by implementing access controls. In addition, the Company will introduce mechanisms to protect information systems that handle personal information from external unauthorized access and unauthorized software.

Handling of Specific Personal Information

The purposes of use of Specific Personal Information, Etc. is restricted by the Individual Number Act, and the Company will not acquire nor use Specific Personal Information, Etc. beyond those purposes.
The Company will not provide any Specific Personal Information, Etc. to any third party unless such provision is permitted under the Individual Number Act.

Procedures for responding to requests for disclosure, etc.

Regarding a notice of the Purpose of Use, disclosure, correction, addition or deletion of the contents, suspension of use, or suspension of provision to a third party of our retained Personal Data (hereinafter collectively referred to as a "Request for Disclosure, etc."), we shall accept and response to such requests for Disclosure, etc.in accordance with our prescribed procedures. For further details, please contact us at the link below.
https://www.sparxgroup.com/contact/

Contact information for Personal Information

For inquiries or complaints regarding the handling of personal information, etc., please contact the following.

Contact for personal information
SPARX Investment Co., Ltd.
Shinagawa Season Terrace 6F, 1-2-70 Konan,
Minato-ku, Tokyo 108-0075 JAPAN
Tel. +81-3-6711-9100
(Hours: 9:00 to 17:00 JST weekday only)

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