The following is an English translation of the original Japanese version.
If there is any inconsistency between the two versions, the Japanese version shall prevail.

SPARX Privacy Policy

SPARX Asset Management Co., Ltd. (the "Company") complies with the Act on the Protection of Personal Information ("Personal Information Protection Act"), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures ("Individual Number Act"), and other related laws and regulations, as well as guidelines issued by relevant government agencies, regarding personal information, individual numbers, and specific personal information ("Specific Personal Information, Etc."; personal information and Specific Personal Information, Etc. are collectively referred to as "Personal Information, Etc."). The Company has established regulations and the like for the protection of personal information and has formulated the following "Privacy Policy."

Management of Personal Information

• The Company will acquire Personal Information, Etc. in accordance with laws and regulations and strive to keep the acquired information accurate and up-to-date.
• The Company shall not use Personal Information, Etc. beyond the scope of its purpose of use. In addition, the Company will not disclose or provide personal information to third parties without consent from the relevant individual, unless there are justifiable grounds to do so such as a legal obligation to disclose personal information.
• The Company will thoroughly educate its officers and employees in order to prevent leaks and unauthorized use of Personal Information, Etc. In addition, the Company will appoint a person in charge of Personal Information, Etc. management and inspections, and establish an appropriate management system therefor.
• In the event that Personal Information, Etc. is handled by an outside service provider (processor), the Company will be responsible for supervising the outside service provider (processor) to make sure that the protection of Personal Information, Etc. is ensured.
• The Company will disclose, correct, and suspend the use of Personal Information, Etc. upon request from the relevant individual in accordance with laws and regulations. In such case, the Company may charge a prescribed fee.
• To ensure the proper handling of Personal Information, Etc., the Company will review this Policy as appropriate and continuously make improvements to the content herein.

Sources of Personal Information

The Company will mainly obtain Personal Information, Etc. though executed agreements, applications pertaining to opening accounts, applications for lecture sessions, examinations of investment candidates, business cards, and the like.

Purpose of use of Personal Information

The Company obtains and uses Personal Information, Etc. for the following purposes when executing investment management, investment advising and agency services, type I financial instruments businesses, type II financial instruments businesses and any businesses incidental thereto, concurrent businesses, and other businesses that the Company is legally permitted to engage in and any businesses incidental thereto. The Company will handle individual numbers only within the scope prescribed in laws and regulations.

• 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 (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 results of a transaction, the balance of an account, 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. (including conducting due diligence and monitoring after investment)
• 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.

• 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.
• 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.
• Purpose of use
  • (1) 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.
  • (2) To introduce the group companies of the Company to customers.
  • (3) To determine the appropriateness of providing products and services in light of the principle of suitability and other factors.
  • (4) To confirm the identity of a customer or a customer's representative.
  • (5) To report to a customer the results of a transaction, the balance of an account, the status of management activities, and the like.
  • (6) To execute rights or fulfill duties based on a contract with a customer or laws and regulations.
  • (7) To research or develop financial products or services by implementing market research, data analysis, questionnaires, and the like.
  • (8) To appropriately and smoothly fulfill transactions with a customer or a party to a transaction.
  • (9) To manage compliance risks and carry out other business management and internal controls of the group companies of the Company.
  • (10) 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.
• Person responsible for the management of such personal data
  SPARX Group Co., Ltd. (Please click here for information on the relevant representative and address.)

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.
• Ascertaining the external environment: The Company handles personal information in the United States. The Company will take security control measures after ascertaining the systems regarding the protection of personal information in the country above.

Recording telephone call content

The Company will record the calls between its officers or employees and its customers by using the Company call recording system. In addition, some of the calls with customers made via mobile phones which the Company provides to its officers and employees will be recorded using the KDDI call recording service.

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

If there is any request in respect of the retained personal data of the Company regarding (1) notification of, disclosure of, or correction, addition, or deletion of the contents of the purpose of use, (2) suspension of use, (3) deletion, or (4) suspension of provision to a third party (collectively, "Request for Disclosure, Etc."), the Company shall accept and respond to such Requests for Disclosure, Etc. in accordance with its prescribed request procedures.

For further details, please contact us at the link below.
https://www.sparxgroup.com/contact/

Consultation desks for Personal Information

For inquiries, complaints, or the like regarding the handling of Personal Information, Etc., please contact the following consultation desk.
Administration Department
SPARX Asset Management Co., Ltd.

Shinagawa Season Terrace, 1-2-70 Konan,
Minato-ku, Tokyo 108-0075
Tel. +81-3-6711-9140
(Hours: 9:00 to 17:00 except on weekends and holidays)

Contact information of accredited personal information protection organizations