Business Operator Handling Personal Information：Japan Growth Capital Investment Corporation
Representative：Executive Managing Officer Shinji Naito
Address：2-3-8 Hamamatsucho, Minato-ku, Tokyo 105-0013, Japan
Japan Growth Capital Investment Corporation (hereinafter “JGC”) complies with the Act on the Protection of Personal Information (Act No. 57 of 2003, including subsequent revisions), related laws, guidelines, and internal rules, etc. in the handling of personal information and endeavors to manage and handle personal information appropriately and safely.
The personal information that JGC obtains is primarily the personal information of the holders of securities issued by JGC and the business partners of JGC. JGC’s purposes of use of personal information are as follows:
| i. | To perform JGC’s obligations to the holders of securities issued by JGC. |
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| ⅱ. | To take steps to build relationships with the holders of securities issued by JGC. |
| ⅲ. | To prepare a unitholder register, a registry of investment corporation bonds and reports required under laws and regulations and manage information on holders of securities issued by JGC. |
| ⅳ. | To gather, compile statistics and analyze data to provide certain information to those considering purchasing securities issued by JGC when investment units or investment corporation bonds are issued or on other occasions. |
| ⅴ. | To gather and analyze data related to acquisitions of assets by JGC, research and examination related to the acquisitions, and solicitation of purchase and to facilitate selling. |
| ⅵ. | To request that lawyers, certified public accountants, and certified public tax accountants, among others, assist JGC in performing its duties. |
| ⅶ. | To borrow funds, issue investment corporation bonds and issue additional investment units in relation to JGC’s acquisitions of assets and asset management |
| ⅷ. | To facilitate the business of JGC appropriately. |
JGC shall use personal information within the scope necessary for achieving the purposes of use of personal information above and shall not use personal information for any purposes other than those stated above. JGC shall not change the purposes of use of personal information outside the scope where the purposes of use after the change are reasonably considered to be related to those before the change. Further, JGC shall not use personal information in a method that is likely to encourage or induce illegal or wrongful conduct.
i. Acquisition of Personal Information
Personal information shall be obtained by fair and lawful means within the scope necessary for achieving its purposes of use. JGC shall publish the purpose of use of personal information on its website or by other means before it obtains the personal information itself or from third parties. If JGC obtains the personal information stated in an agreement or other documents (including electromagnetic records (records created in electronic form, magnetic form, or any other form that cannot be perceived by the human senses); the same applies hereinafter) following the conclusion of the agreement or if JGC obtains personal information on a person directly from that person via other documents, it shall clearly specify the purpose of use of the personal information in advance. JGC may not clearly specify the purpose if the purpose is clear due to the circumstances at the time of the provision of the personal information or if the use of personal information is permitted by laws and regulations.
ⅱ. Acquisition of Sensitive Personal Information
JGC shall not, without your prior consent, obtain any of your sensitive personal information, except as permitted by laws and regulations.
i. Provision of Personal Data to a Third Party
JGC shall not provide personal data to a third party without your prior consent except as permitted by laws and regulations.
ⅱ. Provision of Sensitive Personal Information to a Third Party
JGC shall not provide sensitive personal information to a third party without your prior consent except as permitted by laws and regulations.
JGC shall endeavor to keep personal data accurate and up to date within the scope necessary for achieving the purpose of use of personal data. JGC shall also endeavor to delete personal data without delay if it does not need to use them anymore.
In accordance with the guidelines for the protection of personal information set forth by the Personal Information Protection Commission and/or Financial Services Agency, JGC shall take the following necessary and appropriate steps to manage personal data appropriately and safely and to prevent unauthorized access to personal data from the outside and the unauthorized use, loss, destruction, falsification, leakage, etc. of personal data.
| i. | Establishment of Regulations for the Handling of Personal Data Establish and comply with “Regulations on Personal Information Management” to ensure the proper handling of personal data. |
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| ⅱ. | Systematic Security Control Measures Appoint an information management officer and periodically inspect and audit the status of the handling of personal data. Based on the results of the inspection and audit, the information management officer evaluates, reviews, and improves security control measures. |
| ⅲ. | Human Security Control Measures Ensure that JGC’s directors are well informed of security control measures. |
| ⅳ. | Physical Security Control Measures Take measures to prevent theft or loss of personal data in areas where personal data is handled, and control access to and from the area. |
| ⅴ. | Technical Security Control Measures Install in the information systems handling personal data tools for the identification of, and protection against, unauthorized access from outside or the installation of unauthorized software. In addition, set access privileges as necessary. |
| ⅵ. | Monitoring the External Environment Personal data held by JGC is stored in Japan. When handling personal data in foreign countries, implement the necessary security control measures based on an understanding of the laws and regulations for the protection of personal data in the countries and regions where personal data is handled. |
JGC may outsource the handling of personal data that it holds. If JGC outsources all or part of the handling of personal data, it shall carefully select an outsourcing contractor and enter into an outsourcing agreement on the condition that the contractor has built a management system to protect personal data appropriately and protects personal data appropriately. JGC shall undertake the necessary and appropriate supervision to the contractor to ensure the safe management of personal data.
JGC shall formulate internal rules, including this Privacy Policy, and shall review them continually to improve them. JGC may revise this Privacy Policy in response to revisions to laws and regulations and for other reasons as needed.
You may request that JGC notify you of the purpose of use, disclose, correct, add to, delete, suspend the use of, or erase your personal data held by JGC or suspend the provision of the data to a third party by contacting the contact below. In that case, JGC will verify the identity of the requester (by requesting a copy of their driver’s license or by other means) and will then respond to the request within a reasonable period (In the case of a request from an agent, JGC will respond within a reasonable period of time after confirming that the person is an agent.).
Questions about this Privacy Policy are also accepted by the contact below.
For inquiries about personal information related to information stated in the unitholder registry, etc., please contact the following.
The Privacy Policy may be updated. Please check the last updated date.
(last updated date: November 28, 2024)
