Privacy Policy of T Capital Partners

T Capital Partners aims to increase our corporate value continuously by placing trust from our funds’ investors and potential investors (the “customers”) as the foundation of all of our business activities. Guided by this philosophy, we comply with the Act on the Protection of Personal Information (the "Personal Information Protection Act"), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the "My Number Act") and other relevant laws and regulations, the applicable Personal Information Protection Guidelines in handling personal information as well as personal numbers and specific personal information (personal numbers and specific personal information shall hereinafter be called “Specific Personal Information, etc.”) and anonymously processed information in a proper manner as described below and take appropriate measures for the safety management thereof. We are committed to making every effort to train and educate those engaged in our business so as to ensure the proper handling of personal information and Specific Personal Information, etc. and anonymously processed information. We will also perform reviews as needed in order to improve the following statements as required.

*In this Privacy Policy, “personal information” and “personal data” mean personal information or data of customers and do not include specific personal information, etc.** Terms “personal information”, “personal numbers,” “specific personal information” and “anonymously processed information” are terms defined under the Personal Information Protection Act.

1. Acquisition of personal information of customers

(Please see Clause 6 below with respect to Specific Personal Information, etc.)

T Capital Partners collects personal information of customers in a lawful and appropriate manner to the extent necessary for conducting our business.

2. Purposes of use of personal information of customers

(Please see Clause 6 below with respect to Specific Personal Information, etc.)

T Capital Partners uses personal information of customers only to the extent necessary in order to perform the business activities listed below and for the purposes described in Clause 4 below (hereinafter “Purposes of Use”).

We shall define the Purposes of Use so that they are clear to our customers and announce them on our website. In addition, when we make any changes to the Purposes of Use, we will notify customers concerned or announce such changes on our website.

1. (1) Provision of information on, offering, management and implementation of paperwork for services related to fund management, such as investment advisory services, Type II financial instruments business, specially permitted business for qualified institutional investors and money lending business, etc.
2. (2) Responding to and otherwise handling inquiries and requests
3. (3) Other businesses incidental to (1) or (2) above or business conducted for smooth customer transactions and our business operations

When we handle personal information of customers beyond the extent necessary to achieve the Purposes of Use, we will obtain the consent of customers concerned, except in the cases described in each item of Paragraph 3, Article 16 of the Personal Information Protection Act.

3. Provision/Acquisition of personal data of customers to/from third parties

(Please see Clause 9 below with respect to Specific Personal Information, etc.)

1. (1) T Capital Partners will not provide personal data of customers to any third parties without obtaining prior consent of customers concerned, except in the following cases:
   • When required under laws and regulations
   • When providing information to an outsourcing contractor to the extent necessary to perform our business
2. (2) Unless otherwise prescribed by laws and regulations, when T Capital Partners provides personal data of customers to third parties, we will record matters concerning such provision (what type of personal data was provided to whom, etc.). When we obtain personal data of customers from third parties, we will check and record matters concerning such acquisition (what type of personal data was obtained from whom, how such third parties acquired the said data, etc.).

4. Handling of sensitive information

T Capital Partners will not collect, use, or provide to any third parties personal information requiring special care and information on labor union affiliation, family origin, domicile of origin, health care and sex life (except for information made available by the individual himself/herself, a government agency, a local public agency and persons stipulated in each item of Paragraph 1, Article 76 of the Personal Information Protection Act or in each item of Article 6 of the Ordinance for Enforcement of the Personal Information Protection Act, or information that is obvious from external appearance collected through visual observation or by taking a photograph of the individual. Hereinafter “Sensitive Information”) except as stipulated by the Personal Information Protection Act, other laws, regulations or guidelines.

5. Handling of Specific Personal Information, etc.

The use of Specific Personal Information, etc. is restricted by the My Number Act, and T Capital Partners will not collect or use such information beyond the prescribed purpose.We will not provide Specific Personal Information, etc. to any third parties except in cases permitted under the My Number Act.

6. Notification, disclosure/correction or suspension of use of personal data and Specific Personal Information, etc. retained based on the Personal Information Protection Act

Please direct a request for notification, disclosure/correction or suspension of use of personal data and Specific Personal Information, etc. held by us under the Personal Protection Information Act (hereinafter called a “Request for Disclosure, etc.”) to the contact office provided in Clause 10. (Contact Office) Contact”. We will confirm that the person making the request is the person concerned and ask the requester to fill out a form designated by us, and reply in writing in principle later. For Request for Disclosure, etc., there will be a fee charged by us.

7. Handling of anonymously processed information

1. (1) Creation of anonymously processed information

   When T Capital Partners creates anonymously processed information (information on an individual created from personal information by taking measures stipulated by laws and regulations so that a specific individual cannot be identified, and for which certain measures are taken to prevent the restoration of the personal information), we shall take the following measures:

   1. Appropriately process information based on standards stipulated by laws and regulations
   2. Take safety management measures based on standards stipulated by laws and regulations to prevent the leakage of deleted information or information on how the data was processed
   3. Publicly announce categories of information included in anonymously processed information that has been created
   4. Refrain from taking any action that will identify the individual of the personal information which was the source of creation of anonymously processed information
2. (2) Provision of anonymously processed information

   When providing anonymously processed information to third parties, we shall disclose to the public the categories of information concerning an individual contained in the anonymously processed information to be provided and the method of provision, and explicitly specify to such parties that the information to be provided is anonymously processed information.

8. Management of personal data and Specific Personal Information, etc.

T Capital Partners appoints a person in charge of information management and takes sufficient security measures to prevent the leakage, loss or damage of personal data and Specific Personal Information, etc. and to implement the safety management of such data and information. We will also work to ensure the accuracy and currentness of personal data required to achieve the Purposes of Use. When we outsource the handling of personal data and specific personal information, etc. to a contractor, we shall properly supervise such contractor.

9. Contact

T Capital Partners will appropriately and promptly respond to any complaints or consultations regarding the handling of personal information, Specific Personal Information, etc. and anonymously processed information. For an inquiry or question concerning the handling of, and our safety management measures for, personal information, Specific Personal Information, etc. and anonymously processed information, please contact us at the following.