Albacross Co., Ltd. (hereinafter referred to as “the Company”) considers the importance of protecting personal information, and all persons engaged in business recognize its responsibility, and the Law Concerning the Protection of Personal Information (hereinafter referred to as “the Company”). Comply with the “Personal Information Protection Law”), the Law Concerning the Use of Numbers for Identifying Specific Individuals in Administrative Procedures (hereinafter referred to as the “Number Law”) and other related laws and guidelines. We will properly handle personal information and personal numbers (hereinafter referred to as “personal information, etc.”) and take appropriate measures for safety management.

1. Acquisition of personal information, etc.
   We will eliminate the acquisition of personal information, etc. by fraudulent means, take sufficient safety management measures, and acquire personal information, etc. by legal and fair means to the extent necessary for business. To do.
2. Purpose of use of personal information, etc.
   We will use the personal information, etc. of customers acquired in our business within the necessary range according to the following business and purpose of use.
   (1) Scope of business
   ・ Special business for qualified institutional investors based on Article 63 of the Financial Instruments and Exchange Act (operation and management of investment funds) and provision of related services,
   and other services that the Company can operate in accordance with laws and regulations. Providing business and related services (including business that will be newly handled in the future) (
   2) Purpose of use
   ・ Solicitation of investment business association or investment business limited liability association (hereinafter referred to as “investment fund”)・ To explain and propose and guide various services related to this・ To
   accept applications for investment funds, etc.・
   To confirm that you are the investor of the investment fund or its agent
   To carry out affairs related to the formation and management of
   investment funds ・ To sell securities held by investment funds and to carry out affairs related to this
   ・ To report the investment fund management results to customers
   ・ To find investment candidate companies , And to examine and judge whether or not to invest
   ・ To guide, implement, and perform office work related to services (including consulting) provided by the Company and external support companies in order to improve the value of investee companies.
   ・ For exercising rights and fulfilling obligations based on contracts and laws and regulations ・
   For research and development of investment funds, etc. by conducting market research, data analysis, questionnaire surveys, etc. ・
   Information on information exchange meetings held by the Company・For
   inquiries, requests for materials, etc.
   ・ For cancellation of investment fund transactions and administrative management after transaction contracts
   ・ For inquiries and complaints regarding the handling of personal information, etc.
   ・ Other customers In order to properly and smoothly carry out transactions with customers
   ・ Other purposes specified by the Company when acquiring personal information, etc.
3. Prohibition of improper use
   We will not use personal information in a way that may promote or induce illegal or unjust acts.
4. Prohibition of unintended use
   We will properly manage the personal information we have entrusted to us, and will not provide it to third parties except in the following cases.
   ・It is difficult to obtain the consent of the person when the consent of the person is obtained in advance, when
   the provision is requested by law,
   or when it is necessary to protect the life, body or property of the person. case
   ・ When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the individual.
   ・ Received a national agency or local public body or its consignment. When it is necessary for a person to cooperate in carrying out the affairs stipulated by law, and there is a risk that obtaining the consent of the person will hinder the performance of the affairs
   . When personal data is provided and the academic research institution, etc. needs to handle the personal data for academic research purposes (including cases where part of the purpose of handling the personal data is for academic research purposes, an individual Except when there is a risk of unreasonably infringing the rights and interests of We will not provide such information to third parties unless it is specified in the numbering method.
5. Handling of
   Sensitive Information We will not acquire, use or provide sensitive information to third parties except in accordance with the Personal Information Protection Law and other laws and guidelines.
   Sensitive information refers to sensitive personal information (race, creed, social status, medical history, criminal record / previous history, crime damage information, etc.), membership in labor unions, hometown and hometown, health. Information about medical and sexual life.
6. Ensuring the accuracy of retained personal data
   We will endeavor to keep personal data accurate and up-to-date to the extent necessary to achieve the purpose of use. Unless there is a retention period stipulated by law, etc., we will retain the personal data we hold for a retention period according to our internal rules, and after that period, we will dispose of it or perform other appropriate processing.
7. Safety management measures
   We will take necessary and appropriate safety management measures for the management of personal data, such as prevention of leakage, loss or damage. In addition, we will provide necessary and appropriate supervision to employees and contractors (including subcontractors) who handle personal data.
   (1) Organizational safety management measures
   -Along with appointing a person in charge of clerical work related to the handling of personal data, the employees who handle personal data and the range of personal data handled by the employees are clarified, and the Personal Information Protection Law and the Personal Information Handling Regulations We have established a system for reporting and contacting the person in charge of clerical work when we grasp the facts or signs that violate the above.
   ・ We regularly carry out self-inspections regarding the handling status of personal data.
   (2) Personal safety management measures
   ・ We provide training to employees regarding the handling of personal data.
   ・ We have a non-disclosure contract with employees regarding the handling of personal data.
   (3) Physical safety management measures
   ・ If you take measures to prevent theft or loss of equipment, electronic media, documents, etc. that handle personal data, and carry the equipment, electronic media, etc., personal data will not be easily revealed. We are implementing such measures.
   ・ In areas where personal data is handled, entry and exit restrictions are enforced.
   (4) We have implemented technical safety management measures
   and access restrictions to limit the scope of the person in charge and the personal information database we handle.
   -We have introduced a mechanism to protect information systems that handle personal data from unauthorized access or software from the outside.
   (5) Understanding the external environment
   ・ When handling personal data in a foreign country, we take necessary and appropriate measures for the safety management of personal data after understanding the system related to the protection of personal information in the foreign country. ..
8. Compliance and review
   of laws and norms We will comply with Japanese laws and other norms applicable to personal information we hold, review the contents of this policy as appropriate, and strive to improve it.
9. Request procedure for disclosure, etc.
   We will notify you of the purpose of use of personal information, etc. from customers regarding retained personal data, disclosure, correction, addition or deletion of content, suspension or deletion of use, suspension of provision to third parties, or Requests for disclosure of records provided by third parties (hereinafter referred to as “disclosure, etc.”) will be promptly responded to within a reasonable range after confirming the identity of the individual. However, this does not apply if disclosure is not required based on laws and regulations. When requesting disclosure, etc., please contact us using the inquiry form below for detailed procedures.
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    Even in this case, the information acquired by the external service will be handled in accordance with the privacy policy of the external service.
13. Contact Us
    If you have any opinions or requests regarding our handling of personal information, please contact us using the form below. Click here
    for inquiry form [Reception desk] Albacross Co. , Ltd. 3-28-5 Kanda Ogawamachi, Chiyoda-ku, Tokyo 101-0052