JAFCO Co., Ltd. (“the Company”) ensures proper protection of information which could identify a customer or other specific individual (“personal information”), and that every executive and employee takes responsibility for adequate information management and this policy is efficiently implemented in order to meet the trust of our shareholders, fund investors, investee companies, and others.
1. In pursuit of “value creation through private equity”, the Company shall use personal information in the cases of fund establishment, investment, value adding to investee companies, and investment liquidation, for the purposes of use listed below:
（1）Establishment, management and related operations of funds, etc.
To introduce funds, etc. and related services
To introduce funds, etc. and related services
To confirm that the customer is the person himself/herself or the agent of himself/herself
To report to customers the management results of funds, etc.
To carry out research and development of funds, etc. through market survey, data analysis, questionnaires, etc.
（2）Private equity investment and related operations
To identify investment candidates
To prepare a capital/ financial policy for investee candidates
To decide whether to invest in an investment candidate based on examination and evaluation of its business potential, technology, products, etc.
To exercise rights and fulfill obligations based on laws, contracts, etc. and carry out other clerical work related to investment.
（3）To introduce and offer services provided by the Company, the Company’s subsidiaries and affiliates and outside supporting companies, and to carry out related clerical work with the aim of adding value to investee companies (including consulting)
（4）To sell securities holdings, etc. and carry out related clerical work
（5）If the processing of all or part of the personal information has been outsourced by other business operators, to appropriately carry out such outsourced operations
（6）Other than above, to perform transactions with customers appropriately and smoothly
（7）To procure products, services, funds, etc. necessary for the operation of the Company and the Company’s subsidiaries and affiliates
2. The Company has appointed an officer in charge of information who takes charge of information management for the Company as a whole and a manager in charge of information for each division.
3. To ensure effective implementation of this policy, the Company shall educate all of our executives and employees so as to comply with laws and regulations with regard to protecting customers’ and other personal information. The Company shall establish internal rules and other compliance programs related to personal information protection, and implement, maintain and continue to improve these programs to ensure thorough understanding of its importance among its executives, employees and related parties.
4. The Company shall take appropriate information security measures against unauthorized accesses, computer viruses, etc., to prevent damage, loss, alteration, and/or leakage of personal information.
5. Except for cases permitted by laws and regulations, the Company does not provide personal information obtained from its customers, etc. to third parties. However, the Company will jointly use personal information with others within the scope provided below
（1）Items of personal data shared
Basic information including name, address, phone number, e-mail address, etc., and investment-related information including the number of shareholding, etc.
（2）Scope of persons that share the information
Subsidiaries and affiliates that are listed in the Company’s annual securities report
Companies that list the Company as a subsidiary or an affiliate in their annual securities reports, and such companies’ subsidiaries and affiliates listed in their annual securities reports
Outside supporting companies, including securities firms and stock transfer agents, that jointly provide IPO preparation and value adding support for investee companies
（3）Purposes of joint use of personal information
Same as in 1.
（4）Persons with responsibility for joint use of personal information
6. When outsourcing the handling of personal information to other institutions, the Company conducts impartial investigations of the institutions concerned and supervises the institutions to ensure that appropriate measures are taken to protect personal information and confidentiality.
7. If the Company receives a request from a customer, etc. for disclosure, amendment, etc. of personal information provided by the customer, the Company will promptly respond to the request to a reasonable extent possible. If you have any opinions or questions regarding the Company’s handling of personal information, please call 81-3-5223-7073 or email email@example.com.
8. With regard to the handling of information related to the Company’s directors and employees, the Company shall manage in accordance with its internal rules, etc. separately established.