SPRING INVESTMENT

For Japanese

Privacy Policy

In addition to complying with the Personal Information Protection Act and all other laws and regulations regarding the handling of personal information, Spring Investment Co., Ltd. (the "Company") will comply the following privacy policy.

1. Acquisition of personal information
The Company acquires personal information by legitimate and fair means.

2. Purpose of use of personal information
We will use the personal information we acquire for the following purposes. Except where permitted under the Personal Information Protection Act or any other relevant law or regulation, we will not use an individual's personal information for any purpose outside of those listed below, without that individual's prior consent.

(1) Conclusion and management of related contracts in the financial instruments business (the type II financial instruments business, investment advisory and agency business, and investment management business) and general real estate investment advisory business, money lending business, real estate agency business, consulting on real estate, and property management business, etc.
(2) Providing and management of information on the businesses of the Company, sending and management of greeting cards such as New Year's card, etc.
(3) Any other purpose incidental to those listed above

3. Provision of personal information to third parties
The Company may provide personal information it holds for its related companies, business partners, and outsourcing providers, etc. in accordance with the procedures required by the laws and regulations. The Company will exercise necessary and appropriate supervision over the relative receivers of personal information in order to ensure the security control of the entrusted personal information.

4. Security of personal information
The Company will put in place necessary and proper measures to prevent the disclosure or loss of, tampering with, or damage to, any personal information and secure it.

5. Entrustment of handling personal data
The Company may entrust a third party with the handling of the acquired personal data for the achievement of the purpose of use. In that case, the Company will exercise necessary and appropriate supervision over the trustee to ensure the security control of the entrusted personal information.

6. Requests regarding personal information
If we receive a request from an individual whose personal information we hold to disclose that information, to amend, supplement or delete that information, to temporarily suspend or permanently cease the use of that information, to cease providing that information to a third party, or to inform that individual of the purpose of use of that information, we will respond to that request in reasonably timely manner in accordance with the Personal Information Protection Act, after first confirming that the request is from the individual to whom the information relates.

7. Contact for inquiries
All requests, opinions, questions, complaints, and other inquiries with respect to the Company’s handling of personal information should be referred to our Compliance Department.

Address: 6F Izumikian Kioicho 4-3 Kioicho Chiyoda-ku, Tokyo 102-0094 JAPAN
Telephone: 03-3238-1671
(Please note that business hours for this purpose are from 9:30am to 5:30pm, Monday to Friday.)

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