SPRING INVESTMENT

For Japanese

Privacy Policy

Spring Investment Co., Ltd. (the "Company") recognizes the importance of personal information and will comply with the Act on the Protection of Personal Information, Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures and related laws and regulations (individually or collectively, the "Acts"). The Company will make all efforts to handle personal information appropriately in accordance with the following policy and endeavor to improve its handling continuously.

1. Acquisition, use, and provision of personal information

(1) The Company will acquire personal information (including individual number and personal information which contains individual number (collectively, "Specific Personal Information") by legitimate and fair means.
(2) The Company will use personal information for the purpose set forth in "2. Purpose of use of personal information" (the "Purpose of Use"). The Company will, except for the cases permitted by the Acts, not use personal information, without obtaining a prior consent of the person, beyond the scope necessary for the achievement of the Purpose of Use.
(3) The Company will comply with the procedures stipulated in the Acts when the Company provides or discloses personal information to third parties or is provided or disclosed personal information by third parties.
(4) The Company will not acquire or use Specific Personal Information beyond the purpose stipulated in the Acts definitely.

2. Purpose of use of personal information
The Company will use the personal information for the following purposes.

(1) Personal Information (except Specific Personal Information)
(a) Investigation, consideration, conclusion of contracts, management and provision of information and services in the financial instruments business (the type II financial instruments business, investment advisory and agency business, and investment management business), general real estate investment advisory business, real estate agency business, consulting on real estate, and property management business, etc.
(b) Personnel and labor management of officers and employees of the Company
(c) Hiring and screening officers and employees of the Company
(d) Sending and management of greeting cards
(e) Any other purpose incidental to those listed above
(2) Specific Personal Information of individuals except officers and employees of the Company
(a) Payment records preparation related work
(b) Any other purpose incidental to that listed above
(3) Specific Personal Information of officers and employees of the Company
(a) Processing withholding income tax related work
(b) Processing special collection of local taxes related work
(c) Processing payment reports (incl. those of insurance transactions) preparation related work
(d) Processing employment insurance related work
(e) Processing health insurance and employees' pension insurance related work
(f) Any other purpose incidental to those listed above

3. Provision of personal data to third parties
The Company will, except for the cases permitted by the Acts, not provide personal data to third parties without obtaining a prior consent of the person. In addition, the Company, except for the cases stipulated in the Acts definitely, will not provide Specific Personal Information to third parties.

"Those cases stipulated in the Acts definitely" mentioned above includes cases where the Company entrusts the handling of personal data or Specific Personal Information in whole or in part to other business operators for the achievement of the Purpose of Use, where the Company provides personal information to another business operator as a result of the succession of business, etc. In the case of entrusting a the handling of personal data or Specific Personal Information, the Company will exercise necessary and appropriate supervision over an entrusted person so as to seek the security control of such personal data and Specific Personal Information.

4. Security Control of personal data, etc.
The Company will take necessary and appropriate action for the security control of personal data and Specific Personal Information including preventing the leakage, loss or damage of its handling of those.

5. Disclosure, correction, etc. regarding personal data
If the Company receives a request from an individual whose personal data the Company retains to disclose that information, to correct, 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, the Company will respond to that request in reasonably timely manner based on the Acts, after identity confirmation of the individual by identification documents, such as driver's license, residence certificate, etc.

6. Contact for inquiries
All requests, opinions, questions, complaints, and other inquiries with respect to your own personal data retained by the Company 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.)

In addition to the above, the contact point of the Japan Investment Advisers Association, an accredited personal information protection organization, is also available. Contact point: Counseling Office (in charge of personal information), Secretariat Office of the Japan Investment Advisers Association.
Telephone: 03-3663-0505

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