PRIVACY POLICY

1. Scope of Application

This Policy shall apply to the handling of personal information by and between the Company and corporations, organizations, associations, and individuals with whom the Company has a relationship (hereinafter referred to as “Our Related Persons”). Personal information of Our Related Persons obtained by the Company in connection with the Company’s Businesses will be handled in accordance with this Policy.

2. Personal Information

The term “personal information” refers to all information that is provided to the Company in accordance with the “Act on the Protection of Personal Information” (Act No. 57 of 2003, hereinafter referred to as the “Personal Information Protection Act”). It refers to information about a living individual that can identify the specific individual by name, date of birth, address, telephone number, contact information, or any other description contained in the information, as well as personal identification codes.

3. Method of Collecting Personal Information

When collecting personal information, the Company shall specify the purpose of use in advance, notify or publicly announce it, and collect and use the information in an appropriate manner within the scope necessary to achieve the purpose of use.

4. Purpose of Collection and Use of Personal Information

The Company will not use collected personal information for any purpose other than the purpose of use without obtaining the prior consent of the individual, except as provided for in the Personal Information Protection Act. The purposes for which we collect and use personal information are as follows

• To promote the Company’s Businesses
• To respond to inquiries from Our Related Persons (including identification)
• To contact you as necessary for maintenance, important notices, etc.
• To provide information to third parties
• Purposes incidental to the above purposes of use

5. Change of Purpose of Use

The Company shall change the purpose of use of personal information only when it is reasonably recognized that the purpose of use is related to the purpose of use before the change.
In the event of a change in the purpose of use, the Company shall notify Our Related Persons of the changed purpose by the method prescribed by the Company and publicly announce it on the Company’s website.

6. Provision of Personal Information to Third Parties

Except in the following cases, the Company will not provide personal information to a third party without obtaining the prior consent of the person concerned. However, this excludes cases permitted under the Personal Information Protection Act and other laws and regulations.

1. When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual concerned.
2. Cases in which the provision of personal information is particularly necessary for improving public health or promoting the sound growth of children, and in which it is difficult to obtain the consent of the individual concerned
3. When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the consent of the individual is likely to impede the execution of such affairs.
4. When the Company has notified or announced the following matters in advance and has notified the Personal Information Protection Committee
   • Provision of personal information to third parties is included in the purpose of use
   • Means or method of provision to third parties
   • Data items to be provided to third parties
   • Means or method of provision to third parties
   • Stopping the provision of personal information to third parties in response to the request of the person concerned
   • The method of accepting the request of the individual concerned
5. Notwithstanding the provisions of the preceding paragraph, in the following cases, the party to which the information is provided shall not fall under the category of a third party
   • Cases in which the Company outsources all or part of the handling of personal information within the scope necessary for the achievement of the purpose of use
   • When personal information is provided as a result of the succession of business due to a merger or other reasons.
   • In cases where personal information is used jointly with a specific person, and where this fact, the items of personal information jointly used, the scope of joint use, the purpose of use by the person using the information, and the name of the person responsible for managing the personal information are notified to the person in advance or made readily available to the person in question

7. Disclosure of Personal Information

When the Company is requested to disclose personal information by the person in question, the Company will disclose it to the person without delay. However, if the disclosure falls under any of the following cases, the Company can decide not to disclose all or part of the information, and if the Company decides not to disclose the information, the Company will notify the person concerned to that effect without delay. A fee of 1,000 yen will be charged for each case of disclosure of personal information.

• When there is a risk of harm to the life, body, property, or other rights or interests of the person concerned or a third party.
• Cases in which disclosure of personal information is likely to cause significant hindrance to the proper conduct of the Company’s Business
• Cases in which the handling of personal information violates any other laws or regulations

In principle, however, the Company will not disclose information other than personal information, such as historical information and characteristic information.

8. Correction and Deletion of Personal Information

If personal information held by the Company is incorrect, Our Related Persons may request the Company to correct, add, or delete the personal information through procedures prescribed by the Company in accordance with the Personal Information Protection Act. If the Company receives a request as described in the preceding paragraph from Our Related Persons and deems it necessary to respond to the request, the Company will correct, add, or delete the relevant personal information without delay.
When the Company correct, add, or delete the personal information based on the preceding paragraph, or decides not to, the Company will notify the person concerned of such decision without delay.

9. Suspension of Use of Personal Information, etc.

If the Company is requested by an individual to cease use or delete his/her personal information on the grounds that it has been handled beyond the scope of the purpose of use or that it has been obtained by wrongful means, the Company will conduct the necessary investigation without delay.
If, based on the results of the investigation described in the preceding paragraph, the Company determines that it is necessary to comply with the request, the Company will suspend the use of the relevant personal information without delay.
When the Company suspends the use of personal information in accordance with the preceding paragraph, or when the Company decides not to, the Company will notify the person concerned without delay.
In cases where the suspension of use involves a large amount of cost or where it is difficult to suspend use, etc., and alternative measures can be taken to protect the rights and interests of Our Related Persons, alternative measures shall be taken.

10. Security

The Company has appointed a personal information protection manager and is taking the following measures to strictly manage the protection of personal information.

• Secure Sockets Layer (SSL) encryption to protect against interception by third parties.
• Confidentiality agreements with employees and workers
• Anti-virus software
• Password authentication and appropriate access authorization

11. Modification of Privacy Policy

The contents of this Policy may be changed without notice to Our Related Persons, except as otherwise provided in laws and regulations or in this Policy.
Unless otherwise specified by the Company, the revised version of the Policy shall take effect from the time it is posted on the Company’s website.

Business operator handling personal information, contact for inquiries

For inquiries regarding this Policy, please contact the following

Name of the Company
BLUEPASS CAPITAL INC.

Inquiry Contact
Sumitomo Fudosan Onarimon Tower 7F, 1-1-1 Shiba-Koen, Minato-ku, Tokyo 105-0011
Please contact us using the CONTACT form.

This policy is written in Japanese as the official text. In the event of any discrepancy between the translated version and the Japanese version, the Japanese version shall prevail.