Privacy Policy

Ant Capital Partners Co., Ltd. (“Ant Capital”) has established the following privacy policy. and wWe will adhere to this policy and do our utmost to protect personally-identifiable information about individuals including our clients (“personal informationPersonal Information”).

1. Compliance with relevant laws and regulations

Ant Capital is deeply aware that it is our social responsibility to properly handle personal informationPersonal Information in the course of achieving our business objectives, and, in order to fulfill this responsibility, all of our officers and employees will comply with the Act on the Protection of Personal InformationPersonal Information (“APPI”) and all other relevant laws and regulations.

2. Acquiring personal informationPersonal Information

Ant Capital will not obtain personal informationPersonal Information through unlawful means and will obtain personal informationPersonal Information using legitimate and fair methods and only to the extent necessary to carry out our business. When we obtainobtaining personal informationPersonal Information from a third party, we will not improperly infringe on the rights of the individual.

3. How personal informationPersonal Information is used

Ant Capital will uses the personal informationPersonal Information obtained in the course of business to the extent necessary for the following activities and purposes. It Such Personal Information will not be used for other purposes except when required by law or as otherwise provided in item 4 below.

  1. Scope of activities
    1. Specially permitted businesses for qualified institutional investors, etc pursuant to Article 63 of the Financial Instruments and Exchange Act (e.g. managing and administering an investment fund) and ancillary activities thereof
    2. Other businesses that may be operated by Ant Capital pursuant to laws and regulations, and ancillary activities thereof (including businesses that we may be permitted to begin handling in the future)
  2. Purposes for the use of personal informationPersonal Information
    1. a. For verifying that the individual is an Ant Capital shareholder or an agent thereof and for otherwise implementing various measures to ensure an appropriate and good relationship with our shareholders.
    2. For offering and explaining an investment partnerships andor an investment limited partnerships (“investment fundsInvestment Fund”) and for providing various types of proposals and guidance concerning services related to such funds.
    3. For receiving applications subscriptions for the investment fundsInvestment Fund.
    4. For verifying that the individual is an investor in an investment fund Investment Fund or the agent of an investor.
    5. For carrying out administrative functions concerning the formation or management of an investment fundInvestment Fund, such as the delivery of monies in connection with an investment fundInvestment Fund.
    6. For selling securities held by an Investment Fundinvestment fund or for administrative functions related to such sales.
    7. To report the performance of an Investment Fundinvestment fund to our clients.
    8. To uncover companies that are candidates for investment, and to review and decide whether to make an investment.
    9. To provide information about, perform, or administer services (including consulting) provided by Ant Capital, Ant Capital subsidiaries and affiliates, and external support companies in order to enhance the value of the portfolio companies.
    10. To exercise rights or perform obligations pursuant to law or as stipulated by contracts, and to perform other administrative functions associated with investinginvestments.
    11. To properly perform the work that has been entrusted to us when another business has entrusted to us some or all of its processing of personal informationPersonal Information.
    12. To research and develop investment fundsInvestment Funds by analyzing data and conducting surveys along with carrying out market research.
    13. To provide information about seminars and information exchange sessions held by Ant Capital or Ant Capital subsidiaries and affiliates.
    14. To receive and send various requests for materials and to provide the information deemed necessary.
    15. To cancel investment fundInvestment Fund transactions and to follow-up after a transaction agreement.
    16. To address inquiries or complaints concerning our handling of personal informationPersonal Information.
    17. To make Ant Capital’s hiring decisions.
    18. To administer employment at Ant Capital.
    19. To otherwise fulfill transactions with our clients an appropriate and orderly fashion.

4. Prohibited purposes

Ant Capital will not use personal informationPersonal Information for purposes beyond those specified in item 3(2) above, except as stated below.

  1. When the individual has given advance consent.
  2. When required by law.
  3. When it is necessary to protect a person’s life, physical person or property, but it is difficult to obtain the individual’s consent.
  4. When it is especially necessary in order to improve public health or to promote child welfare, but it is difficult to obtain the individual’s consent.
  5. When it is necessary to cooperate with a national government agency or local governmental body, or a designee thereof, in discharging their legal duties, and when obtaining the individual’s advance consent could impede the performance of such duties.

5. Notifying, disclosing, and clarifying the purpose of use

When Ant Capital obtains personal informationPersonal Information, we will promptly notify and/or disclose to the individual the purpose for which it will be used, except when the purpose has already been disclosed.

When Ant Capital obtains personal informationPersonal Information listed in a written agreement or in other documents from an individual in connection with the execution of a contract, we will clearly indicate the purpose for which it will be used in advance.

6. Sensitive iInformation

Ant Capital will not obtain, use, or provide sensitive information to third parties except as stated below. Sensitive iInformation refers to information concerning an individual’s political views, religious beliefs (faith, ideology and beliefs), trade union membership, race or ethnic group, ancestry or origin (except for the name of the prefecture), health care or lifestyle, or criminal record.

  1. When required by law.
  2. When it is necessary to protect a person’s life, physical person or property.
  3. When it is especially necessary in order to improve public health or to promote child welfare.
  4. When it is necessary to cooperate with a national government agency or local governmental body, or a designee thereof, in discharging their legal duties.
  5. When obtaining, using or providing an employee’s Ssensitive Iinformation concerning his or her membership in, or affiliation with, a political or religious organization or trade union to a third party, to the extent necessary to fulfill withholding duties
  6. When obtaining, using or providing Ssensitive Iinformation to a third party to the extent necessary for estate procedures such as the transfer of rights and obligations
  7. When obtaining, using or providing Ssensitive Iinformation to a third party to the extent necessary to perform our duties, with the consent of the individual, because it is necessary to ensure appropriate business practices
  8. When biometric information constituting Ssensitive Iinformation is used to verify identity, with the consent of the individual

7. Ensuring the accuracy of personal data

Ant Capital will endeavor to ensure that personal data is accurate and current, to the extent necessary to accomplish the purposes for its use. Except when there is a legally mandated retention period, Ant Capital will retain the personal data that we possess for the retention period specified by our internal rules, and we will discard or otherwise appropriately dispose of this information after that period has lapsed.

8. Measures for securely controlling personal data

  1. To prevent losses of, leaks of, destruction of, or damage to personal data, Ant Capital will implement security measures necessary depending on the risk, and take the appropriate information security measures to prevent unauthorized access and infection by computer viruses.
  2. If Ant Capital outsources some or all of the handling of personal data, along with selecting contractor(s) meeting selection criteria and executing agreements that contain security requirements, we will also carry out the necessary and appropriate supervision of these contractors to ensure the personal data is securely managed.
  3. Ant Capital will also provide the necessary and appropriate training and supervision for our officers and employees to ensure they are aware of the importance of protecting personal informationPersonal Information.

9. Providing personal data to third parties

Ant Capital will not disclose or provide the personal data that we have obtained to third parties without the individual’s advance consent, except as provided below.

  1. When required by law.
  2. When it is necessary to protect a person’s life, physical person or property, but it is difficult to obtain the individual’s consent.
  3. When it is especially necessary in order to improve public health or to promote child welfare, but it is difficult to obtain the individual’s consent.
  4. When it is necessary to cooperate with a national government agency or local governmental body, or a designee thereof, in discharging their legal duties, and when obtaining the individual’s advance consent could impede the performance of such duties.

10. Sharing personal data

Ant Capital may share personal data with third parties as described below to the extent that this falls within the scope of the purpose of use.

  1. Types of personal data that may be shared
    1. Client information, such as name, address, date of birth, contact information including telephone number, employment, and trading needs.
    2. Information about client trading, such as trade details and trade balances.
  2. Parties with which information may be shared
    1. Ant Capital and Ant Capital subsidiaries and affiliates.
    2. Co-investors in investment fundsInvestment Funds in which Ant Capital is a managing partner or general partner.
    3. External support companies such as securities firms and shareholder services entities that work with Ant Capital to help the portfolio companies prepare to meet listing requirements and enhance value.
  3. Purpose for the use of shared information Information that is shared is used for the purposes described in item 3(2) above.
  4. Party responsible for managing this personal data
    Ant Capital Partners Co., Ltd.

11. Disclosure of retained personal data

Client requests for the disclosure, correction, or suspension of use of retained personal data (hereafter collectively referred to as “dDisclosure”) should be directed to the point of contact listed in item 13 below. After we have verified that the person making the request is the correct individual, we will follow the procedure described below, except when Ddisclosure is not required by law. If the result of our investigations show that the information about the individual is inaccurate, we will correct the information as dictated by these results.

  1. Types of retained personal data that are eligible for disclosure requests Name, address, telephone number, date of birth, transaction volume (amount invested in investment fundsInvestment Funds), etc.
  2. Documents to be submitted when requesting a Ddisclosure
    1. The disclosure request form prescribed by Ant Capital*
    2. Identity verification documents (presenting a driver’s license, passport, or a copy of one of these)
    3. In addition to the proof of identity described in item b above, the power of attorney prescribed by Ant Capital when the Ddisclosure request is made by a legal agent* After checking the documents, Ant Capital may verify the individual’s intentions.

    *Please direct your request for the disclosure request form and power of attorney to the point of contact listed in item 13 below. We will deliver the documents either in person or by mail. After entering the necessary information in the disclosure request form and power of attorney, please send or bring them back to our point of contact.

  3. Response method
    We will promptly respond in writing to either the address that the individual has supplied or in person at our offices, whichever method is requested, but please be aware that we may need some time to investigate. Please also note that even if the request is made by an agent, in some cases we may respond directly to the individual.
  4. Fees for handling disclosure requests
    As a general rule, this is free of charge. However, please be aware that there may be a charge if actual costs are incurred.
  5. Purpose for which personal informationPersonal Information obtained in connection with the disclosure request process will be used
    Personal informationPersonal Information obtained by Ant Capital in the disclosure request process will be used to review the request, to verify the identity of the individual or his agent, to collect fees (only when fees are collected), and to respond to the disclosure request.
  6. When information the Personal Information is not disclosed
    Please be aware that information the Personal Information cannot be disclosed under the following circumstances. If it is determined that we cannot disclose the informationPersonal Infromation, notice will be provided with the reasons attached.

    1. If we are unable to verify the individual’s identity.
    2. If we are unable to confirm authorization when the request is received from an agent.
    3. If the prescribed documents are incomplete.
    4. If the requested disclosure specifies types of information that are not in the retained personal data.
    5. If there is a risk of harm to the life, physical person, property, or other rights or interests of the individual or a third party.
    6. If it could seriously impede the proper execution of our business.
    7. If it would violate the law.

12. Commitment to continual improvement

Ant Capital complies with the APPI and all other relevant laws and regulations, and we are committed to the proper handling of personal informationPersonal Information. Through our educational and awareness efforts for our officers and employees we ensure that personal informationPersonal Information is not used for other than its intended purposes. We strive for continual improvement by promptly addressing inquiries and complaints concerning our handling of personal informationPersonal Information and by reviewing our handling of personal informationPersonal Information and our security measures.

13. Inquiries to Ant Capital

Ant Capital endeavors to respond in a prompt and sincere manner to inquiries and complaints concerning our handling of personal informationPersonal Information. Please direct any inquiries or comments concerning our handling of personal informationPersonal Information or retained personal data to the point of contact listed below.

<Point of contact >Ant Capital Partners Co., Ltd., Corporate Planning and Administration
Address:1-2-1 Marunouchi, Chiyoda-ku, Tokyo, 100-0005
5th Floor Tokio Marine Nichido Building Shinkan
Telephone:03-3284-1711
Fax:03-3284-1885
Hours:Monday – Friday, 9:00 am to 6:00 pm
(except for legal national holidays and January 2 and 3, and December 30 and 31)