1 Basic Principles
Growthix Capital Ltd. (the “Company”) recognizes the importance of personal information (meaning “personal information” as defined in the Act on the Protection of Personal Information (the “PI Act”), including information relating to a living individual and containing information such as a name, date of birth, or other descriptions whereby a specific individual can be identified; and this will be referred to as “Personal Information”), considers that to protect Personal Information is social responsibility, complies with relevant rules including the PI Act, laws and regulations, guidelines, and internal rules of the Company, and appropriately handles Personal Information.
2 Name and Address of Company and Name of Representative
Growthix Capital Ltd.
6th floor of Tokyo Central Place, 22-6 Nihombashi-kabuto-cho, Chuo-ku, Tokyo, 103-0026
Mitsuo Nakajima, CEO and Representative Director
3 Acquisition of Personal Information
4 Utilization Purposes of Personal Information
Except as stipulated in law or as agreed to by a relevant client, the Company will appropriately use Personal Information acquired by the Company to the extent necessary for achieving the following utilization purposes:
(i) To provide, perform, or introduce M&A intermediate services and financial advisory services (“M&A Services”) and any other services incidental to M&A Services.
(ii) To operate, maintain, or manage M&A Services.
(iii) To send notifications and materials, accept consultations and applications, conduct questionnaire surveys for improvement and upgrade, and check and record responses, concerning M&A Services.
(iv) To research and analyze usage histories and relevant matters of M&A Services, and use the result of such research and analysis for improving and developing M&A Services and for serving advertisement.
(v) To appropriately implement management of the Company.
(vi) To conduct recruiting activities.
5 Management of Personal Data
The Company takes data security measures as enumerated below as necessary and appropriate for personal data security management, including the prevention of leaking, losing, or damaging personal data (meaning “personal data” as defined in the PI Act constituting personal information database, etc., which is systematically organized so that specific Personal Information can be searched for therefrom; and this will be referred to as “Personal Data”). Also, the Company will implement necessary and appropriate supervision over employees and outsourcees (including sub-outsourcees) handling Personal Data.
(2) Establishment of Rules on Handling of Personal Data
For each of stages including acquisition, utilization, storage, provision, deletion, and disposal, the Company has established its internal rules such as “Personal Information Protection Rules” on matters including handling methods, persons in charge, contact persons, and their scopes of work.
(3) Organized Measures for Security Management
The Company has appointed a person in charge of handling Personal Data, demarcated the ranges of employees handling Personal Information and of Personal Data handled by such employees, prepared a system by which if any fact or sign of breach in any rule including the PI Act or the Company’s Personal Information Protection Rules”, such fact or sign will be reported to the person in charge.
(4) Human Measures for Security Management
The Company conducts, for its employees, regular trainings in matters to be noted in handling Personal Data.
(5) Physical Measures for Security Management
The Company takes measures for managing areas where Personal Data is handled and for preventing unlawful acts, including thefts, of relevant items for handling Personal Data such as equipment and electronic media.
(6) Technical Measures for Security Management
The Company has introduced processes for protecting the access control and the information system handling Personal Data from unlawful access or unlawful software of any outsider.
6 Third Party Provision
Except as stipulated below, the Company will not provide any Personal Data that the Company acquires from a client to any third party.
(i) With the prior written consent of such client.
(ii) In accordance with laws and regulations.
(iii) If there is a need to protect a human life, body or fortune and it is difficult to obtain the consent of such client.
(iv) If there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations and there is a possibility that obtaining the consent of such client would interfere with the performance of such affairs.
(v) If Personal Information is provided as a part of business succession due to reasons including merger.
7 Disclosure, Correction, Utilization Cease of Retained Personal Data
In cases where the Company receives any request to disclose, correct, or cease utilization of, Personal Data which the Company retains, the Company will handle such request in accordance with procedures designated by the Company. The details of such procedures will be separately explained and clarified upon clients’ request at the consultation desk for protecting Personal Information as described in 10 below.
9 Compliance with Laws, Regulations, and Norms
The Company will comply with the laws and regulations of Japan and any other rules that are applicable to Personal Information which the Company retains.
10 Consultation Desk for Protecting Personal Information
The Company will accept any complaints or consultations from users and appropriately and promptly respond to such complaints or consultations. Also, the Company will respond promptly and appropriately to any users’ requests for relevant matters including disclosure, correction, addition, deletion, use, or refusal of provision regarding Personal Information.
Please contact the desk below for any questions, complaints, or any other equipment matters concerning the Company’s handling of Personal Information.
6th floor of Tokyo Central Place, 22-6 Nihombashi-kabuto-cho, , Chuo-ku, Tokyo
Consultation Desk for Protecting Personal Information, Growthix Capital Ltd.
Open Hours: 10:00 to 18:00
This policy is established on: February 6, 2023