California Privacy Notice2023

This California Privacy Notice provides information about how SPARX Asset Management Co.,
Ltd. collects, uses, discloses and otherwise processes personal information of individual residentsof the State of California within the scope of the California Consumer Privacy Act of 2018, as
amended by the California Consumer Privacy Rights Act (collectively, the “CCPA”). This
California Privacy Notice applies solely to the individual residents of the State of California(“consumers”).
Information on the categories of California Personal Information collected and/or whether wesell or share personal information is contained in Sections “1. Categories of California Personal
Information collected by us” and “4. Disclosure and Sale of California Personal Information”
below. Information on the length of time the business intends to retain California Personal
Information is contained in Section “6. Retention Period.” below. Information on your rights
regarding your California Personal Information is contained in Section 8 . “Your Rights
Concerning California Personal Information” below.

Unless otherwise expressly stated, all terms in this California Privacy Notice shall have the same
meaning as defined in the CCPA.
Scope of Notice
When we use the term “personal information” in this California Privacy Notice, we mean
information that identifies, relates to, describes, is reasonably capable of being associated with,or could reasonably be linked, directly or indirectly, with a particular consumer or household. It
does not include information that is made publicly available from government records, that isdeidentified or aggregated such that it is not reasonably capable of being associated with anindividual, or that is otherwise excluded from the CCPA’s scope.

1.

Categories of California Personal Information collected by us

We have collected the following categories of personal information under the CCPA (“CaliforniaPersonal Information”) from and about you in the preceding 12 months:
Identifiers (e.g. real name, email address, SNS account name, IP address)

California Customer Records (Cal. Civ. Code § 1798.80(e)), (e.g. name, mobile phone
number, home address, business address, email address)

Commercial information (e.g., investment history).

Internet or other electronic network activity (e.g., strictly necessary cookies, technicaland device information).

2.

Professional or employment-related information (e.g. name of the company your workfor, your title, job experience and track record data)

Education information (e.g. records of educational organization, degree information,awards)Inferences drawn from any of the above (e.g., preferences or characteristics)



Inferences drawn from personal information above

Categories of sources of California Personal Information

In the preceeding 12 months we have collected the California Personal Information specified inSection 1 above directly from you or indirectly from third parties, including companies yourwork for and our service providers, such as though executed agreements, applications pertainingto opening accounts, applications for lecture sessions, examinations of investment candidates,
business cards, the due diligence process, and the KYC process.3. How We Use PersonalInformation

3.

Our Use of California Personal Information

Our purposes of use of California Personal Information are as set forth below.

(1)
To solicit or sell the products and services of the Company such as securities, investment
advisor contracts, and discretionary investment contracts under the Financial Instruments andExchange Act, or to introduce services related thereto.
(2)
To introduce the group companies of the Company (the parent company of the Company
and consolidated subsidiaries stated in its annual securities report thereof) to customers.
(3)
To determine the appropriateness of providing products and services in light of theprinciple of suitability and other factors.
(4)

To confirm the identity of a customer or a customer’s representative.

(5)
To report to a customer the results of a transaction, the balance of an account, the statusof management activities, and the like.
(6)
To carry out administrative tasks related to a transaction with a customer or a party to atransaction (including conducting due diligence and monitoring after investment)(7)
To execute rights or fulfill duties based on a contract with a customer or laws andregulations(8)
To research or develop financial products or services by implementing market research,data analysis, questionnaires, and the like.

(9)To appropriately execute entrusted businesses when, for example, the Company isentrusted with processing all or part of Personal Information, Etc. and the like from anotherbusiness entity or similar party.
(10) Other matters in order to appropriately and smoothly fulfill transactions with a customer
or a party to a transaction.
(11)

To carry out the Company’s business management or internal controls.

Our commercial purposes as identified in the CPRA include advancing a person’s commercial oreconomic interests, such as by inducing another person to buy our products and services, orenabling or effecting, directly or indirectly, a commercial transaction.
Our business purposes as identified in the CPRA include (i) helping to ensure security andintegrity to the extent the use of California Personal Information is reasonably necessary andproportionate for these purposes, (ii) debugging to identify and repair errors that impair existing
intended functionality, (iii) short-term, transient use, (iv) performing services on behalf of thebusiness, and (v) providing advertising and marketing services.

4. Disclosure and Sale of California Personal Information
Disclosure for Business Purposes
In the last 12 months, we have disclosed for business purposes all categories of personal
information outlined above to the following categories of recipients: Affiliates, Service Providers,and certain other third parties where we are complying with law or protecting our rights (such asto our legal advisors).
Sale of Personal Information
We have not sold and/or shared California Personal Information in the preceding 12 months.

5. Sensitive Personal Information
We do not collect “Sensitive Personal Information” as defined by the CCPA.

6. Retention Period
We retain California Personal Information for as long as necessary to fulfil our commercial andbusiness purposes for which we collected it, including for the purposes of satisfying any legal,
accounting, or reporting requirements, to establish or defend legal claims, or for compliance andprotection purposes. To determine the appropriate retention period for California PersonalInformation, we consider the amount, nature, and sensitivity of the California PersonalInformation, the potential risk of harm from unauthorized use or disclosure of your California

Personal Information, the purposes for which we process your California Personal Information
and whether we can achieve those purposes through other means, and the applicable legalrequirements.
7. Your rights concerning California Personal Information
California residents have certain rights with respect to California Personal Information wecollect. If you are a California resident, you may exercise the following rights regarding your
California Personal Information, subject to certain exceptions and limitations: The right to know any or all of the following information relating to the personal
information we have collected about you or disclosed in the last 12 months, uponverification of your identity:
 The specific pieces of personal information we have collected aboutyou;
 The categories of personal information we have collected about you;
 The categories of sources of the personal information we have collectedabout you;
 The categories of personal information that we have disclosed about
you to third parties for a business purpose, and the categories ofrecipients to whom this information was disclosed;
 The categories of personal information we have sold about you (if any),
and the categories of third parties to whom this information was sold;and The business or commercial purposes for collecting or, if applicable, selling personal
information about you.The right to request that we delete the personal information
we have collected from you or maintain about you, subject to certain exceptions; The right to correct inaccurate personal information we maintain about you, taking
into account the nature of the personal data and the purposes of the processing of thepersonal data.;
 The right to opt out of our sale(s) or sharing of your personal information. You havethe right to direct us not to “sell” your personal information to third parties for monetaryor other valuable consideration, or “share” your personal information to third parties forcross-context behavioral advertising purposes. If you are under the age of 16, you have theright to opt in, or to have a parent or guardian opt in on your behalf, to such sales or sharing.
(As explained above, we do not sell or share your personal information as those practices
are defined under the CCPA); The right to limit the use and disclosure of sensitive personal information. You havethe right to direct us to limit the use of your sensitive personal information to certain
purposes, including to perform the services or provide the goods reasonably by anaverage consumer who requests those goods or services. As explained above, we do notcollect your sensitive personal information as part of the Services.
 The right not to receive discriminatory treatment for the exercise of the privacy rights
conferred by the CPRA. However, please note that if the exercise of the rights describedabove limits our ability to process personal information (such as in the case of a deletionrequest), we may no longer be able to provide you our products or services or engage
with you in the same manner.
Shine the Light. Under California’s “Shine the Light” law (Civil Code Section §1798.83), California residents that have an established business relationship with us haverights to know how their information is disclosed to third parties for their direct marketingpurposes.

How to Exercise Your California Privacy Rights
To exercise the above rights, please submit a request by: Emailing us at SAM_CCPA@sparxgroup.com.
Verification procedures and necessary information: We may request that you provide additional
information to verify your identity or to correctly understand, evaluate and respond to your request,
but you are not required to create an account with us in order to have it fulfilled. We ask you toprovide specific personal information for our records and reference. We will require you to provide,
at a minimum name and email address. Although we try to limit the personal information collectedin connection with a request to exercise the right to know and/or the right to deletion to thecategories of personal information identified above, certain requests may require us to obtain
additional personal information from you. In certain circumstances, we may decline a request toexercise the right to know and/or right to deletion, particularly where we are unable to verify youridentity.
Authorized Agent: If you are a California resident, in certain circumstances, you may designate
an authorized agent to submit requests on your behalf through the designated methods set forth
above where we can verify the authorized agent’s authority to act on your behalf by:
For requests to know or delete personal information:o Receiving a power of attorney valid under the laws of California from you or yourauthorized agent; oro Receiving sufficient evidence to show that you have:Provided the authorized agent signed permission to act on your behalf;

Verified your own identity directly with us pursuant to the instructions set
forth in this California Privacy Notice; and

Directly confirmed with us that you provided the authorized agent
permission to submit the request on your behalf.

For requests to opt out of personal information sales: Receiving a signed permission
demonstrating your authorized agent has been authorized by you to act on your behalf.

We may deny a request in the event we are not able to verify the authorized agent’s authority toact on your behalf.

8. MinorsWe do not and will not “sell” the personal information of consumers we know to be less than 16years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either theminor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13years of age.

9. California Do Not Track Disclosure.
Our websites, apps and other online services are not designed to respond to “Do Not Track”
requests from browsers.

10. Changes to this California Privacy Notice
We reserve the right to amend this California Privacy Notice at our discretion and at any time.
When we make changes to this California Privacy Notice, we will post the updated notice on theWebsite and update the notice's effective date.

11. Contact Information
You may contact us with questions or concerns about our privacy policies or practices and yourchoices and rights under California law at here.
E-mail :SAM_CCPA@sparxgroup.com