Privacy policy
Alternative Investment Capital Limited (hereinafter referred to as "the Company") shallappropriately protect personal information (personal information as set forth in Paragraph 2 ofArticle 2 of the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafterreferred to as "the Act"); the same shall apply hereinafter) and each director and employee shall be
responsible for appropriate information management in order to respond to the trust of shareholders,fund investors, and investee companies, and shall endeavor to ensure that this Policy functions
effectively.
1.

The Company shall, in order to realize value creation through private equity, use PersonalInformation for the following purposes in relation to the formation of funds, investments,increasing the value of the companies we have invested in, and collecting the return ofinvestments.
(1) Formation and operation of funds and the business operations related or ancillary thereto(2) Investment advisory business, business operations concerning investment advisory
agreements, and other business operations the Company is permitted to conduct by relevantlaws and regulations and guidelines from supervising authorities, as well as the businessoperations ancillary thereto(3) Other business operations the Company is permitted to conduct by relevant laws,
regulations and guidelines from supervising authorities and the business operations ancillary
thereto (including business operations that the Company will be permitted to conduct in thefuture)(4) Otherwise for appropriate and efficient performance of transactions with our clients2.

In the event of acquiring personal information for purposes other than the above, the Company
shall promptly notify the person with the purpose of use in writing, by mail, e-mail, or by
posting such notice on the Company's website. Should the Purpose of Use is changed at thetime of acquisition, the Company shall notify or publicly announce as such. In addition, we will
not use the acquired personal information for purposes other than the intended purpose, andhandle complaints in accordance with the Act. We will not acquire, use, or provide a third party
with sensitive information defined in the Guidelines for the Protection of Personal Informationin the Financial Sector (such as personal information requiring consideration and information
on membership registration in labor unions, family origin, registered domicile, health andmedical care, etc.), except as permitted by laws and regulations.

3.

In the event personal information is provided to a third party in a foreign country with theconsent of the customer, if the third party to whom the personal information is provided can beidentified ex post facto, the specified information will be provided upon request of thecustomer.

4.

We will keep personal information accurate and up-to-date, and will strive to erase such
personal information without delay if it is no longer necessary to use it. In addition, we will
implement necessary and appropriate safety management measures to prevent the leakage ofpersonal information and conduct appropriate supervision of officers and employees.

5.

We will respond to the request of the employee without delay with regard to the security control
measures for personal data.

6.

To ensure proper handling of personal information, we will review this policy from time to timeand strive for continuous improvement.

7.

Method of Acquisition of Personal Information
We will obtain personal information of our customers in an appropriate manner in accordancewith laws and regulations.
Specifically, we will acquire information related to transaction-related documents such asconfirmation forms and contracts, questionnaires, Internet, postcards, telephone, etc., and theprinciples of conformity based on the consent of the customer.

8.

Except in the following cases, we will not provide personal information provided by customers
to third parties without obtaining the prior consent of the individual.
(1) cases based on laws and regulations(2) cases in which there is a need to protect human life, body or fortune, and when it is difficult
to obtain a principal’s consent(3) cases in which there is a special need to enhance public hygiene or promote fostering
healthy children, and when it is difficult to obtain a principal’s consent.
(4) cases in which there is a need to cooperate with a central government organization or a local
government, or a person entrusted by them performing affairs prescribed by laws andregulations, and when there is a possibility that obtaining a principal’s consent wouldinterfere with the performance of the said affairs(5) cases in which the handling of personal data is entrusted to a third party in whole or in partwithin the scope necessary to achieve the Purpose of Utilization(6) cases in which information is provided to a person within the scope of the following jointusers

A. Items of Personal Data to be Shared
Basic information such as name, address, telephone number, e-mail address, etc., andinvestment information such as the number of shares held
B. Scope of joint users
The scope of parties with whom the Company jointly uses the information is as follows:(Company Names)
・AIC shareholders (click here for our shareholders)
・T&D Asset Management Co., Ltd.
・Sumitomo Mitsui DS Asset Management Co., Ltd.
・AIC Private Equity Fund General Partner Limited
C. Purpose of joint use
As with the purpose of use stated in 1 in the above.
D. Information manager in the case of joint use
Alternative Investment Capital Limited (Reijiro Samura, President and CEO, Tekko
Building 6F, 8-2 Marunouchi 1-chome, Chiyoda-ku, Tokyo)
9.

When subcontracting the handling of personal data to a third party, the Company shall conduct
a strict investigation of the third party and supervise the third party to ensure it thoroughly
conducts appropriate management of personal data, such as maintaining confidentiality.

10. The Company accepts client requests for disclosure, correction, suspension of use, andsuspension of provision to third parties (hereinafter referred to as “Disclosure”) in relation to
the personal data acquired by the Company. Concerning the specific procedures for requesting
Disclosure, please see “Procedure for requesting disclosure, correction, deletion, andsuspension of use.“ Please refer to the above for questions and complaints regarding ourhandling of personal data.