Privacy Policy
1. Basic Policy(1) Codo Advisory, Inc. (hereinafter referred to as “we” or "the Company") has a social
responsibility to protect personal information obtained by the Company and to ensure the trust
therein. Therefore, all directors and employees of the Company must comply with all laws andregulations concerning the protection of personal information, and must handle the personal
information held by the Company in an appropriate manner.
(2) Leakage, falsification, loss, unauthorized use, or unauthorized disclosure of personal
information obtained by the Company will result in loss of trust from the Company's customers
and business partners, as well as damage to the Company. Employees who engage in such acts
will be subject to disciplinary action and may also be subject to legal penalties. The Company
hereby requires all officers and employees to be aware of the importance and responsibility of
personal information management and to act in good faith and in accordance with this Privacy
Policy (hereinafter referred to as the "Policy").
(3) In addition, we will take the following measures to ensure the smooth operation of thisPersonal Information Protection Policy.

2. Handling of personal information(1) We will appoint a person responsible for the management of personal information, properly
manage such information in accordance with our rules and regulations for the protection ofpersonal information, and prohibit inappropriate use of such information.
(2) We will conduct systematic education and training to ensure that all of our directors andemployees are familiar with this Policy, and will periodically check and evaluate the status ofcompliance with this Policy, and review, maintain, and improve our personal information
protection measures as appropriate.
(3) In order to prevent leakage, falsification, loss, or unauthorized use of personal information heldby the Company, we will strive to ensure and improve appropriate information security,
including measures against unauthorized access, computers, and viruses.
(4) We shall use personal information only within the scope of the purpose of use and only byauthorized persons in accordance with their specific duties, and only to the extent necessary forthe performance of their duties.
(5) All officers and employees of the Company shall not disclose to any third party or use for any
improper purpose any personal information obtained in the course of their duties. The same
shall apply even after they leave the Company.

3. Purpose of use of personal information(1) The purposes of the acquisition and use of personal information shall be as follow:(a) To send out administrative communications, questionnaires, and various types of1

information (products, services, seminars, exhibitions, etc.) from the Company.
(b) To perform administrative procedures such as billing and payment to customers andperformance of contracts and transactions with customers and business partners.
(c) To analyze the acquired browsing history information and distribute various types ofinformation in accordance with the analysis results.
(2) When personal information is provided for purposes other than those listed above, we will
notify you in advance of the purpose of use, etc., and handle personal information within an
appropriate scope.

4. Joint Use
We may use personal data jointly as follows:
Amita Corporation
6-7, Kanda Kajicho 3-chome, Chiyoda-ku, Tokyo
Takahide Suetsugu, Representative Director
Scope of joint use
MCP Asset Management (Japan), Inc.
1-8-1, Otemachi, Chiyoda-ku, Tokyo
Tetsuya Tanaka, Representative Director・ To use personal information in connection with the performanceof contracts and transactions with customers and business
partners. We also use personal information for the purpose ofadministrative communication, surveys, and the distribution ofvarious types of information (products, services, seminars,exhibitions, etc.).
・ To use personal information for the purpose of analyzing thePurpose of joint use
acquired browsing history information and distributing various
offers in accordance with the results of the analysis.

Information Items used
jointly
Joint UseManager

Information

When we ask you to provide personal information for joint usepurposes other than those listed above, we will notify you in advanceof the joint use purposes, etc., and handle your personal information
within the appropriate scope.
Name, date of birth, gender, address, telephone number, fax number,e-mail address, company (organization) name, department name,title, and information on use of services, etc.
Codo Advisory, Inc.
2-12-1 Tenjin, Chuo-ku, Fukuoka City, Fukuoka Prefecture
Kaori Suzuki, President and CEO

5. Provision of personal information to third parties
We will not provide personal data to third parties without the consent of the individual, except
when providing personal data to third parties for the purpose of outsourcing work within thescope necessary to achieve the purpose of use, when jointly using personal data as described in
4. above, or when other exceptions are recognized by the laws and regulations concerning theprotection of personal information. In addition, when providing personal data to third parties, wewill screen such third parties in accordance with predetermined standards, conclude necessary2contracts, and take other measures required by law.

6. Inquiries about disclosure, correction, suspension of use, etc. of personal Data
We will respond in good faith to your requests for disclosure, correction, addition, deletion,suspension of use, elimination, and suspension of provision to third parties of your personal data
held by the Company. Please direct inquiries and complaints to:
Personal Information Complaints and Consultation Desk at Codo Advisory, Inc.
E-mail address: privacy@codo.jp

7. Other matters(1) We cannot be responsible for the security of personal information at other companies linkedto our website.
(2) Any important changes or announcements will be posted on the website.
(3) We may revise this Policy in order to better protect personal information, or in response tochanges in relevant laws and regulations.
April 2022

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