Character Size:

Citigroup Capital Partners Japan Ltd.(hereinafter termed "the Company") herein declares its basic policy on the protection of Personal Information (hereinafter termed "Basic Policy") in order to comply with the requirements of the laws and regulations applicable to the Company. The Company values and protects Personal Information on its customers, as an Investment company that values and appreciates the importance of good standing in its relationships with customers and with society at large. The Company is fully aware of its social responsibility to safeguard the Personal Information of customers when engaging in business activities. Based on this understanding, the Company confirms that all of its Employees will comply faithfully with the Law Governing the Protection of Personal Information, other laws and regulations, and the Company's Basic Policy, and that the entire company is committed to fair and appropriate handling of Personal Information. Personal Information will be used to the limits necessary for the purposes listed below in executing the business activities described below, and the use of such information shall not exceed the limits necessary to achieve the said purposes. Further, the Company shall not modify the purposes for use beyond the limits recognized to be fair and rational. (Business Activities) (1) Investment management activities including transactions of securities and accompanying financial businesses. (2) Activities regarding consulting for management and financial affairs of investees and partners. (3) Other supplementary and accompanying activities (Purposes for Use) (1) For the purpose of exploring investment opportunities. (2) For the purpose of evaluating the appropriateness of investment opportunities. (3) For the purpose of supporting procedures for investment or lending to targeted investee companies. (4) For the purpose of making and carrying out a policy plan for the improvement of value in investee companies and working on the accompanying operations. (5) For the purpose of supporting procedures to recoup investments or loans. (6) For the purpose of supporting procedures for funding and investment aspects in the Company or its subsidiaries. (7) For the purpose of management of customers, including to confirm the identity of a customer or his /her proxy. (8) For the purpose of correctly executing activities relegated from other business entities, or relegated with handling of Personal Information either in full or in part, etc (9) For the purpose of handling inquiries, etc., related to Personal Information. (10) For the purpose of handling inquiries of Citigroup Japan Holdings Corp., a holding company of the Company. (11) For the purpose of business management and internal control and administration of the Company. The Company may use and share Personal Data as follows: (1) Items of Personal Data to be shared and used ·  Information on the customer, such as name, address, date of birth, occupation ·  Information related to transactions of the customer, such as transaction details, outstanding deposits, etc. ·  Information on customer needs, such as in asset management (2) The range of parties authorized for shared use ·  The Company. ·  Citigroup Japan Holdings Corp ·  Consolidated companies and equity method affiliates of Citigroup Japan Holdings Corp. that are entered in its annual security report. (3) Purposes for use by using parties ·  For the purpose of a full range of research, development, information service and supply of the best and most appropriate products and services that match the needs of the customers in asset management, etc., through coordination of the group companies, led by the holding company of the entire group, Citigroup Japan Holdings Corp. ·  For the purpose of business management and internal control and administration of the group companies led by Citigroup Japan Holdings Corp. as a holding company. (4) Name of the party responsible for managing shared use of Personal Information: The Company (Citigroup Japan Holdings Corp.) The Company shall not collect, use or provide to third parties information on political views, credo (religion, philosophy, and beliefs), membership of labor unions, race or ethnic group, family origin or permanent domicile, matters related health and medicine, habits related to sexual activity, or criminal record (hereinafter called "Sensitive Information"), except under the conditions described below. If such information is to be collected, used, or provided to third parties under the conditions described below, the information shall be handled with special attention and caution to avoid collection, use, or provision to third parties exceeding the extent of the said conditions. (1) In case of applications of laws and regulations. (2) In case of needs for the protection of human life, health, or property. (3) In case of special needs for improvements to public health or promotion of sound development of children. (4) In case of needs for cooperation with a government organization, local government entity or party designated by those for the execution of their affairs designated by law. (5) In case of collection, use or provision to third parties of Sensitive Information regarding membership of political, religious, or other organization, or labor union of Employees, etc., within the scope necessary for the execution of withholding tax affairs etc. (6) In case of collection, use, or provision to third parties of Sensitive Information within limits necessary in execution of transfer of rights and obligations, in inheritance administration procedure etc. (7) In case of collection, use, or provision to third parties of Sensitive Information within the limits necessary in the execution of business with the consent of the Person in Question, due to the need to ensure appropriate proceedings of financial instrument exchange business and other business activities in the financial field. (8) In case of use of biometric information classified as sensitive information to confirm the identity of a person, with consent of the Person in Question. (1) The Company shall not use fraudulent or other unauthorized means to collect Personal Information. (2) When Personal Information is collected from third parties, the Company shall not improperly infringe upon the interests of the individuals in question. Moreover, the Company shall not, with the knowledge that such Personal Information in question was leaked illegally, collect information from third parties that have employed illegal means to collect Personal Information. (3) The Company may use the following methods to collect Personal Information of customers: ·  Collection of Personal Information from third parties, such as database services firms, etc. ·  Collection through audio recordings, video recordings, reception of e-mail, etc. ·  Collection of information found in government bulletins, newspapers, magazines, Internet, etc. (4) If Personal Information is not provided as requested by the Company, all or part of the Company's services may not be available. The Company shall indicate the purposes of use of Personal Information on its Web site and shall indicate the means, responding to inquiries, etc. The Company shall notify the person or disclose publicly the purposes of use of Personal Information promptly at the collection of the said information, except when the purposes of use have been disclosed in advance. The Company shall explicitly specify the purposes of use of Personal Information in advance when the Company obtains written Personal Information directly from the person in question. The Company shall make efforts to guarantee that Personal Data is accurate and up-to-date within the range necessary to achieve the purposes of use. The Company shall specify the period of storage of Personal Data depending on the purpose of use, and delete the said data after expiration of the said period, except when the period of storage is designated by laws and regulations. The Company shall implement measures that are necessary and appropriate for Personal Data security, such as prevention of leakage or loss of, or damage to, collected Personal Data by establishing a basic policy and regulations on security management and the necessary administration pertaining to security management measures. Necessary and appropriate measures include the following for collection, use, storage, etc., of Personal Data. (1) Organized security management measures: The responsibilities and authority of Employees regarding the management of Personal Data security are clearly defined. Regulations related to security management, etc., have been developed and implemented, and inspection and audits are executed to examine the state of implementation. (2) Human security management measures: Contracts, etc., are concluded with Employees on non-disclosure of Personal Data, and employee training and other programs are executed for the necessary and appropriate supervision of Employees in ensuring the management of Personal Data security. (3) Technical security management measures: Technical measures are implemented for the management of Personal Data security, such as access control to Personal Data and information systems handling Personal Data, surveillance of information systems, etc. The Company shall not provide Personal Data to a third party, except under the conditions below: (1) With the advance consent of the Person in Question. (2) In cases of application of laws and regulations. (3) In response to inquiry or investigation by taxation office, investigative organization, juridical body and other external organizations, etc. (4) In cases of need for the protection of human life, health, or property, and when the consent of the individual in question is difficult to obtain. (5) If all or part of Personal Data handling is commissioned to others, within the range necessary to achieve the purposes of use. (6) In cases of provision of Personal Data due to consolidation or succession of business by other reasons. (7) In cases of shared use of Personal Data based on Article 4 of the Basic Policy. (8) In other cases authorized by relevant laws and regulations. The Company may outsource all or part of its handling of Personal Data within the range necessary to achieve the purposes of use. In such a case, the Company will execute necessary and appropriate supervision over the contractors to which Personal Data handling is outsourced in order to ensure Personal Data security. The Company will accept requests for notification of use purpose, disclosure, revision, addition, deletion, suspension of use, and removal or suspension of provision to third parties related to Collected Personal Data (hereinafter called "Disclosure") in compliance with the application procedure designated by the Company. For further details, please read the Guide to Procedures concerning Applications for Personal Information Disclosure. The guide is outlined below: (1) Contact when requesting Disclosure. Requests are accepted by Management control Division, Citigroup Capital Partners Japan Ltd.. (2) Forms to be submitted to request Disclosure. Please submit the Application for Personal Information Disclosure (3) Method of confirmation of identity for the applicant or proxy requesting Disclosure. Documents for authenticating identity as designated by the Company must be submitted. (4) Charges and collection of payment Charges will be made in accordance with the method designated by the Company in case of notification of the use purposes or disclosure. The Company will properly handle inquiries, complaints, etc., regarding the handling of Personal Information. All inquiries, complaints, etc., should be directed to: Management control Division, Citigroup Capital Partners Japan Ltd. You may dial 03-5221-0100 (representative phone) to speak to Management control Division The Company shall review the content of the Basic Policy as the need arises and revise it in response to any revision of relevant laws and regulations or developments such as changes in the IT environment, etc. The revised Basic Policy will be published on the Company's Web site, and the revised methods to respond to inquiries, etc. shall be disclosed. Specific terms used in the Basic Policy are defined as follows: (1) "Personal Information" is information concerning a living individual (including the customers, Employees of the Company, and other individuals related to business enterprises, etc.), such as name, date of birth, and other descriptions, code or number attached to each individual, and visual and auditory data that can identify the individual (including information that cannot identify the individual by itself, but can easily identify the said individual when associated with other information). (2) "Personal Information Database, etc." is the aggregate of information, including Personal Information, which has been organized systematically for searching specific Personal Information with computers, etc. (3) "Personal Data" is Personal Information that makes up the Personal Information Database, etc. (4) "Collected Personal Data" is Personal Data for which the Company is able to disclose, revise, add, delete, suspend the use, remove and suspend provision to third parties, but excludes information that may infringe on public interests and other interests through disclosure of its presence or absence, or information that is expected to be removed within six months (excluding information that is to be updated). (5) "Person In Question" is the specific individual who can be identified through the Personal Information. (6) "Employees" are individuals who are engaged in the Company's business activities under direct or indirect supervision and management of the Company within its organization, including workers with established employment relationships (executive directors, full-time employees, contractual employees, part-time workers, etc.) and also those without an employment relationship with the Company (directors, executive officers (shikoyaku), auditors and workers assigned from temporary manpower services). Announced on October 14, 2005 Updated on May 1, 2008 Updated on September 1, 2008 Updated on October 1, 2009 Updated on October 31, 2009  Page Top