TSUNEISHI CAPITAL PARTNERS Co., Ltd.

Privacy policy

Personal Information Protection Policy (Privacy Policy)

TSUNEISHI CAPITAL PARTNERS CO., LTD. (hereinafter referred to as the “Company”) recognizes the importance of respecting the right to the protection of personal information as one of the fundamental rights of individuals.
The Company considers the protection of customers’ personal information to be both a fundamental principle of its business and a social responsibility. Accordingly, the Company has established the following Personal Information Protection Policy and will ensure that its directors, employees, and business partners are fully informed of and comply with this Policy.

1. Compliance with Applicable Laws, Regulations, and Guidelines

The Company will comply with the Act on the Protection of Personal Information and all other applicable laws, regulations, and guidelines concerning the handling of personal information.

2. Appropriate Acquisition of Personal Information

When acquiring personal information, the Company will clearly specify the purposes of use and obtain such information by lawful and fair means, within the scope necessary to achieve those purposes.

3.  Purposes of Use of Personal Information

The Company will use the personal information it acquires for the following purposes and will not use such information for any other purpose.
If the Company intends to use personal information beyond the scope of the purposes specified below, the Company will obtain the individual’s prior consent by an appropriate method.

  1. To conduct the Company’s investment activities, including the evaluation of potential investment targets, due diligence, communications, and consultations
  2. To consider and implement collaboration, joint development, and business partnerships with startups, businesses, and other relevant parties
  3. To provide information concerning the Company’s business activities and to conduct operational management
  4. To communicate with shareholders, provide various types of information, and manage shareholder-related matters
  5. To exercise rights or fulfill obligations under applicable laws and regulations
  6. To respond to inquiries and requests from individuals concerning their personal information
  7. To conduct personnel administration and provide employee welfare benefits for the Company’s employees and other personnel
  8. To carry out the Company’s corporate social responsibility (CSR) activities
  9. To provide information regarding services, events, and programs offered by the Company or its group companies, and to conduct surveys
  10. To conduct any other activities incidental or related to the purposes listed above
  11. To fulfill the purposes described in Section 6, “Joint Use of Personal Information,” in addition to the purposes listed above

4. Appropriate Management of Personal Information

The Company will strictly manage personal information and implement preventive measures against risks such as loss, destruction, alteration, leakage, and unauthorized access. The Company will also take necessary and appropriate measures to ensure the secure management of personal information. In addition, the Company will establish specific rules governing the appropriate handling and use of personal information and appoint a person responsible for its management.

5. Provision of Personal Information to Third Parties

  1. The Company will not provide personal information to any third party except in any of the following circumstances:
    1. When the individual’s prior consent has been obtained
    2. When required or permitted by applicable laws or regulations
    3. When it is necessary to protect the life, physical safety, or property of an individual and it is difficult to obtain the individual’s consent
    4. When it is particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the individual’s consent
    5. When it is necessary to cooperate with a national government agency, local government, or a person entrusted by such an agency or government in performing duties prescribed by law, and obtaining the individual’s consent may interfere with the performance of those duties
    6. In any other circumstances in which the provision of personal information is permitted under the Act on the Protection of Personal Information
  2. Notwithstanding the provisions above, the Company will neither provide specified personal information to third parties nor jointly use such information, except where permitted by applicable laws and regulations.

6. Joint Use of Personal Information

The Company may jointly use personal information with its group companies as described below.

（1）Joint Use of Customer and Business Partner Information

  1. Categories of personal data to be jointly used
    • Name, address, telephone number, email address, date of birth, workplace, gender, details of transactions, and other relevant information
  2. Scope of joint users
    • The Company’s group companies
  3. Purposes of use by joint users
    • To perform contracts with the individual
    • To provide services offered by the Company or its group companies
    • To provide information regarding services offered by the Company or its group companies and to conduct surveys
    • To forward inquiries, applications, and other requests from the individual to the relevant company in relation to services offered by the Company or its group companies
    • To manage business partners of the Company or its group companies
    • To consider and promote investment activities and business collaborations
    • To conduct any other activities incidental or related to the purposes listed above
  4. Entity responsible for the management of jointly used personal data
    TSUNEISHI CAPITAL PARTNERS CO., LTD.

（2）Joint Use of Employee Information

  1. Categories of personal data to be jointly used
    • (a) Name, address, telephone number, email address, date of birth, workplace, gender, facial photograph, employee identification number, department, position, employment status, company email address, information concerning company-issued mobile devices, annual income, monthly income, bonuses, methods used to determine compensation, dependent status, retirement benefits, performance evaluations, educational background, qualifications and licenses, grade or rank, employment history, disciplinary actions, awards, and other relevant information
      This may include the name, address, relationship to the employee or other relevant individual, gender, and date of birth of family members whose personal data has been provided by the employee or other relevant individual.
    • (b) Information concerning leave of absence, health conditions, physical or mental disabilities, and other information relating to health management or workplace accommodations
  2. Scope of joint users
    • The Company’s group companies
  3.  Purposes of use by joint users
    • ⑴ Purposes of use of the personal data specified in (i)(a)
      • To undertake human resources strategy, risk management, digital transformation support, personnel administration, and other related activities
      • To comply with applicable laws and regulations and submit notifications and other documentation required by law
      • To conduct any other activities incidental or related to the purposes listed above
    • ⑵ Purposes of use of the personal data specified in (i)(b)
      • To consider personnel assignments, workplace return arrangements, and support for returning to work, and to conduct occupational health and safety management and related risk management
  4. Entity responsible for the management of jointly used personal data
    TSUNEISHI GROUP CORPORATION

7. Management of Contractors Handling Personal Information

The Company may entrust the handling of acquired personal information to third-party contractors when necessary for the efficient performance of its business operations.
In such cases, the Company will select contractors that maintain an adequate level of personal information protection, require them through contracts or other appropriate means to maintain such protection standards, and ensure that personal information is handled appropriately.

8. Security Control Measures

The Company implements the following security control measures with respect to retained personal data.

  1. Establishment of a Basic Policy
    ・To ensure the appropriate handling of personal data, the Company has established a basic policy addressing matters such as compliance with applicable laws, regulations, and guidelines, as well as contact points for questions and complaints.
  2. Establishment of Rules for the Handling of Personal Data
    ・The Company has established rules for handling personal data that specify handling procedures, responsible persons, personnel in charge, and their respective duties at each stage, including acquisition, use, storage, provision, deletion, and disposal.
  3. Organizational Security Control Measures
    ・The Company periodically conducts internal reviews of the handling of personal data and audits by departments other than the department responsible for handling such data.
  4. Personnel Security Control Measures
    ・The Company provides employees with regular training on matters requiring attention when handling personal data.
  5. Physical Security Control Measures
    ・The Company takes measures to prevent the theft, loss, or other unauthorized removal of devices, electronic media, documents, and other materials used to handle personal data.
  6. Technical Security Control Measures
    ・The Company implements access controls to limit the personnel authorized to handle personal data and the scope of personal information databases and other systems accessible to such personnel.

The Company will continuously improve its Personal Information Protection Policy and internal rules to ensure that the protection of personal information required by society is implemented effectively.

9. Procedures for Requests for Disclosure and Other Actions Concerning Retained Personal Data

  1. If an individual wishes to request notification of the purpose of use of the Company’s retained personal data, disclosure of retained personal data, correction, addition, or deletion of its contents, or suspension of use or erasure of such data (collectively referred to as a “Request for Disclosure, etc.”), the individual must mail the following documents and other required materials to the Personal Information Inquiry Desk specified in Section 10.
    1. A written request specifying the individual’s address, name, occupation, telephone number, email address, and purpose of the request
    2. Documentation verifying the individual’s identity, such as a copy of a driver’s license, passport, health insurance card, or other identification document
    3. Postage stamps corresponding to the applicable processing fee. Please contact the Personal Information Inquiry Desk to confirm the amount of the fee.
  2. After verifying the individual’s identity, the Company will investigate the relevant retained personal data, take any necessary action, and mail a written response setting forth the results to the individual.
  3. Personal information acquired in connection with a Request for Disclosure, etc. will be used only to the extent necessary to process that request.
  4. The Company may decline to disclose information in any of the following circumstances. If the Company decides not to disclose the information, the Company will notify the individual of the decision and the reason for it.
    1. When the Company is unable to verify the identity of the individual
    2. When the applicable processing fee has not been paid
    3. When the request does not qualify as a Request for Disclosure, etc.
    4. When disclosure may harm the life, physical safety, property, or other rights or interests of the individual or a third party
    5. When disclosure may significantly interfere with the proper performance of the Company’s business operations

10. Notification of Purposes of Use and Requests for Disclosure of Personal Information

To submit a Request for Disclosure, etc., please contact the Personal Information Inquiry Desk below and inform us of the nature of your request.
The Company will respond appropriately in accordance with the purpose and principles of the Act on the Protection of Personal Information.

（Personal Information Inquiry Desk）

Personal Information Protection Consultation Desk
TSUNEISHI CAPITAL PARTNERS CO., LTD.

Address: 1083 Tsuneishi, Numakuma-cho, Fukuyama, Hiroshima 720-0393, Japan
Telephone: +81-84-987-3553
Business hours: Monday through Friday, excluding public holidays and the year-end and New Year holiday period
9:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m.
TSUNEISHI CAPITAL PARTNERS CO., LTD.

11. Continuous Improvement of the Personal Information Protection Policy and Internal Rules

The Company will continuously improve its Personal Information Protection Policy and internal rules to ensure that the protection of personal information required by society is implemented effectively.

Established: June 2026

©2026 TSUNEISHI CAPITAL PARTNERS Co., Ltd.