FORTUNA GROUP Co., Ltd. (hereinafter, “the Company”) sets forth the following Privacy Policy (hereinafter, “this Policy”) with respect to the handling of personal information of clients, prospective clients and other persons who interact with this website or with the advisory services of the Company (hereinafter together, “the Services”).

Article 1 (Personal Information)

“Personal information” refers to “personal information” as defined by the Act on the Protection of Personal Information of Japan: namely information relating to a living individual that can identify a specific individual by name, date of birth, address, telephone number, contact information or other description, as well as data such as facial features, fingerprints and voiceprints, and identification codes such as the insurer number of a health insurance card that can identify a specific individual on their own (individual identification codes).

Article 2 (Method of Collecting Personal Information)

When you contact the Company through this website, become a client or prospective client of our advisory services, or otherwise engage with the Company, we may ask you to provide personal information such as your name, date of birth, address, telephone number, email address and, where relevant to the engagement, bank account or other payment-related details. The Company may also obtain personal information about you from contractual partners (including professional advisers and service providers; hereinafter, “Partners”) in connection with records of transactions or payments arising from our engagement with you.

Article 3 (Purposes of Collecting and Using Personal Information)

The Company collects and uses personal information for the following purposes:

1. To provide and administer the Services.
2. To respond to enquiries (including identity verification).
3. To send information relevant to an engagement, such as service updates and important notices.
4. To contact clients and other relevant persons as necessary for administration, scheduling or important communications.
5. To identify and decline further engagement with persons attempting to use the Services for fraudulent or improper purposes, or in breach of any terms applicable to the engagement.
6. To allow individuals to verify, correct or delete the information the Company holds about them.
7. For administration and billing in respect of advisory and other paid engagements.
8. Purposes incidental to the foregoing.

Article 4 (Change of Purposes of Use)

1. The Company may change the purposes of use of personal information only insofar as the changed purposes are reasonably recognised as related to those before the change.
2. When the purpose of use is changed, the Company shall notify the individual or publish such change on this website in the manner prescribed by the Company.

Article 5 (Provision of Personal Information to Third Parties)

1. The Company shall not provide personal information to any third party without the prior consent of the individual, except in the following cases or where otherwise permitted by the Act on the Protection of Personal Information or other laws and regulations:
   1. Where provision is necessary for the protection of the life, body or property of a person, and it is difficult to obtain the consent of the individual concerned.
   2. Where provision is particularly necessary for improving public health or promoting the sound upbringing of children, and it is difficult to obtain the consent of the individual concerned.
   3. Where it is necessary to cooperate with a national government agency, a local government, or a party entrusted by either of them in performing duties prescribed by law, and obtaining the consent of the individual concerned is likely to impede the performance of such duties.
   4. Where the following matters have been notified or made public in advance, and the Company has notified the Personal Information Protection Commission:
      1. That the purpose of use includes provision to third parties.
      2. The items of data to be provided to third parties.
      3. The means or method of provision to third parties.
      4. That the provision of personal information to third parties shall be discontinued at the request of the individual.
      5. The method of receiving requests from the individual.
2. Notwithstanding the preceding paragraph, the recipient of the information shall not be regarded as a third party in the following cases:
   1. Where the Company entrusts all or part of the handling of personal information within the scope necessary to achieve the purpose of use.
   2. Where personal information is provided in connection with the succession of business due to a merger or other reason.
   3. Where personal information is used jointly with a specific party, and that fact, together with the items of personal information used jointly, the scope of joint users, the purpose of use by those users, and the name of the party responsible for the management of such personal information, has been notified to the individual in advance or made readily accessible to the individual.

Article 6 (Disclosure of Personal Information)

1. When requested by an individual to disclose his or her personal information, the Company shall disclose it to the individual without delay. However, if disclosure would fall under any of the following, the Company may decline to disclose all or part of the information, and shall notify the individual of any such decision without delay. A handling fee of JPY 1,000 shall apply to each request for disclosure of personal information:
   1. Where disclosure is likely to harm the life, body, property or other rights or interests of the individual or a third party.
   2. Where disclosure is likely to significantly impede the proper conduct of the Company’s business.
   3. Where disclosure would otherwise violate laws or regulations.
2. Notwithstanding the preceding paragraph, the Company shall, in principle, not disclose information other than personal information, such as historical or behavioural data.

Article 7 (Correction, Addition or Deletion of Personal Information)

1. Where personal information held by the Company is incorrect, the individual may, in accordance with the procedures prescribed by the Company, request the Company to correct, add to or delete such personal information (hereinafter, “Correction, Addition or Deletion”).
2. If, upon receiving a request under the preceding paragraph, the Company determines that it is necessary to respond, it shall carry out the Correction, Addition or Deletion of the personal information concerned without delay.
3. The Company shall notify the individual without delay when it has carried out Correction, Addition or Deletion under the preceding paragraph, or when it has decided not to do so.

Article 8 (Suspension of Use or Deletion of Personal Information)

1. Where an individual requests suspension of use or deletion of personal information (hereinafter, “Suspension of Use or Deletion”) on the grounds that the information is being handled beyond the scope of the purpose of use, or that it was obtained by improper means, the Company shall conduct the necessary investigation without delay.
2. Based on the results of the investigation under the preceding paragraph, if the Company determines that it is necessary to respond to the request, it shall carry out the Suspension of Use or Deletion of the personal information concerned without delay.
3. The Company shall notify the individual without delay when it has carried out Suspension of Use or Deletion under the preceding paragraph, or when it has decided not to do so.
4. Notwithstanding the foregoing two paragraphs, where Suspension of Use or Deletion would entail substantial expense or is otherwise difficult to carry out, and where alternative measures necessary to protect the rights and interests of the individual can be taken, the Company shall take such alternative measures.

Article 9 (Changes to this Privacy Policy)

1. The contents of this Policy may be changed without individual notice, except for matters otherwise stipulated by law or in this Policy.
2. Except where otherwise provided by the Company, the revised Privacy Policy shall take effect from the time it is posted on this website.

Article 10 (Contact)

Please direct any enquiries regarding this Policy to the following:

Address: Iida Building 1F, 5-5 Rokubancho, Chiyoda-ku, Tokyo, Japan
Company: FORTUNA GROUP Co., Ltd.
Department: Privacy Enquiries
Email: info@fortuna-group.co.jp

This English version is provided for the convenience of international readers. In the event of any discrepancy between this translation and the original Japanese text, the Japanese version shall prevail.