Compass Capital Co., Ltd. and its wholly owned subsidiary, Compass Asset Management Co., Ltd. (collectively, the “Compass Capital Group”), recognize that the proper handling and protection of customers’ personal information is an important responsibility in conducting the real estate transaction business and related operations of Compass Capital Co., Ltd., as well as the Type II Financial Instruments Business, Investment Advisory and Agency Business, and related operations of Compass Asset Management Co., Ltd.

This Policy sets forth the basic principles governing the acquisition, use, and management of personal information handled by the Compass Capital Group.

The Compass Capital Group shall comply with the Act on the Protection of Personal Information (the “APPI”), the Financial Instruments and Exchange Act, and other applicable laws and regulations, and shall endeavor to ensure the proper protection of personal information.

In addition, the Compass Capital Group shall establish internal rules necessary for the proper management of personal information, provide all officers and employees with training on personal information protection, and continuously develop and maintain a system for the secure management of personal information.

This Privacy Policy applies to personal information obtained from customers and business counterparties in connection with all services provided by the Compass Capital Group.

When acquiring personal information from customers and others, the Compass Capital Group shall do so by lawful and appropriate means, after clearly indicating, notifying, or publicly announcing the purpose of use, and only to the extent necessary to achieve such purpose.

Except as otherwise provided by law, the Compass Capital Group shall not acquire sensitive personal information as defined under the APPI without obtaining the prior consent of the customer or other relevant individual.

The personal information acquired by the Compass Capital Group from customers and others includes, without limitation:

• • Contact information such as name, address, telephone number, and email address
• • Basic information such as date of birth, gender, and occupation
• • Information used in making investment judgments, such as income, asset status, investment experience, and transaction history of financial instruments
• • Other information necessary to achieve the purposes of use

The Compass Capital Group primarily acquires personal information by the following methods:

• • Completion of contracts and application forms
• • Interviews conducted by telephone or in person
• • Information entered through the Compass Capital Group’s website

The Compass Capital Group shall specify, to the greatest extent possible, and publicly disclose the purposes of use of personal information acquired by each company within the Group.

The purposes of use currently contemplated are as follows:

• • Provision of services relating to real estate transactions and real estate investment (Compass Capital Co., Ltd.)
• • Provision of financial instruments transaction services and investment advisory services (Compass Asset Management Co., Ltd.)
• • Proposal of optimal products and services based on customers’ needs and circumstances
• • Performance of contracts, post-transaction administration, and procedures required under laws, regulations, and association rules, including identity verification
• • Provision of information regarding products and services handled by the Compass Capital Group, and marketing activities such as customer analysis for product development, improvement, and service enhancement
• • Responding to inquiries and handling complaints

The Compass Capital Group shall use personal information of customers and others only to the extent necessary to achieve the purposes of use.

Except where prior consent has been obtained from the customer or other relevant individual, or where otherwise permitted by law, the Compass Capital Group shall not use personal information beyond the scope necessary to achieve such purposes.

Except in the following cases, the Compass Capital Group shall not provide personal information to any third party without obtaining the prior consent of the customer or other relevant individual:

• • Where required by laws or regulations
• • Where necessary for the protection of human life, body, or property, and it is difficult to obtain the consent of the customer or other relevant individual
• • Where responding to a lawful request from a public authority

The Compass Capital Group may jointly use personal information provided by customers and others with affiliated companies under the following conditions:

• • Items of information subject to joint use: name, address, contact details, transaction history, etc.
• • Scope of joint users: Compass Capital Co., Ltd. and Compass Asset Management Co., Ltd.
• • Purpose of use: provision of comprehensive services and risk management
• • Name, address, and representative of the party responsible for managing personal information subject to joint use:

  　Compass Capital Co., Ltd.
  1F Kudan Kaikan Terrace, 1-6-5 Kudanminami, Chiyoda-ku, Tokyo
  Representive Director Sha Yi

  
  

  　Compass Asset Management Co., Ltd.
  1F Kudan Kaikan Terrace, 1-6-5 Kudanminami, Chiyoda-ku, Tokyo
  Representive Director Hitoshi Maehara

To prevent leakage, loss, or damage of personal information, the Compass Capital Group shall implement security control measures including the following.

Details of such measures shall be provided without delay upon request by the relevant individual.

• • Technical measures: access restrictions to information systems, encryption of communication data, etc.
• • Human measures: development of internal rules, implementation of employee training, etc.
• • Physical measures: locked storage of materials, restrictions on entry by unauthorized persons, etc.
• • Organizational measures: appointment of responsible persons, clarification of roles, and establishment of reporting and communication systems, etc.

The Compass Capital Group may outsource all or part of the handling of personal information within the scope necessary to achieve the purposes of use.

In such cases, the Compass Capital Group shall select contractors deemed capable of properly handling personal information, stipulate appropriate matters regarding security control, confidentiality, conditions for re-outsourcing, and other matters concerning the handling of personal information in outsourcing agreements, and exercise necessary and appropriate supervision.

The Compass Capital Group shall provide officers and employees with education and training on personal information protection and ensure thorough internal dissemination of such training.

The Compass Capital Group shall also provide necessary and appropriate supervision to officers and employees to ensure the secure management of customers’ personal information.

The Compass Capital Group shall continuously review and improve its rules and organizational structure for handling personal information so that they remain effective and properly operated on an ongoing basis.

Where revision of this Privacy Policy becomes necessary, the Compass Capital Group shall make improvements as appropriate and provide notice through the Compass Capital Group’s website or other appropriate means.

The Compass Capital Group may receive from third parties information relating to customers and others, such as identifiers and behavioral history (“person-related information”), and may acquire such information as personal information by linking it with personal information of customers managed by the Compass Capital Group.

Specifically, such information may include cookies, mobile advertising identifiers, email addresses and telephone numbers (including those subjected to irreversible conversion processing), advertisement delivery logs such as the number of ad views, website browsing history, search history, purchase history, location information, and other behavioral history. The Compass Capital Group may link and use such information together with personal information it manages.

In such cases, the Compass Capital Group shall handle such information appropriately as personal information within the scope necessary to achieve the purposes of use described in this Privacy Policy.

Where a request is made under the APPI for disclosure, correction, suspension of use, deletion, or similar action with respect to personal data retained by the Compass Capital Group, the Compass Capital Group shall, after confirming that the requester is the individual concerned or his/her authorized representative, respond promptly in accordance with applicable laws and regulations, unless there are special reasons such as a risk of harming the life, body, property, or other rights and interests of the individual or a third party, or a serious hindrance to the proper conduct of business.

Requests, complaints, and inquiries regarding personal information handled by the Compass Capital Group may be directed to the following contact points:

• • Personal Information Protection Officer, Compass Capital Co., Ltd. (info@cmpscap.com)
• • Personal Information Protection Officer, Compass Asset Management Co., Ltd. (info@cmpscap.com)

Compass Asset Management Co., Ltd. is a member of the Investment Trusts Association, Japan, which is an authorized personal information protection organization certified by the Personal Information Protection Commission.

The Association’s consultation desk accepts complaints and inquiries regarding the handling of personal information by its member companies.

Investors Consultation Office, Member Audit Department
The Investment Trusts Association, Japan
Tel: 03-6821-8756
Business Hours: Monday through Friday
(excluding national holidays and the year-end/New Year holidays)
9:00 a.m. to 11:30 a.m.; 12:30 p.m. to 5:00 p.m.