Privacy Policy

Global Brain Corporation ("Global Brain", "us," "our," or "we") recognizes the significance of protecting personal information and complies with Japan's Act on the Protection of Personal Information ("Personal Information Protection Act"), striving to appropriately handle and protect personal information in accordance with the following privacy policy ("Privacy Policy"). Unless otherwise defined in this Privacy Policy, terms used herein have the meanings defined in the Personal Information Protection Act.

1. Definition

In this Privacy Policy, personal information means information relating to a living individual that falls under any of the following items:

• Information containing a name, date of birth, or other identifier or the equivalent (meaning all items made by writing, recording, sound or motion, or other means, in a document, drawing, or electronic or magnetic record) which can be used to identify a specific individual (this includes any information that can be easily collated with other information and thereby used to identify that specific individual);
• Information that contains an individual identification code.

2. Purposes of Use

We use personal information for the following purposes:

• To form and operate investment limited partnerships;
• To acquire and hold securities, such as shares and share options issued by stock companies, and perform other investment operations;
• To provide management or technical guidance and other support to portfolio companies;
• To provide information regarding our services, etc.;
• To improve our services, develop new services, etc.;
• To manage employment and carry out internal procedures (for personal information of officers and employees), and conduct selection and communication in recruitment activities (for personal information of applicants);
• To manage shareholders and handle procedures under the Companies Act and other laws and regulations (for personal information of shareholders and share option holders, etc.);
• To create statistical data processed into a format that does not identify specific individuals in connection with our services;
• Other purposes incidental to the above.

3. Changes to Purposes of Use

We may change the purposes of using personal information within a scope that is reasonably considered to be relevant to the original purposes. In the event of such a change, we will notify the individual who is the subject of the personal information ("Individual") or publicly announce the change.

4. Restrictions on Use

We do not handle personal information beyond the scope necessary to achieve the purposes of use without obtaining the prior consent of the Individual, except as permitted by the Personal Information Protection Act and other laws and regulations. However, this does not apply in the following cases:

• Cases based on laws and regulations;
• Cases in which there is a need to protect the life, body, or property of an individual and it is difficult to obtain the consent of the Individual;
• Cases in which there is a special need to improve public wellbeing or promote healthy child development and it is difficult to obtain the consent of the Individual;
• Cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations and obtaining the consent of the Individual is likely to interfere with the performance of such functions.

5. Proper Acquisition

5.1. We acquire personal information through appropriate means and do not acquire it through deception or other wrongful means.

5.2. We do not acquire sensitive personal information (as defined in Article 2, Paragraph 3 of the Personal Information Protection Act) without obtaining the prior consent of the Individual, except in the following cases:

• Cases falling under any of the items in Article 4 above.
• Cases in which the sensitive personal information is open to the public by the Individual, a national government organ, a local government, a person set forth in each item of Article 57, Paragraph 1 of the Personal Information Protection Act, or other person prescribed by the Order of the Personal Information Protection Commission;
• Cases in which sensitive personal information that is obvious from the appearance of the Individual is acquired through visual observation or filming;
• Cases in which sensitive personal information is provided by a third party and such provision by the third party falls under any of the items of Paragraph 7.1.

5.3. When receiving personal information from a third party, we confirm the following matters pursuant to the Order of the Personal Information Protection Commission. However, this does not apply to cases in which the provision of personal information by the third party falls under any of the items in Article 4 or any of the items in Paragraph 7.1:

• The name and address of the third party, and if it is a corporation, the name of its representative (or for an organization without legal personality that has made provisions for a representative or manager, the name of the representative or manager);
• The background of the third party's acquisition of the personal information.

6. Security Management

We exercise necessary and adequate supervision over its employees to ensure the security management of personal information against risks such as loss, destruction, alteration, and leakage. Furthermore, when entrusting another person with all or part of the handling of personal information, we exercise necessary and adequate supervision over the entrusted person to ensure the security management of personal information.

7. Provision to Third Parties

7.1. We do not provide personal information to third parties without obtaining the prior consent of the individual, except in cases falling under any of the items of Article 4. However, the following cases do not constitute provision to third parties as set forth above.

• Cases in which we provide personal information in connection with the entrustment of all or part of the handling of personal information within the scope necessary to achieve the purposes of use;
• Cases in which we provide personal information due to the succession of business resulting from a merger or other reasons.

7.2. Notwithstanding the provisions of Paragraph 7.1, except in cases falling under any of the items of Article 4, when we provide personal information to a third party (excluding third parties that have established a system conforming to the standards designated by the Order of the Personal Information Protection Commission pursuant to Article 28, Paragraph 1 of the Personal Information Protection Act) in a foreign country (excluding those designated by the Order of the Personal Information Protection Commission pursuant to Article 28, Paragraph 1 of the Personal Information Protection Act), we obtain the prior consent of the Individual to the effect that the Individual approves the provision to a third party in a foreign country.

7.3. When having provided personal information to a third party, we prepare and keep a record pursuant to Article 29 of the Personal Information Protection Act.

7.4. When receiving personal information from a third party, we confirm the required matters and prepare and keep a record of such confirmation pursuant to Article 30 of the Personal Information Protection Act.

8. Disclosure

Upon request from the Individual for disclosure of personal information pursuant to the provisions of the Personal Information Protection Act, we first verify that the request is made by the Individual themselves and then disclose the personal information to the Individual without delay. (If the personal information does not exist, we notify the Individual accordingly). However, this does not apply if we are not obligated to disclose such information under the Personal Information Protection Act or other laws and regulations.

9. Corrections

Upon request from the Individual for correction, addition, or deletion ("Corrections") of the content of the personal information pursuant to the provisions of the Personal Information Protection Act on the grounds that such information is not true, we first verify that the request is made by the Individual themselves and then conduct the required investigation without delay to the extent necessary to achieve the purpose of use. Based on the results, we perform the Corrections of the personal information and notify the Individual. (If we decide not to perform the Corrections, we notify the Individual accordingly). However, this does not apply if we are not obligated to make Corrections under the Personal Information Protection Act or other laws and regulations.

10. Cease of Use or Deletion

Upon request from the Individual for cease of use or deletion of personal information ("Cease of Use or Deletion") pursuant to the provisions of the Personal Information Protection Act on the grounds that the personal information is being handled beyond the scope of the previously announced purposes of use or was acquired by deceit or other wrongful means, or for cease of its provision ("Cease of Provision") on the grounds that the personal information is being provided to a third party without the Individual's consent, and if it is found that there is a reason for the request, we first confirm that the request is made by the Individual themselves and then proceed with Cease of Use or Deletion or Cease of Provision without delay and notify the Individual. However, this does not apply if we are not obligated to conduct Cease of Use or Deletion or Cease of Provision under the Personal Information Protection Act or other laws and regulations.

11. Use of Cookies and Other Technologies

Our services may use Cookies and similar technologies. These technologies help us understand the usage of its services and contribute to service improvement. Users who wish to disable Cookies are able to do so by changing their web browser settings. However, if Cookies are disabled, some functions of our services may become unavailable.

12. Contact Information

If you have any requests for disclosure, etc., opinions, questions, complaints, and other inquiries regarding the handling of personal information, please contact us as described below:

Website: Global Brain Corporation
Email: privacy@globalbrains.com

13. Continuous Improvement

We review the operational status regarding the handling of personal information from time to time for continuous improvement. Please note that we may change this Privacy Policy as necessary.