Definition of Personal Imformation

CyberAgent Capital recognizes that personal information is information about a living individual prescribed under the Act on the Protection of Personal Information (information that can identify a specific individual by name, date of birth, or the like); any email address, user ID, password, credit card details, or any other information that is used in connection with a specific individual; or interests, family composition, age, or any other attribute information about an individual that is incorporated in personal information.

Cookies and IP address Information

CyberAgent Capital does not consider cookies and IP address information to be personal information because cookies and IP address information cannot be used independently to identify a specific individual. However, CyberAgent Capital will deem cookies or IP address information to be personal information if either is incorporated and used together with personal information.
CyberAgent Capital discloses the purpose or method of utilization of any cookies or IP address information it utilizes within the media it operates, even if, for example, those cookies or that IP address information cannot be used to identify any specific individual. It is possible to set a browser to refuse cookies, and if a service cannot be used when a browser is set to refuse cookies, CyberAgent Capital will make a public announcement to that effect.

Specification of Purpose of Utilization of Personal Information

CyberAgent Capital specifies, to the extent possible, the purpose of utilization of personal information it handles.

Restrictions on Utilization of Personal Information

CyberAgent Capital does not handle your personal information beyond the scope necessary for achieving the purpose of utilization without obtaining your prior consent. Even if CyberAgent Capital acquires your personal information as a result of a merger or any other instance of succession of business, CyberAgent Capital will not, without obtaining your prior consent, handle your personal information beyond the scope necessary for achieving the purpose of utilization before the succession of business. However, these restrictions do not apply in any of the following cases:

1. (1) a case in which the handling of personal information is based on any law or ordinance;
2. (2) a case in which the handling of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain your consent;
3. (3) a case in which the handling of personal information is especially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain your consent; or
4. (4) a case in which the handling of personal information is necessary for cooperation with a state organ, a local government, or any party delegated by either a state organ or local government to execute affairs prescribed by any law or ordinance and in which obtaining your consent is likely to impede the execution of those affairs.

Proper Acquisition of Personal Information

CyberAgent Capital acquires personal information in a proper manner and does not acquire personal information through deception or any other wrongful means. In addition, CyberAgent Capital is also mindful to avoid collecting information of a personal nature from any child under 15 years old unless CyberAgent Capital has good reason to do so and the consent of a person who has parental authority.

Notice of Purpose of Utilization at the Time of Acquisition of Personal Information

CyberAgent Capital publicly announces in advance the purpose of utilization of any personal information it acquires from you; however, this provision does not apply in any of the following cases:

1. (1) a case in which notifying you of the purpose of utilization or publicly announcing it is likely to harm your or a third party’s life, body, or property or any other right or interest held by you or a third party;
2. (2) a case in which notifying you of the purpose of utilization or publicly announcing it is likely to harm any right or legitimate interest of CyberAgent Capital;
3. (3) a case in which it is necessary to cooperate with a state organ or a local government to execute affairs prescribed by any law or ordinance and in which notifying you of the purpose of utilization or publicly announcing it is likely to impede the execution of those affairs; or
4. (4) a case in which it is deemed that the purpose of utilization is clear in consideration of the circumstances of the acquisition.

Changes to Purpose of Utilization of Personal Information

CyberAgent Capital will not change the purpose of utilization of your personal information beyond a scope in which it is reasonably considered that the purpose of utilization after the change remains duly relevant to that before the change and will notify you of or publicly announce any change to the purpose of utilization.

Secure Management of Personal Information and Supervision of Employees

CyberAgent Capital provides personal information protection regulations to prevent leakage of, loss of, or damage to personal information and to otherwise securely manage personal information and carries out necessary and appropriate supervision of its employees.

Supervision of Delegated Parties

If CyberAgent Capital completely or partially delegates handling of personal information, then CyberAgent Capital will enter into an agreement with the delegated party that includes provisions concerning confidentiality or will request that delegated party’s agreement with stipulations made by CyberAgent Capital and will carry out necessary and appropriate supervision to ensure that the delegated party carries out secure management of the personal information.

Restrictions on Provision to Third Parties

CyberAgent Capital does not provide your personal information to a third party without obtaining your prior consent, except in any of the following cases:

1. (1) a case in which the provision of personal information is based on law or ordinance;
2. (2) a case in which the provision of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain your consent;
3. (3) a case in which the provision of personal information is especially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain your consent;
4. (4) a case in which the handling of personal information is necessary for cooperation with a state organ, a local government, or any party delegated by either a state organ or local government to execute affairs prescribed by any law or ordinance and in which obtaining your consent is likely to impede the execution of those affairs; or
5. (5) CyberAgent Capital provides notice of or publicly announces any of the following items:
   1. 1. the fact that the provision to a third party is included in the purpose of utilization;
   2. 2. the items of your personal information to be provided to a third party;
   3. 3. the means or method of provision to a third party; or
   4. 4. the fact that provision of your personal information to a third party will be discontinued at your request.

However, none of the following cases falls under provision to a third party under this article (“10. Restrictions on Provision to Third Parties”):

1. (1) a case in which CyberAgent Capital
   completely or partially delegates the handling of your personal information within the scope necessary for the achievement of the purpose of utilization;
2. (2) a case in which your personal information is provided as a result of the succession of business in a merger or otherwise; or
3. (3) a case in which your personal information is utilized jointly with a specific party and in which this fact, the items of your personal information jointly utilized, the scope encompassed by the parties jointly utilizing your personal information, the purpose for which your personal information is utilized by those parties, and the name or title of the party responsible for the management of your personal
   information is, in advance, notified to you or made readily accessible to you.

If CyberAgent Capital jointly utilizes your personal information with any specific party, CyberAgent Capital will, in advance, notify you or make readily accessible to you details of any change to the purpose of utilization of your personal information or any change to the name or title of any person responsible for managing your personal information.

Public Announcement of Matters Concerning Personal Information

CyberAgent Capital makes information concerning the following matters relating to your personal information readily accessible to you and will respond to any request from you regarding these matters without delay:

1. (1) the purpose of utilization of your personal information (unless it is prescribed under the Act on the Protection of Personal Information that CyberAgent Capital does not bear any obligation to make that information readily accessible; if CyberAgent Capital decides not to respond to your request, CyberAgent Capital will notify you to that effect without delay); or
2. (2) contact information for inquiries regarding your personal information.

Personal Information Disclosure

CyberAgent Capital will disclose to you your personal information without delay if you request disclosure. However, CyberAgent Capital may decide not to disclose all or part of your personal information in any of the following cases, and in that case CyberAgent Capital will notify you to that effect without delay:

1. (1) a case in which disclosure is likely to harm your or a third party’s life, body, property, or any other right or interest held by you or a third party;
2. (2) a case in which disclosure is likely to seriously impede the proper execution of CyberAgent Capital’s business; or
3. (3) a case in which disclosure will breach any other law or ordinance.

In principle, CyberAgent Capital does not disclose access logs or information other than personal information.

Correction of Personal Information

If you request CyberAgent Capital to correct, add, or delete any details of your personal information on the grounds that those details of your personal information are false, CyberAgent Capital will, except in cases in which any special procedure is prescribed by any other law or ordinance, carry out any necessary investigation without delay within the scope necessary for the achievement of the purpose of utilization and, on the basis of the results, correct, add, or delete those details of your personal information and notify you to that effect.

Discontinuance of Utilization of Personal Information

If you request CyberAgent Capital to discontinue utilizing or to erase your personal information on the grounds that your personal information is being handled in a manner that exceeds the scope of the purpose of utilization publicly announced in advance or because your personal information has been acquired through deception or any other wrongful means, CyberAgent Capital will carry out any necessary inspection on your personal information without delay and, on the basis of the results, discontinue utilizing or erase your personal information and notify you to that effect. However, this provision does not apply in any case in which it requires excessively large costs or it is otherwise difficult to discontinue utilizing or to erase your personal information and in which CyberAgent Capital takes necessary alternative measures to protect your rights and interests.

Explanation of Reasons

If CyberAgent Capital decides not to do any of the following despite receiving a request from you, CyberAgent Capital will endeavor to explain the reason for that decision to you when notifying you of that decision:

1. (1) notify the purpose of utilization of your personal information;
2. (2) disclose all or some of your personal information;
3. (3) discontinue utilizing or erase your personal information; or
4. (4) discontinue provision of your

personal information to any third party.

Note

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