GVC Asset Management Inc. (hereinafter referred to as "the Company") believes that protecting personal information is one of our key responsibilities, as we provide investment advisory services, asset management, and consulting services for company management. As such, we have established this Basic Policy on Personal Data Protection and declare our commitment to handling personal information appropriately.

1. Compliance with Applicable Laws and Regulations

The Company recognizes that the protection of personal information and the fulfillment of confidentiality obligations are its social responsibilities as a business entity. Therefore, the Company will comply with the "Act on the Protection of Personal Information," the "Enforcement Order of the Act on the Protection of Personal Information," the "Basic Policy on the Protection of Personal Information," the "Guidelines for Personal Data Protection in the Financial Sector," the "Guidelines on the Protection of Personal Information" (Investment Trust Association), the "Guidelines on the Handling of Personal Information" (Japan Investment Advisers Association), and other relevant laws and regulations (hereinafter referred to as "Laws and Regulations"). The Company will ensure the appropriate handling of personal information in the course of performing its investment management, investment advisory services, management consulting services, and related business activities. 

2. Purpose of Use of Personal Information

 The Company will handle personal information only within the scope necessary to achieve the purposes listed below, except when consent is obtained from the customer or when there are exceptions provided by laws and regulations. Additionally, any changes to the purpose of use will only be made within a reasonable and recognized scope.

[Business Uses]
① Investment management and advisory services, as well as Type II financial instruments business
② Management consulting services
③ Other business activities that the Company is permitted to conduct
④ Business activities related to the above-mentioned services

[Purpose of Use]

① To conduct operations related to the establishment of investment trusts, discretionary investment contracts, partnership contracts, and investment advisory agreements (including solicitation)

② To provide investment management and advisory services, as well as Type II financial instruments business services

③ To report on investment management, investment advisory services, and Type II financial instruments business

④ To conduct operations related to management consulting agreements (including solicitation)

⑤ To provide management consulting services

⑥ To appropriately and smoothly communicate and respond to customers, including necessary contact

⑦ To confirm whether the customer is the actual person or acting on behalf of the customer

⑧ To conduct market research, data analysis, surveys, etc.

⑨ To provide information regarding seminars and other events

⑩ To perform management and internal control for the Company 

3. Notification, Disclosure, and Clarification of the Purpose of Use of Personal Information

 The Company will disclose the purpose of use of personal information by posting this basic policy on its website. When the Company acquires personal information, except when the purpose of use has already been notified or disclosed, the Company will promptly notify the individual in writing or disclose the purpose of use. When personal information is obtained through the conclusion of a contract with a customer, the Company will clarify the purpose of use in advance. Personal information obtained from publicly disclosed corporate information, etc., will be used for the purposes mentioned above, as well as for conducting research or making proposals related to the management of the relevant corporation, etc. In addition, if the Company changes the purpose of use of personal information, the Company will notify the individual or disclose the change.

4. Sensitive Information

The Company will not acquire, use, or provide to third parties any information related to a customer's political views, religion, beliefs, membership in labor unions, race, ethnicity, family background, registered domicile, health and medical care, sexual life, or criminal history (hereinafter referred to as "Sensitive Information"), except in cases required by laws and regulations. If the Company acquires, uses, or provides sensitive information to third parties, it will handle such information with caution in accordance with applicable laws. 

5. Security Management Measures

 The Company will comply with applicable laws and regulations and establish a thorough internal control system to prevent the leakage, loss, or damage of personal information and to ensure the safety management of personal information.
Additionally, except in cases where the retention period is prescribed by laws and regulations, the Company will set retention periods for structured personal data (hereinafter referred to as "Personal Data") that can be searched, based on the purpose of use, and will delete any personal data that exceeds the retention period.

6. Outsourcing

When outsourcing the handling of personal information, either in whole or in part, the Company will ensure that the outsourcing party has an adequate information security management system in place. The Company will enter into a contract with the outsourcing party that includes provisions regarding information security management and will provide necessary and appropriate supervision to ensure that personal information is handled securely.

7. Provision to Third Parties

Except in cases where required by laws and regulations, the company will not provide personal information to third parties without notifying the individual in advance of the recipient, the purpose of use, and the content of the information, and obtaining their consent. 

8. Disclosure, etc.

If an individual requests the disclosure, correction, addition, or deletion of their personal information, suspension of its use, erasure, or suspension of provision to third parties, the company will handle such requests in accordance with the prescribed procedures. For further details, please contact our inquiry desk. 

9. Correction, etc.

If an individual requests the correction, addition, or deletion of their personal information due to the content being inaccurate, the company will promptly conduct the necessary investigation, such as verifying the facts, within the scope required to achieve the intended purpose. Based on the results of the investigation, the company will make the necessary corrections to the personal information. 

10. Response to Leakage or Other Incidents

In the event of a personal information leakage or other incidents, we will take the necessary measures to resolve the issue promptly and report the incident immediately to the Financial Services Agency, the Investment Trust Association, the Japan Investment Advisers Association, and other relevant organizations. 

11. Inquiries and Complaints Contact Point
In the event that we receive inquiries or complaints regarding the handling of personal information, we will investigate the matter and make efforts to address it appropriately and promptly. Inquiries and complaints regarding the handling of personal information can be made through the following contact point:

GVC Asset Management Co., Ltd.
　　　　　　Inquiry Contact Point
Phone: 03-6661-7621

12. Complaints and Consultation Contact Points for Industry Associations
Our company is a member of the Investment Trust Association of Japan and the Japan Investment Advisers Association, both of which are certified personal information protection organizations recognized by the Financial Services Agency. These associations accept complaints and consultations regarding the handling of personal information by their members.

• Investment  Management Association of Japan
  Phone: 03-5614-8440