Privacy Policy

Consonant Investment Management Co., Ltd. (the "Company") deems that it is its social responsibility to protect personal information in an appropriate manner. The Company complies with the Act on the Protection of Personal Information (Act No.57 in 2003; the "Personal Information Protection Act") and other relevant laws and legislation, as well as the following "Privacy Policy". With regard to policy on protection of individual numbers and specific personal information and matters such as purpose of use, collection and provision to any third parties, the Company will separately establish a basic policy on appropriate handling of individual numbers and specific personal information and abide by such.

1．Collection of Personal Information

The Company collects personal information in fair and lawful manners, to the extent necessary to achieve the Purpose of Use specified below. The Company shall not collect special care-required personal information without obtaining the consent of the individual concerned, with the exception of cases subject to laws and regulations; nor shall it collect sensitive information (as defined in the Guidelines for Personal Information Protection in the Financial Field (the "Guidelines in Financial Field"), with the exception of cases provided by the Guidelines in Financial Field.

2. Disclosure of Purposes of Using Personal Information

When collecting personal information, the Company specifies its purposes of use and announces, notifies or expressly discloses such purposes.

3. Purposes of Use of Personal Information

The Company uses personal information to the extent necessary to achieve the following purposes. The Company will not change the Purposes of Use of Personal Information beyond the extent that it deems reasonable.

1. exercise of rights by unitholders who hold securities issued by Invincible Investment Corporation (the "Investment Corporation") in accordance with the Act on Investment Trusts and Investment Corporations (Act No. 198 in 1951; the "Investment Trusts Act") , the Companies Act (Act No.86 in 2005; the "Companies Act") and other relevant laws and legislation, and performance by the Investment Corporation of its obligations;
2. notification of information, etc., to unitholders of the Investment Corporation with regard to the business of the Investment Corporation;
3. management of information of unitholders, such as the creation of a list of unitholders in accordance with the Investment Trust Acts, creation and submission of reports of the Investment Corporation in accordance with the Investment Trust Acts, the Companies Act, the Financial Instruments and Exchange Act and other relevant legislation, as well as regulations set by the Financial Instruments Exchange Act, and the creation of data with respect to the unitholders of the Investment Corporation;
4. response to inquiries and requests for materials to the Company and the Investment Corporation;
5. borrowing, issuance of investment corporation bonds and short-term investment corporation bonds and additional issuance of investment units;
6. conducting business regarding the acquisition, investigation, and deliberation on the acquisition of some assets that will be managed by the Investment Corporation, or the sale of the assets managed by the Investment Corporation;
7. conducting business regarding the leasing of the assets managed by the Investment Corporation;
8. conducting other business of the Company or the Investment Corporation in appropriate and smooth manners; and
9. provision of personal information to any third parties to the extent necessary to achieve the Purposes of Use above

4. Use of Personal Information beyond the Scope of Defined Purposes

The Company undertakes the necessary procedures in accordance with the Personal Information Protection Act, etc., in cases where the Company manages personal information beyond a reasonable extent without the consent of the individual whose personal information will be disclosed or provided. The Company shall not use sensitive information with the exception of the cases provided by the Guidelines in Financial Field.

5. Disclosure of Personal Information to Third Parties

The Company shall not disclose or provide any acquired personal information to any third party except in the cases listed below. The Company shall not disclose or provide sensitive information to any third parties with the exception of the cases provided by the Guidelines in Financial Field

1. an individual whose personal information will be disclosed or provided has consented to such disclosure or provision;
2. such disclosure or provision is required in accordance with laws and regulations;
3. such disclosure or provision is necessary to protect life, the human body or property, and it is difficult to obtain the consent from the individual whose personal information will be disclosed or provided; and
4. it is necessary for the Company to cooperate with government authorities, local public organizations, or those who are entrusted by such parties regarding their administrative operation in accordance with laws and legislations, and obtaining the consent of the individual whose personal information will be disclosed or provided may adversely affect the implementation of such administrative operation.

However, the Company may disclose or provide personal data to the following parties other than the Company if such is not regarded as provision to third parties under the Personal Information Protection Act, including cases when providing the personal data in line with outsourcing the handling of all or part of personal data within the scope necessary to achieve the purpose of use.

6. Management and Protection of Personal Data

With the aim of appropriately managing personal data, the Company makes its best efforts to protect personal data by establishing its internal regulations and internal management system and conducting security management procedures, on an appropriate and rational level, to prevent dangers, such as leakage, loss of or damage to such personal information or illicit accesses from outsiders.

7. Supervision of Outsourcee

The Company may outsource the handling of all or part of personal data within the scope necessary to achieve the purpose of use. In such cases, the Company appropriately selects such outsourced parties and provides necessary and appropriate supervision of such outsourced parties to ensure the safe management of such outsourced personal data.

8. Procedures on Disclosure and Correction of Registered Information and Suspension of Use

In cases where the Company receives any request to disclose, correct, discontinue the use of or delete personal data retained by the Company from an individual or the party entrusted by such individual, the Company responds to such request sincerely and rationally in accordance with law and legislation to the extent that such response to such request does not disturb the appropriate implementation of its business operation. In this case, the Company confirms the identification of such individual, or the party entrusted by such individual, using a predetermined method. The request regarding disclosure, correction or discontinuation of the use of personal information will be accepted at the contact number stated in paragraph 10.

9. Improvement of Policy on Private Information Protection

The Company will comply with applicable laws and guidelines, etc., including the Personal Information Protection Act. In addition, the Company may revise the Privacy Policy with the aim of protecting personal information further or in accordance with a change in applicable laws.

10. Inquiries into Management of Personal Information

For inquiries and applications submitted by unitholders regarding content in the register of unitholders held by INV (correction, addition or deletion of items in the register of unitholders), please contact the Administrator below.

Please note that depending on the content of the inquiry or application, in light of applicable laws and regulations, we may not be able to reply or respond.

11. Contact for Complaint/Consultation at the Authorized Personal Information Protection Organization

The Company is a member of The Investment Trusts Association, Japan ("JITA"), which is a personal information protection organization authorized by the Japanese Financial Services Agency. JITA receives inquiries and provides consultation on its member companies' handling of personal information.
For all inquiries, please use the contact details below: