Privacy Policy

MIRARTH Asset Management Inc. (hereinafter, the “Company”), in addition to the parent company MIRARTH Holdings Inc. (hereinafter, the “Group”), recognizes that the protection and appropriate management of personal information is an important social responsibility, and thereby establishes, implements, and maintains the Privacy Policy as follows.

1. Basic Policy

The Company respects and complies with the laws and regulations regarding the protection of personal information and public order and strives to handle and protect personal information appropriately.

2. Acquisition, Use, and Provision of Personal Information

The Company acquires personal information in a legitimate and appropriate manner, and announces, notifies, or specifies the purpose of use. The Company will not handle personal information beyond the scope of the purpose of use without the consent of the person concerned. In addition, when providing or disclosing personal information to a third party, the Company will do so in accordance with the procedures prescribed by laws and regulations.

3. Purpose of Use of Personal Information

The purposes for which the Company uses personal information it acquires are as follows:

  • Purpose of use of personal information acquired in the fulfillment of contracts, provision of information and services relating to the following businesses conducted by the Company and the Group
    • For the exercise of the rights of investors in private funds (hereinafter referred to as the “Investors”), the performance of the obligations of the private funds, and other responses to Investors.
    • For providing Investors with information regarding business operations and management.
    • For preparing and submitting various notifications, filings, reports, and other documents required of private funds pursuant to the Financial Instruments and Exchange Act and other applicable laws and regulations.
    • For creating investor registers and other data, and for managing Investor information relating to private funds.
    • For responding to inquiries, communications, and marketing activities relating to private funds.
    • For responding to borrowing, other financing activities, and investor relations (IR) activities conducted by private funds.
    • For carrying out leasing or management operations and other operations related to the assets managed by private funds, for understanding the leasing status of such assets, and for the accumulation, statistical processing, and analysis of such data.
    • For conducting operations relating to the acquisition of assets by private funds (including due diligence and other investigations conducted prior to acquisition).
    • For conducting operations related to the sale or disposition of assets by private funds (including solicitation of purchasers).
    • For the proper and smooth performance of services entrusted by private funds, and for carrying out other operations or administrative tasks deemed necessary in connection with or incidental to the purposes set forth in item “(1)” through “(9)” above.
    • For providing personal information to third parties, to the extent reasonably necessary to achieve the purposes set forth in items “(1)” through “(10)” above.
  • Provision of personal information to a third party to the extent necessary for the achievement of the Purpose of use set forth in 1.
  • Sales and marketing activities, such as solicitations, advertisements, or questionnaire surveys, by in-person visits, mail, telephone, e-mail, or other communication methods to achieve the contract fulfillment and provision of information and services in relation to item 1 above.
  • Analysis of customer trends or research and analysis of product development, etc. with respect to each business in 1.
  • Purpose of use of job applicant information
    • Recruitment and recruitment activities: Providing information to and contacting applicants, and selection activities.
  • Purpose of use of personal information of our employees
    • Legally required procedures and notifications, operations related to payment of salaries, etc., employment and personnel management.
  • Information and service provision and advertising will be discontinued upon request from the individual.

    • 4. Joint Use of Personal Data

    • In the following cases, personal data retained by the Company will be provided to joint users (*), including the Group, in writing, by mail, telephone, internet, e-mail, advertising media, or other communication methods with respect to the required items such as name, address, telephone number, e-mail address, date of birth, family structure, place of employment, and annual income. In addition to the purposes of use of personal information as described in 3 above, personal information will be used for business, sales activities, customer trend analysis, or survey analysis conducted by the joint users.
      Specified personal information received from business partners will not be provided or disclosed to third parties, including the Group and joint users, except for the following cases:
      • When a customer gives their consent.
      • When provision is required by laws and regulations.
      • When it is necessary for the protection of the life, body, or property of a person and it is difficult to obtain consent from the person concerned.
      • When it is particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain consent from the person concerned.
      • When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either of them to execute clerical work prescribed by laws and regulations, and obtaining consent from the person concerned is likely to impede the performance of such clerical work.
      • When personal information is provided or disclosed to joint users including the Group to the extent necessary to achieve [3. Purpose of use of Personal Information].
    • Joint users refer to companies designated to sell options, construction companies, management companies, moving companies, and other service providers when customers purchase or build houses; construction companies and design companies for the construction of condominiums and buildings; and other related parties who are necessary for the provision of services under the contracts by and between the Company/Group and customers (including the anticipated contracts).
    • Name, address, and representative of the company responsible for the management of personal data:
      MIRARTH Asset Management Inc.
      Taisei Otemachi Building 18F, 2-1-1 Marunouchi, Chiyoda-ku, Tokyo 100-0004, Japan
      Takehiko Kusajima, Representative Director and CEO

      • 5. Provision of Personal Data to Third Parties

      Personal data retained by the Company may be provided to third parties to the extent necessary to achieve the purpose of use.
      In the event of provision, required items including name, address, telephone number, e-mail address, date of birth, family structure, place of employment, annual income will be provided to third parties in writing, by mail, telephone, internet, e-mail, advertising media, or other communication methods.
      Upon request from the person concerned, the provision of personal information will be suspended.
      (Examples of third parties to be provided with personal information)
      The Group, financial institutions, judicial scriveners, moving companies, utility companies, sales agents, Real Estate Information Network Systems, real estate brokers, etc.

      6. Provision of Personal Information to Third Parties Located Overseas

      Except as otherwise required by laws and regulations, the Company will not provide personal data in its possession to third parties located overseas (meaning countries or regions outside of Japan) without obtaining the prior consent of the person concerned.

      7. Safety Control Measures for Personal Information

      The Company manages personal information in its possession appropriately and carefully, and takes necessary and appropriate safety control measures to prevent unauthorized access, loss, falsification, leakage, and other unauthorized handling of personal information.

      8. Outsourcing the Handling of Personal Information

      The Company may outsource the handling of personal information in its possession to outside contractors to the extent necessary to achieve the purpose of use. In such cases, the Company will exercise necessary and appropriate supervision over the contractor in accordance with laws and regulations.

      9. Procedures for Disclosure and Correction of Personal Information

      When the person concerned requests the Company to disclose, correct, suspend use of and disclose records of provision to third parties of personal information retained by the Company, the Company will handle these requests in accordance with laws and regulations and procedures separately prescribed by the Company after confirming the identity of the person concerned. Fees and postage incurred for disclosure requests and other procedures will be chargeable.

      10. Inquiries about Personal Information

      For questions and inquiries regarding the Company’s handling of personal information, please contact the following:

      Address Taisei Otemachi Building 18F, 2-1-1 Marunouchi, Chiyoda-ku, Tokyo 100-0004, Japan
      Name MIRARTH Asset Management Inc. Group General Affairs Department
      Phone +81-3-6262-6402
      Fax +81-3-6262-6403
      E-mail info@mirarth-am.co.jp
      Office Hours 9:00 a.m. to 5:30 p.m. on Monday to Friday (excluding Saturdays, Sundays, national holidays, and year-end/New Year holidays)

      11. Access Logs and Cookies

      When you access the Company’s web pages, the date and time of your access, your domain name, IP address, browser type, operating system, and other information will be recorded and stored on the Company’s server in the form of an access log. The Company may also send cookies to your computer. The Company will use the results of analyzing access logs and cookies for the following purposes:

    • Display advertisements and provide services related to new products and services according to tastes and preferences.
    • Individually customize the information displayed on the Company’s website for each customer.
    • Improve the user-friendliness of the Company’s website through statistical analysis of usage history and other information, input assistance and others.
    • Manage servers, including security status monitoring.
      • Access logs will be deleted after a certain period of strict management in accordance with the Company’s regulations.

      12. Links to Other Websites

      The Company has no control over the content of websites operated by third parties other than the Company that are linked to/from the Company's website (hereinafter referred to as the "Linked Websites"). The Company is not responsible for the content of Linked Websites or any damages resulting from the use or the effects of Linked Websites.

      13. Revision of This Policy

      This policy will be reviewed and revised as necessary to meet legal requirements and further improve the protection of personal information.

      End
      Established: March 23, 2016
      Partially revised: March 1, 2018
      Partially revised: June 21, 2022
      Partially revised: December 19, 2023
      Partially revised: April 1, 2024
      Partially revised: November 26, 2025
      Partially revised: January 27, 2026