Cygnos Capital (hereinafter referred to as the “Company”) establishes this Privacy Policy (hereinafter the “Policy”) as set forth below in order to comply with the Act on the Protection of Personal Information (hereinafter the “APPI”) and other relevant laws and regulations, and to ensure the appropriate handling and protection of personal information obtained from customers.

1. Definitions of Personal Information, etc.

  1. In this Policy, “personal information” means personal information as defined in Article 2, Paragraph 1 of the APPI; that is, information relating to a living individual that falls under either of the following:
    1. information that can identify a specific individual by name, date of birth, or other descriptions, etc. contained therein (including information that can be readily collated with other information and thereby identify a specific individual); or
    2. information containing an individual identification code.
  2. “Personal data” under this Policy means personal information constituting a personal information database, etc.
  3. “Retained personal data” under this Policy means personal data that the Company has the authority to disclose, correct, add to, or delete the content of, to cease the use of, to erase, and to cease the provision of to third parties, excluding such data whose existence or non-existence, if made clear, would harm the public interest or other interests, as prescribed by Cabinet Order.

2. Purposes of Use of Personal Information

The Company uses customers’ personal information for the following purposes:

  1. to solicit subscriptions to, and manage, fund interests by the Company;
  2. to provide information on products, services, various campaigns, events, etc. of the Company or its affiliates;
  3. to notify customers of changes to this Policy and various terms, and changes to the Company’s products or service offerings;
  4. to respond to customer inquiries, report on service usage, make emergency contact, and otherwise provide customer support;
  5. to make necessary communications such as maintenance and support of the Company’s services and other important notices;
  6. to verify the identity of a customer or that a person is the customer’s authorized representative;
  7. to conduct questionnaires, market research, marketing, and advertising distribution, etc.;
  8. to improve, plan, and develop the Company’s products and services;
  9. to exercise rights and perform obligations based on contracts with customers or applicable laws; and
  10. for other purposes incidental to the purposes of use stated above.

3. Change of Purposes of Use of Personal Information

Where the Company changes the purposes of use of personal information, it will not do so beyond the scope reasonably deemed to have relevance to the purposes of use prior to the change, and it will notify customers of, or publicly announce, the changed purposes of use.

4. Method of Acquiring Personal Information

The Company acquires personal information appropriately and will not acquire it by deceit or other wrongful means.

5. Restrictions on the Use of Personal Information

The Company will not handle personal information beyond the scope necessary to achieve the purposes of use without the customer’s consent, except in the following cases:

  1. where based on laws and regulations;
  2. where necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the customer’s consent;
  3. where especially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the customer’s consent; or
  4. where it is necessary to cooperate with a national government organ, a local government, or a party entrusted thereby in performing affairs prescribed by laws and regulations, and obtaining the customer’s consent is likely to impede the performance of those affairs.

6. Provision of Personal Data to Third Parties

  1. The Company will not provide personal data to third parties without the customer’s prior consent, except in the following cases:
    1. where based on laws and regulations;
    2. where necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the customer’s consent;
    3. where especially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the customer’s consent;
    4. where it is necessary to cooperate with a national government organ, a local government, or a party entrusted thereby in performing affairs prescribed by laws and regulations, and obtaining the customer’s consent is likely to impede the performance of those affairs;
    5. where the Company entrusts all or part of the handling of personal data to an external party within the scope necessary to achieve the purposes of use (in such case, the Company will select an entrustee with sufficient security control measures and enter into an appropriate entrustment agreement); or
    6. where personal data is provided in connection with the succession of the Company’s business due to a merger, company split, business transfer, or other reasons.
  2. With the customer’s prior consent, the Company may provide personal data to third parties located in the following foreign country:
    1. Country name
      Republic of Singapore
    2. The personal information protection system of the relevant foreign country
      Please refer to the information provided by the Personal Information Protection Commission at the following link:
      https://www.ppc.go.jp/files/pdf/singapore_report.pdf
    3. Personal information protection measures taken by the third party
      The recipient generally implements measures regarding the handling of personal data at a level equivalent to the measures required of personal information handling business operators in Japan.

7. Security Control of Personal Information

  1. The Company implements appropriate security control measures to prevent the loss, alteration, leakage, etc. of customers’ personal information. For details of the security control measures taken by the Company, please contact the “Inquiry Desk” set forth in Section 10.
  2. The Company educates all officers and employees who handle customers’ personal information on the importance of personal information protection, and where it entrusts the handling of customers’ personal information, it appropriately supervises the entrustee.

8. Disclosure, etc. of Retained Personal Data

With respect to retained personal data held by the Company, if the Company receives a request from the customer in person for the disclosure, correction, deletion, suspension of use, suspension of provision to third parties, or disclosure of third-party provision records, etc. of his or her own retained personal data (hereinafter “Disclosure, etc.”), the Company will respond without delay after confirming that the request is made by the customer in person. However, this does not apply where the Company is not obligated to make a Disclosure, etc. under the APPI or other laws and regulations. If the Company decides not to make a Disclosure, etc., it will notify the customer in person to that effect without delay. For requests for Disclosure, etc., please contact the “Inquiry Desk” set forth in Section 10.

9. Use of Cookies, etc.

In its services, the Company may acquire and use customers’ cookie information, etc. in order to provide better services. Customers can disable cookies by changing their web browser settings. However, if cookies are disabled, some functions of the Company’s services may become unavailable.

10. Inquiries

Please direct requests for Disclosure, etc. of personal information, opinions, questions, complaints, and other inquiries regarding the handling of personal information to the desk below.

Personal Information Inquiry Desk
info@cygnos.capital

11. Changes to this Privacy Policy

The Company reviews the operational status of its handling of personal information from time to time, strives for continuous improvement, and may change this Policy as necessary. When this Policy is changed, the Company will publicly announce or notify the details of the change via its website or otherwise.

End.
Established: August 23, 2022

Cygnos Capital
105 Cecil Street, #24-02 The Octagon, Singapore 069534
Director  Hiroyuki Mihara