These privacy policies (the "Privacy Policies") clarify that CAT Partners Co., Ltd. ("CAT") complies with the Act on the Protection of Personal Information (the "Act") and other relevant ordinances and guidelines. CAT handles information about a manager member ("Member") which can identify the specific individual ("Member Personal Information") including name, address, e-mail address, telephone number, date of birth and Internet Protocol address which are required in a registration process as a Member of "Hedge Partner Japan Site" (the "Website") and in the course of its operation of CAT's business. Therefore please carefully read and acknowledge the Privacy Policies below which have been included with a view to protecting Member Personal Information as well as ensuring that CAT complies with the relevant legislations.

1. Compliance with Laws and regulations

CAT makes endeavour to ensure that when processing Member Personal Information CAT is protecting both CAT's and Member's interests by complying with the Act and other relevant ordiances and guidelines.

2. The purposes of the use of Member Personal Information

CAT will use Member Personal Information only for the following purposes except circumstances required by regulatory authorities or law enforcement officials who have jurisdiction over CAT, or as otherwise required by any applicable law.

The purposes of the use of Member Perosnal Information:

• To determine with respect to the eligibility and suitability as a Member of the Website
• To determine with respect to the eligibility and suitability to renew a Member of the Website
• To develop and improve the Service provided by CAT in the Website or else by analyzing data, by researching the market and by conducint surveys
• To develop and improve the Service provided by CAT in the Website or else by analysing access including behaviour pattern analysis in the homepage and the Website, or by obtaining Internet Protocol Address
• To administer the Website and improve its system, design, services and functionality
• To prevent fraud, unauthorized transactions and liability; and
• To verify an identification of Member or Member's representative

3. Security of Member Personal Information

• CAT has adopted generally and economically accepted standards of technology and operational security in order to protect the confidentiality and security of Member Personal Information.
• CAT takes appropriate measures to prevent loss, leakage or damage of Member Personal Information
• CAT handles complaints from a Member with respect to Member Personal Information in an appropriate and a prompt manner
• CAT works on continuous improvement of its policies to protect Member Personal Information
• CAT never uses Member Personal Information besides the purposes mentioned above or makes public without obtaining Member's consent in advance except when required by regulatory authorities or law enforcement officials who have jurisdiction over CAT, or as otherwise required by any applicable law

If it is found that Member Personal Information submitted by a Member is not properly updated or changed without reporting to CAT, CAT will discard Member Personal Information in an appropriate way. Please acknowledge that in such a case a Member is required to resubmit Member Personal Information to CAT for

4. Member Personal Information to any third parties

CAT never offers and provides any third parties Member Personal Information without obtaining Member's consent in advance except when required by regulatory authorities or law enforcement officials who have jurisdiction over CAT, or as otherwise required by any applicable law.

5. Management of Member Personal Information

CAT has taken appropriate security measures to prevent unauthorized access, loss, leakage or damage of Member Personal Information. CAT makes endeavour to assume Member Personal Information to be accurate and updated.

In accordance with "Cabinet Office Ordinance Concerning the Financial Instruments Business," CAT takes proper measures to ensure that CAT does not use Member Personal Information including race, creed, family origin, domicile, special information that is not learned or obtained in other business or information disclosed about criminal records or health information for any purposes other than deemed necessary for the operation of CAT business.

CAT establishes internal guidelines how to manage, handle and use Member Personal Information including the purposes of the use of Member Personal Information and complies with the guidelines.

If a Member inquiries about Member Personal Information or wishes to correct, add or delete Member Personal Information, CAT processes the inquiries or the requests with proper investigations in a prompt manner.

6. Training and supervision over the employees to ensure the security control of Member Personal Information

All management members and regular employees at CAT understand the importance of Member Personal Information. CAT provides necessary and appropriate training, education and supervision over the employees to ensure the security control and the handling of Member Personal Information. CAT reviews the system of management for protection of Member Personal Information for further improvement.

If, at any time, CAT adopts any material changes to the Privacy Policies, CAT shall provide each Member with a revised notice reflecting new Privacy Policies. If you have any questions or concerns, or request to correct or delete regarding your Member Personal Information kept by CAT, please contact us at info@catpartners.co.jp.