1. Our personal information protection policy

Endeavour United shall comply with the laws and regulations regarding protection of personal information such as the "Act on the Protection of Personal Information" of Japan, guidelines issued by the government authorities in charge as well as Authorized Personal Information Protection Commission's policy and the Policy.

2. Acquisition of personal information

Endeavour United shall acquire personal information through appropriate and fair means.

3. Utilization of personal information

Endeavour United shall utilize personal information only for the purpose of our operation with regard to the following businesses :

Investment business, moneylending business, investment fund management, management consulting business, credit management consulting business, credit research, M&A business, asset trading, capital participation, advisory and arrangement on business tie-ups and merger, recruitment, general worker dispatch business based on Manpower Dispatching Business Act, credit business including funding, financial guarantee and receivables purchase, trading, brokerage and appraisal of real estate, investment advisory business, investment advisory and agency business, private offering of collective investment schemes, associated or related businesses of each of the preceding items.

4. Provision of personal information to third parties

Unless specifically allowed by the law, we will not disclose or provide our customer's personal information to any third parties without the customer's prior consent.

5. Sharing of personal information

Endeavour United shall share personal information among our related companies only if necessary subject to the conditions as specified below:

1. Items of the personal information to be shared
   Name, address, date of birth, title, telephone number and email address
2. Scope of companies that share the personal information with Endeavour United
   Related companies of Endeavour United (i.e. Phoenix Capital Co., Ltd. and PA Investment Advisors Co., Ltd.) as well as subsidiaries of Endeavour United and its related companies as named above.
3. Utilization purpose
   Same as stipulated in item 3 "Utilization of personal information"
4. Supervise of sharing information
   Endeavour United.

6. Safety control measures

To prevent a leakage of personal information, we implement necessary and appropriate safety control measures and monitor our management and employees appropriately.

7. Continuous improvement

Endeavour United shall review our privacy information control program with consideration of our customer's opinion to improve this program continuously.

8. Request for disclosure of personal information

Endeavour United will accommodate with individual requests for information regarding utilization purpose, disclosure, correction, deletion, disconnection, and suspension to provide information to third parties. For details, please contact us as mentioned below. Please be noted that we may charge a certain fee for such requests.

9. Claims

Endeavour United will deal with claims by our customers on handling of personal information promptly and sincerely. For claims, kindly contact to the person in charge as mentioned below.