Chartered Innovation Nexus Co., Ltd. (the “Company”) recognizes that the proper protection of personal information relating to our clients, business partners, investors, portfolio companies, job applicants and all other persons with whom we have a relationship is an important responsibility.
The Company complies with the Act on the Protection of Personal Information and other applicable laws, regulations and guidelines, and appropriately manages and uses the personal information it obtains.
1 – Personal Information We Collect
The Company collects the following personal information to the extent necessary for the conduct of its business.
(1) Information relating to customers and investors
· Name
· Address
· Date of birth
· Telephone number
· Email address
· Employment information
· Nationality
· Information relating to investor classification
· Information stated in identity verification documents
· Tax-related information
· Bank account information
· Information necessary for screening against organised crime groups and other anti-social forces
· Information necessary for anti-money laundering measures
(2) Information relating to portfolio companies and business partners
· Company name
· Location
· Name of representative
· Contact person information
· Financial information
· Legal information
· Shareholder information
· Business information
· Other information necessary for due diligence or investment decisions
(3) Information relating to website users
· IP address
· Cookie information
· Device information
· Access logs
· Details of enquiries
2 – Purpose of Personal Information Use
The Company uses the personal information it obtains for the following purposes.
Fund management and investment-related activities
· Investor solicitation and investor administration
· Formation, operation and administration of funds
· Payment of distributions
· Reporting to investors
· Assessment and review of investment opportunities
· Execution of investments and post-investment monitoring
· Collaboration with and support for portfolio companies
Legal and regulatory compliance
· Compliance with the Financial Instruments and Exchange Act
· Compliance with the Act on Prevention of Transfer of Criminal Proceeds
· Identity verification and Know Your Customer procedures (KYC)
· Anti-money laundering and countering the financing of terrorism measures (AML/CFT)
· Screening against sanctions lists and similar databases
· Reporting to regulatory and supervisory authorities
· Tax, accounting and audit-related matters
Consulting and advisory services
· Performance of outsourced service agreements
· Provision of various forms of advice
· Mergers and acquisitions support services
· Fundraising support services
· Business development activities and customer relationship management
Other purposes
· Responding to enquiries
· Providing information about seminars, events and similar activities
· Service improvement and quality enhancement
· Recruitment and candidate selection
· Exercise of contractual rights and performance of contractual obligations
3 – Appropriate Collection of Personal Information
The Company collects personal information through lawful and fair means.
4 – Provision of Personal Information to Third Parties
The Company will not provide personal information to third parties without obtaining the prior consent of the individual concerned, except in the following cases:
· Where the provision is required or permitted by law
· Where the provision is necessary to protect the life, physical wellbeing or property of an individual
· Where cooperation with a national government authority, local public authority or similar body is required
· Where information is provided to a service provider to the extent necessary for the performance of outsourced
services
· Where otherwise permitted under the Act on the Protection of Personal Information or other applicable laws
and regulations
5 – Provision of Personal Information to Service Providers
The Company may outsource the handling of personal information to external service providers where necessary to achieve the purposes described above. The Company’s principal categories of service providers include:
· Fund administrators
· Trust banks
· Securities firms
· Financial institutions
· AML/KYC service providers
· Cloud service providers
· Accounting firms
· Audit firms
· Law firms
· Tax accounting firms
· IT system operators and service providers
The Company exercises appropriate supervision over these service providers.
6 – Handling of Personal Information Outside Japan
In connection with its international investment activities and business operations, the Company may store or transfer personal information outside Japan.
In such cases, the Company will implement appropriate security control measures in accordance with the Act on the Protection of Personal Information and other applicable laws and regulations. For further details of these measures, please contact the enquiry point set out in Section 12 below.
The Company also takes necessary and appropriate measures after obtaining an understanding of the applicable foreign legal systems, personal information protection regimes and other relevant external conditions in foreign countries where personal information is handled.
The Company may provide personal information, to the extent necessary, to overseas portfolio companies, co-investors, fund administrators, professional advisers and other relevant parties.
7 – Information Relating to Investment Opportunities and Due Diligence
In the course of evaluating investment decisions, M&A transactions, capital alliances and other similar transactions, the Company may collect personal information relating to portfolio companies, target companies, members of management, shareholders and other relevant parties.
The Company uses such information for the following purposes:
· Investment decisions
· Risk assessment
· Due diligence
· Contract negotiations
· Post-merger integration (PMI)
· Legal and regulatory compliance
8 – Use of Cookies and Similar Technologies
The Company’s website may use cookies and other similar technologies to analyse usage and improve its services.
Users may restrict or refuse cookies through their browser settings.
9 – Security Control Measures
The Company implements organisational, personnel, physical and technical security control measures to prevent the leakage, loss, damage, unauthorised access, or other improper handling of personal information.
Specifically, the Company establishes an internal management framework for personal information protection; provides training to its officers and employees; manages access permissions; implements authentication and security measures in cloud services such as Microsoft 365; appropriately supervises service providers; and takes other necessary measures.
Where personal information is stored or transferred outside Japan,the Company implements appropriate security control measures after obtaining an understanding the personal information protection regime and other external conditions of the relevant country.
For further information about the security control measures implemented by the Company, please contact the enquiry point set out in Section 12 below.
10 – Requests Concerning Retained Personal Data
In accordance with applicable laws and regulations, an individual may make the following requests to the Company:
· Notification of the purposes of use
· Disclosure of personal information or records concerning its provision to third parties
· Correction, addition or deletion
· Suspension of use
· Erasure
· Cessation of provision to third parties
The Company will respond within a reasonable period after verifying the identity of the individual making the request.
11 – Retention Period for Personal Information
The Company retains personal information for the period required by applicable laws and regulations and for the period necessary to achieve the purposes of use for which the information was obtained. After the applicable retention period expires, the Company will delete or dispose of the personal information by appropriate means.
12 – Enquiries
For enquiries regarding personal information, please contact:
Chartered Innovation Nexus Co., Ltd.
Person Responsible for Personal Information Protection
Email: info@charterednexus.co.jp
13 – Amendments to this Privacy Policy
The Company may amend this Privacy Policy as necessary due to changes in applicable laws and regulations, changes in its business activities or where otherwise necessary. Any amended Privacy Policy will take effect when it is published on the Company’s website.
Effective Date: 8 September 2026
Chartered Innovation Nexus Co., Ltd.
Toranomon Towers Office, 6th Floor
4-1-28 Toranomon, Minato-ku, Tokyo, Japan
Representative Director: Azusa Ogawa
* The Japanese version constitutes the official and legally binding text.