SHIFT Growth Capital Inc. (hereinafter referred to as the “ Company”) understands the purpose of the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”) and recognizes its social responsibility to use and manage personal information appropriately. Company have therefore established a Privacy Policy (hereinafter referred to as the “Policy”), and all of our employees understand the importance of protecting personal information, and Company will make every effort to ensure that the Policy is thoroughly understood by all of our employees.

1. Personal Information to be collected and method of collection

In this Policy, “Personal Information” means information about individuals as defined in the Personal Information Protection Law that Company collect in accordance with this Policy. The personal information Company collect in the service we provide (hereinafter referred to as the “Service(s)”) is as follows;

• Profile information such as name, date of birth, gender, occupation, etc.
• Contact information such as e-mail address, telephone number, and address
• Still image information including the customer’s portrait
• Details of inquiries (e.g., company details)
• Details of questions asked in seminars, questionnaires, etc.
• Information entered or transmitted by the customer through input forms or other methods determined by Company

2. Purpose of use

The specific purposes for which Company use Personal Information are as follows;

1. (1) For applications, consultations, sending of materials, and inquiries regarding seminars and events operated by or involving Company
2. (2) To send requested materials, questionnaires, etc.
3. (3) To disseminate information related to M&A and PMI (meaning for advertising, publicity, and sales promotion activities for services operated by Company and its group companies, including use for information analysis and marketing purposes)
4. (4) For public relations and investor relations activities of Company or its group companies
5. (5) To provide information on Company’s services and to respond to inquiries, etc.
6. (6) For employment selection activities
7. (7) To execute contracts with customers and business partners and provide support
8. (8) To manage the history of customers who visit our office
9. (9) To respond to any violations of Company’s terms and conditions, policies, etc. regarding the Services.
10. (10) To notify you of changes to this Policy or other terms and conditions of our services.

3. Method of notification, publication, or obtaining consent, and method of requesting cessation of use

Customers may request discontinuation of the collection or use of all or part of their Personal Information by making the prescribed settings for Services, in which case Company will promptly discontinue the use of such information in accordance with our stipulations. In addition, since the collection or use of some items of Personal Information is a prerequisite for Services, Company will stop the collection or use of such information only when the customer cancel your membership to Services in accordance with our prescribed method.

4. Existence of external transmission, provision to third parties, and information collection modules

Company may use cookies, web beacons, etc. to improve the usability of Services, to deliver advertisements, and to obtain statistical data, and to obtain usage and attribute information. Please be aware, however, that the customers may not be able to use some of our services if you have set your browser to disable cookies, web beacons, etc.

5. Provision to third parties

Company will not provide Personal Information to any third party (including parties located outside Japan) without obtaining prior consent from the customer. However, Company will not provide Personal Information to third parties (including parties located outside of Japan) without the prior consent of the customer. However, Company will not provide Personal Information to third parties (including those located outside of Japan) for the following reasons;

1. (1) When Company outsource all or part of the handling of Personal Information within the scope necessary to achieve the purpose of use.
2. (2) When Personal Information is provided as a result of the succession of business due to merger or other reasons
3. (3) When it is necessary to cooperate with a government agency, a local government, or an individual or entity entrusted by either a government agency or local government to execute affairs prescribed by law, and obtaining customer consent is likely to impede the execution of such affairs.
4. (4) Other cases permitted under the Personal Information Protection Law or other laws and regulations.

6. Joint use

Company will jointly use customers’ Personal Information as follows

(1) Items of Personal Information to be jointly used

Information specified in section 1.

(2) Scope of joint use

(i) SHIFT Inc. (ii) Subsidiaries and Affiliated companies of SHIFT Inc.

(3) Purposes of joint use

Same as the purpose specified in Section 2

(4) Name of the person responsible for the management of personal information

Hidetaka Kojima (Representative Director)

7. Disclosure of Personal Information

When a customer requests disclosure of Personal Information in accordance with the provisions of the Personal Information Protection Law, we will disclose the Personal Information to the customer without delay after confirming that the request is made by the customer himself/herself (if the relevant Personal Information does not exist, Company will notify the customer to that effect). (If such Personal Information does not exist, Company will notify the customer of such fact. However, this does not apply to cases in which Company are not obligated to disclose the information under the Personal Information Protection Law or other laws and regulations. Please note that a fee (1,000 yen per case) will be charged for the disclosure of Personal Information.

8. Correction and suspension of use of Personal Information

8-1 If a customer requests Company to correct the content of his/her personal information in accordance with the provisions of the Personal Information Protection Law because (1) the Personal Information is untrue, or (2) the Personal Information has been handled beyond the scope of the purpose of use publicly announced in advance or has been collected through deception or other wrongful means, Company will conduct the necessary investigation without delay after confirming that the request is made by the customer. If a customer requests that Company stop using his/her personal information in accordance with the provisions of the Personal Information Protection Law, Company will conduct the necessary investigation without delay after confirming that the request is made by the customer himself/herself, and based on the results, Company will correct the content of the Personal Information or stop using it, and notify the customer to that effect. If Company decide not to correct or suspend the use of Personal Information, Company will notify the customer to that effect.
8-2 If a customer requests deletion of his/her Personal Information, and Company deem it necessary to comply with the request, Company will delete the Personal Information after confirming that the request is made by the customer himself/herself, and notify the customer to that effect.
8-3 The provisions of 8-1 and 8-2 do not apply in cases where Company are not obligated to correct or suspend the use of Personal Information under the Personal Information Protection Law or other laws and regulations.

9. Contact for inquiries

Please direct any comments, questions, complaints, or other inquiries regarding the handling of Personal Information to the following contact point.

　Azabudai Hills Mori JP Tower, 1-3-1 Azabudai, Minato-ku, Tokyo 106-0041, Japan
　SHIFT Growth Capital Inc.
　Contact: shift-gc-info@shiftinc.jp

10. Procedures for Changing the Privacy Policy

Company will change this Policy as necessary. However, in the event that Company modifies this Policy in such a way that the consent of the customer is required by law, the modified Policy shall apply only to those customers who have consented to the modification in the manner prescribed by Company. In the event that Company changes this Policy, Company shall make known or notify customers of the effective date and content of the changed Policy by displaying the revised Policy on Company’s website or by any other appropriate means.

[Established on March 24, 2022]