Privacy Policy

For the purpose of Alternative Investment Capital Limited (hereinafter referred to as “Company”) to appropriately protect the information that can be used to identify specific individuals, such as our clients, (hereinafter referred to as “Personal Information”) and respond to the trust of the shareholders, fund investors, companies we have invested in and other parties, each and every officer and employee of the Company shall be responsible for executing appropriate information management and strive to ensure this policy functions effectively.

  1. The Company shall, in order to realize value creation through private equity, use Personal Information for the following purposes in relation to the formation of funds, investments, increasing the value of the companies we have invested in, and collecting the return of investments.

(1) Formation and operation of funds and the business operations related or ancillary thereto

(2) Investment advisory business, business operations concerning investment advisory agreements, and other business operations the Company is permitted to conduct by relevant laws and regulations and guidelines from supervising authorities, as well as the business operations ancillary thereto

(3) Other business operations the Company is permitted to conduct by relevant laws, regulations and guidelines from supervising authorities and the business operations ancillary thereto (including business operations that the Company will be permitted to conduct in the future)

(4) Otherwise for appropriate and efficient performance of transactions with our clients

  1. The Company shall strive to maintain Personal Information as accurate and up-to-date as possible, and if the Company no longer needs to use such information, it shall strive to delete such Personal Information without delay. In addition, for the purpose of preventing leakage of Personal Information, the Company shall implement the necessary and appropriate safety management measures and, at the same time, supervise its officers and employees accordingly.
  2. The Company shall, for the purpose of proper handling of Personal Information, strive to revise as necessary and continue to improve this Policy.
  3. How Personal Information is acquired
    The Company shall acquire clients’ Personal Information in accordance with the laws, regulations and guidelines from supervising authorities, through appropriate methods. Specifically, the Company shall acquire information through transactional documents, such as confirmation forms and contracts, as well as through questionnaires, the Internet, postal mail, telephone calls, and information acquired in accordance with the principle of suitability based on the consent of the client.
  4. The Company shall not provide Personal Information provided by clients to any third party without consent from the subject individual except the following cases.

(1) When required based on laws, regulations and guidelines from supervising authorities

(2) When it is necessary for protecting the life, physical wellbeing, or property of an individual, and it is difficult to obtain consent from the client

(3) When it is deemed especially necessary for improving public health or promoting the wellbeing of children, and it is difficult to obtain consent from the client

(4) When it is necessary to cooperate with the national or local government in relation to carrying out the operations stipulated by laws, regulations and guidelines from supervising authorities and obtaining consent from the client may hinder the performance of such operations

(5) When all or part of the handling of Personal data(“Personal data” means Personal Information constituting a personal information database etc. within the Company) is subcontracted to the extent necessary for achieving the purpose of use

(6) When information is provided to a person within the scope of the following joint users

(a) Personal data items to be jointly used
Name, address, telephone number, email address, and other basic information, as well as information concerning investments, such as the number of shares held

(b) Scope of joint users
The scope of parties with whom the Company jointly uses the information is as follows:

(Company names)

– The Company’s shareholders (see here for a list of the Company’s shareholders)

– T&D Asset Management Co., Ltd.

– Sumitomo Mitsui DS Asset Management Company, Limited.

– AIC Private Equity Fund General Partner Limited.

(c) Purpose of joint use
As with the purpose of use stated in 1 in the above.

(d) Information manager in the case of joint use
Alternative Investment Capital Limited

  1. When subcontracting the handling of personal data to a third party, the Company shall conduct a strict investigation of the third party and supervise the third party to ensure it thoroughly conducts appropriate management of personal data, such as maintaining confidentiality.
  2. The Company accepts client requests for disclosure, correction, suspension of use, and suspension of provision to third parties (hereinafter referred to as “Disclosure”) in relation to the personal data acquired by the Company. Concerning the specific procedures for requesting Disclosure, please see “Procedure for requesting disclosure, correction, deletion, and suspension of use.

Procedure for requesting disclosure, correction, deletion, and suspension of use


The following is the procedure used by the Company to notify the client of the purpose of use of the personal data acquired by the Company, disclose or correct the data, and suspend the use or provision to third parties (hereinafter referred to as “Disclosure”) in response to the request received from the client.

1.   Personal data acquired by the Company that is subject to Disclosure

The Personal Information subject to Disclosure shall be limited to the Personal Information acquired by the Company for which the Company has the authority for Disclosure (hereinafter referred to as “Acquired Personal Data”).

2. Consultation desk for Disclosure and complaints

The following is the Company’s consultation desk for requesting Disclosure of Acquired Personal Data and filing complaints concerning the handling of Acquired Personal Data.

(a) Address

Alternative Investment Capital Limited,

Personal information protection consultation desk

1-8-2 Marunouchi, Chiyoda-ku, Tokyo 100-0005 Japan

(b) Telephone number

+81-3-5218-5230

(c) Open hours

Monday to Friday, 9:30 AM to 5:00 PM (excluding Japanese public holidays and New Year’s Holidays)

3. Procedure for requesting Disclosure

  (1) Postal mail to the personal information consultation desk

Please enclose the following documents and mail them to the consultation desk.

(a) “Request for Disclosure of Acquired Personal Data” (Download the form from “6 Request form” below)

(b) Identify verification documents (See (2) below. When a proxy makes the request, the document in (4) below is also required.)

(c) Postal money order equivalent to the amount of processing fee (See (3) below.)

  (2) Identity verification documents

To verify the identity of the client, mail a copy of the following identity verification documents.

(a) Send a copy of a photo identification document issued by a public agency, such as a driver’s license, passport, residence card, special permanent resident certificate, or individual number card (do not send a copy of the page containing the individual number). Only a copy of one form of such identification is necessary.

(b) Send a copy of two identification documents without a photograph issued by a public agency, such as the health insurance card or Pension Handbook.

  (3) Processing fee

A fee of 1,000 Japanese Yen (including tax) is required for each request. Please send a postal money order with fixed amount (issued by the Japanese Post Office) for 1,000 Japanese Yen along with the request form (if making multiple requests at the same time, send a postal money order with fixed amount equivalent to the total amount). Please note the processing fee will not be refunded even if the Company is unable to respond to the requested Disclosure.

  (4) Requests for Disclosure through a legal representative / proxy

When the person requesting Disclosure is a legal representative of the subject individual, such as a minor or adult ward, or a proxy appointed and entrusted by the subject individual, please mail the documents stated in (a) and (b) below along with the identity verification documents in (2) above.

   (a) Document confirming the proxy

i. In the case of a legal representative

i) In the case of a minor: Abstract of the family register of the subject individual or a copy of a health insurance card stating the dependent family members

ii) In the case of an adult ward: Certificate of the registered matters set forth in Article 10 of the Act on Guardianship Registration

ii. In the case of a proxy: The letter of proxy and the seal registration certificate of the subject individual

   (b) Identity verification documents to verify the identity of the legal representative / proxy

Please also mail the identity verification documents stated in (2) above regarding the legal representative / proxy.

4. Cases in which it is not possible to respond to the request

In the cases described in the following (1) to (3), the Company will be unable to respond to the request from the client.

  (1) When the request cannot be accepted due to an error in the request

In the following cases, the request cannot be accepted. Please correct the error and resubmit the request form in accordance with the procedure designated by the Company.

(a) When the request form designated by the Company is not used

(b) When a required document is not submitted

(c) When the identity of the client cannot be verified based on the matters stated in the request form;

(d) When it is not possible to confirm that the request has been made by the subject individual, such as when there is a discrepancy in the address stated in the request form, address stated in the identify verification document, and the address registered with the Company

(e) In relation to a request through a legal representative / proxy, the proxy cannot be confirmed

(f) Otherwise there is a deficiency in the request document submitted by the client

(g) When the request is made without following the procedure designated by the Company

  (2) Cases when the request for Disclosure will be declined

     i. Notification of the purpose of use

In the following cases, the Company will be unable to notify the purpose of use of the Acquired Personal Data when requested.

(a) When notifying the subject individual the purpose of use or making it public may harm the life, physical well-being, property or other rights and interests of the subject individual or a third party

(b) When notifying the subject individual the purpose of use or making it public may harm the rights or legitimate interests of the Company

(c) When it is necessary to cooperate with the government organization or local government in carrying out the operations stipulated by law and notifying the subject individual the purpose of use or making it public may hinder the performance of such operations

  ii. Disclosure

In the following cases, the Company will be unable to disclose the Acquired Personal Data when requested.

(a) When doing so may harm the life, physical well-being, property, or other rights and interests of a client or a third party

(b) When doing so may significantly hinder the proper implementation of the Company’s business operations

(c) When the disclosure will violate other laws and regulations

(d) When the provisions of other laws and regulations stipulate special procedures for disclosure

  iii. Corrections (correction, addition or deletion)

In the following cases, the Company will be unable to correct the Acquired Personal Data when requested.

(a) When the provisions of other laws and regulations stipulate special procedures for the correction, addition or deletion of such contents

(b) When correction, addition or deletion of such contents is not necessary for achieving the purpose of use of the Acquired Personal Data

  iv. Suspension of use (suspension of use, elimination)

In the following cases, the Company will be able to suspend the use of the Acquired Personal Data when requested.

(a) When, in order to correct a violation, suspension, or use or elimination of part of the subject Acquired Personal Data is sufficient

(b) When it requires a substantial expense to suspend the use or eliminate the data or otherwise when it is difficult to suspend the use, and alternative measures necessary for protecting the client’s rights and interests have been implemented

  v. Suspension of provision to third parties

In the following cases, the Company will be unable to suspend the provision to third parties.

(a) When it requires a substantial expense to suspend the provision to third parties or otherwise when it is difficult to suspend the provision to third parties and alternative measures necessary for protecting the client’s rights and interests have been implemented

5. Notification of the decision for disclosure/ nondisclosure

   (1) Notification of the decision for disclosure of the Acquired Personal Data

When the Company decides to notify the purpose of use of the Acquired Personal Data for which Disclosure has been requested or when it decides to disclose, correct, suspend the use or suspend the provision to third parties all or part of such data, the Company will notify the client or legal representative / proxy who made the request by sending the notification of the decision for disclosure of the Acquired Personal Data.

   (2) Notification of the decision for nondisclosure of the Acquired Personal Data

When the Company decides not to notify the purpose of use of the Acquired Personal Data for which Disclosure has been requested or when it decides not to disclose, correct, suspend the use or suspend the provision to third parties all of such data, the Company will notify the client or legal representative / proxy who made the request by sending the notification of the decision for nondisclosure of the Acquired Personal Data.

6. Request form

 Please download the following request form and fill out the form after confirming matters stated in 1 to 5 above.

->Request for Disclosure of the Acquired Personal Data