AtoG Capital Inc. (the “Company”) recognizes the importance of protection of personal information and has established the following privacy policy (this “Policy”) to ensure that all employees of the Company are well-informed of and comply with this Policy.

1. Compliance with Laws and Regulations Concerning the Protection of Personal Information

The Company complies with the Act on the Protection of Personal Information and all other applicable laws, regulations, guidelines, etc. related to handling of personal information.

2. Purposes of Utilization of Personal Information

The Company uses collected personal information for the following purposes.

i. Business related to acquisition and hold of securities.

• ・To compose, operate, and manage fund.
• ・To search and study potential investee companies and make decisions regarding investment execution.
• ・To manage investee companies and cultivate and advise on business.
• ・To perform internal research on investee companies and create research documents.

ii. M&A brokerage and advisory business, etc. entrusted to the Company and the Group Companies

• ・To perform M&A brokerage and advisory services, corporate valuation services, management consulting services, and other services (the “Provided Services”) that are or may be entrusted to the Company and Nihon M&A Center Holdings, Inc., the consolidated subsidiaries and equity method affiliates of Nihon M&A Center Holdings, Inc. as stated in the annual securities reports and other documents of Nihon M&A Center Holdings, Inc. (the “Group Companies”, exclude the Company).
• ・To accept consultation and applications, send materials, and respond inquiries regarding the Provided Services, as well as seminars and other projects operated by or involving the Company and the Group Companies.
• ・To manage the execution and termination of various contracts, as well as the post-merger management after the termination of transactions.
• ・To offer the Provided Services appropriately and smoothly.

iii. Recruitment and selection activities, etc. (Limited to personal information obtained from directors, employees, and applicants for employment)

• ・Recruitment and selection activities of the Company and the Group Companies.
• ・Business and employment management and communication with directors, officers, and employees (including unofficial employment offers and retirees)

iv. Others

• ・To provide information on the services of the Company, the Group Companies, and the business partners of the Company and the Group Companies.
• ・To promote and educate the public on the Provided Services, fund business, and M&A and succession of business of the Company and the Group Companies.
• ・Public relations and investor relations activities of the Company and the Group Companies.
• ・To appropriately carry out the business management operations of the Company and the Group Companies, including the identification and management of various risks.
• ・To execute supplemental or related tasks of the items mentioned above.

v. Personal information obtained from outsourcing business from third parties will be utilized and handled within the scope necessary to carry out the outsourcing business.

3. Basic Principles regarding Acquisition, Use, and Provision to Third Parties of Personal Information

i. Principles when acquiring personal information directly
The Company will acquire personal information through legal and fair means.

ii. Principles regarding the handling of personal information in the case of outsourcing business from third parties
Personal information obtained from outsourcing business from third parties will be strictly managed and used only for the purposes stated at the time of acquisition and within the scope of the outsourcing business.
We will maintain the confidentiality of personal information, and stipulate and comply with the method of handling personal information at the end of the contract.

iii. Principle of outsourcing business to third parties
We may outsource the handling of personal information to third parties who are obligated to maintain confidentiality with us and the Group Companies to the extent appropriate for business operations, and we will appropriately supervise such third parties.

4. Provision of Personal Information to Third Parties

We will not disclose or provide personal information we have obtained to any third party without prior consent of the individual, except as required by law.

5. Joint Use of Personal information

We will jointly use personal information as set forth below.

i. Items of personal information to be shared
Name, date of birth, address, telephone number, e-mail address, name of the company where the person works or holds shares, corporate information regarding the company, position, interests, and other information that can identify a specific individual.

ii. Scope of joint users
・The Group Companies
・Third parties who provide services or plan seminars, etc. jointly with the Company or the Group Companies (including the person who introduced you to the Company when you applied for the service)

iii. Purpose of use
・To perform business described in 2.ii with the joint users described in ii above.

iv. Name of party responsible for the management of personal information
・Company Name: Nihon M&A Center Holdings, Inc. AtoG Capital
・Address: 24F TEKKO BUILDING 1-8-2, Marunouchi, Chiyoda-ku, Tokyo, Japan, 100-0005
・Representative Director and President
Otsuki Masahiko

6. Appropriate Management of Personal Information

We will endeavor to keep acquired personal information accurate and up-to-date to the extent necessary to achieve the purposes for which it is used.
We will establish basic policies to prevent personal information from unauthorized access, lost, destruction, alteration, or leakage, maintain disciplines regarding handling of personal information, and take reasonable and appropriate security measures such as systematic security control measures, human security control measures, physical security control measures, and technical security control measures.
We will appoint a person in charge of handling personal information, and will take appropriate action in response to updates, corrections, storage, complaints, and other inquiries we receive regarding personal information.

7. Improvements and Review of Handling Personal Information

The Company reviews the handling of personal information, its management system, and efforts for the protection of personal information to attain continuous improvement.

8. Procedures of Request for Disclosure, etc.

In principle, notifications of purpose of use, requests for disclosure, corrections and add-on and deletions of personal information, suspension of use, or requests for erasure (the "Requests for Disclosure, etc.") will be accepted by mail.
After filling out the form prescribed by the Company and providing the identity verification documents prescribed by the Company, we will respond in accordance with the law upon confirming that the applicant is the person himself/herself (or his/her agent), specify the target data, and other requirements of the Requests for Disclosure, etc.
We will stop delivering direct mail once we receive such a request from the person himself/herself.

9. Contact Information

i. Mailing address
24F TEKKO BUILDING 1-8-2, Marunouchi, Chiyoda-ku, Tokyo, Japan, 100-0005
AtoG Capital Inc.
General Administration Department

ii. Telephone number
Main TEL: 03-6777-5054 (Available from 9AM to 5:30PM during weekdays)
AtoG Capital Inc.

Enacted September 17, 2024.