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Strategic Capital, Inc.

Privacy Policy

Privacy Policy

On Privacy

Strategic Capital, Inc. (“Strategic Capital”) is committed to protecting your privacy and has established the Privacy Policy (“Policy”) as below in compliance with laws and regulations regarding the protection, collection and/or use of personal information.

Collection and Management of Personal Information

  1. Personal information will only be collected in accordance with laws and regulations, and necessary measures will be taken to ensure that such personal information is accurate and up-to-date.
  2. Personal information will not be used beyond the scope of the purpose for which it was obtained. In addition, personal information will not be disclosed or provided to a third party without the consent of the person unless such disclosure or provision of personal information is required by laws, regulations or other valid reason.
  3. Officers and employees of Strategic Capital are given thorough education to prevent leakage and/or unauthorized use of personal information. In addition,Strategic Capital has established an appropriate management system and appointed an officer responsible for the management and monitoring of such system.
  4. When outsourcing the handling of personal information to a third party, Strategic Capital will be responsible to conduct proper supervision over such third party in order to protect personal information.
  5. When Strategic Capital receives a request for disclosure, correction or suspension of use of personal information by the person, Strategic Capital will respond appropriately to such request in accordance with the laws and regulations.
    In certain circumstances, Strategic Capital may charge the applicable cost for handling these matters.
  6. Strategic Capital is committed to reviewing and improving this policy on a continuous basis in order to handle personal information appropriately

Use of Personal Information

Strategic Capital will obtain and use personal information for the following purposes in order to conduct business as an investment manager, an investment advisor, a Type II financial instruments business and any other related or subsidiary business in accordance with laws and regulations.

  1. To solicitate, sell or provide information regarding the products and services of Strategic Capital, such as discretionary investment contracts and collective investment schemes based on the Financial Instruments and Exchange Act.
  2. To determine the appropriateness of products and services in light of principles regarding suitability and other factors.
  3. To confirm the identity of the clients or agents acting on their behalf.
  4. To convey information to the clients such as transaction results, account balances and investment status.
  5. To conduct administration with respect to transactions with clients and business counter parties.
  6. To exercise rights and fulfill obligations pursuant to contracts with the client and any applicable laws.
  7. To provide information to the shareholders of the investee companies, exercise voting rights or make proxy solicitations.
  8. To research and develop financial products and services through market research, data analysis and questionnaires.
  9. To facilitate transaction with clients and business counter parties appropriately.
  10. To conduct business management and internal control of Strategic Capital.
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