In this privacy policy, “UMI” refers to both Universal Materials Incubator Co., Ltd. and UMI Growth Capital Co., Ltd.

UMI sometimes receives personal information (as defined in Article 2, Paragraph 1, of the Act on the Protection of Personal Information (hereinafter, the “Personal Information Protection Act”); the same definition applies hereinafter) from our business partners in relation to our investment business, fund management business and other businesses. UMI deeply understands the importance of protecting the personal information of our business partners, and believes that building a good relationship with our business partners is impossible without protecting their personal information. In order to further deepen the relationship of mutual trust with our business partners, we hereby set out UMI’s privacy policy.

  1. UMI will not use the acquired personal information of our business partners for any purposes other than those stated below.
    1. i.to find potential companies to invest in;
    2. ii.to consider and determine the possibility of potential investment in those companies;
    3. iii.to cultivate and support investing firms;
    4. iv.to process administrative works related to the formation, solicitation and management of funds;
    5. v. to verify the identity of a contributor to a fund or a contributor’s agent;
    6. vi.to report results of fund management, etc. to its contributors;
    7. vii.to obtain and dispose of securities through a fund;
    8. viii.to exercise rights and perform obligations under applicable law , ordinance, or agreements as well as to conduct other administrative works in relation to investment or a fund;
    9. ix.to provide services on “Deal Flow Database” (“DFD”), a website offered by UMI, as well as follow-up services related to DFD;
    10. x.to provide services on “Material Connect” (“MC”), a website offered by UMI, as well as follow-up services related to MC;
    11. xi.to conduct market research, data analysis and surveys;
    12. xii.to conduct administrative works, such as those in relation to various types of events UMI holds;
    13. xiii.to comply with applicable laws and regulations related to our business;
    14. xiv.to make decisions related to personnel recruitment;
    15. xv.to properly conduct employment management;
    16. xvi.to manage the operations of affiliated companies;
    17. xvii.to deal with complaints and inquiries; and
    18. xviii.to adequately perform transaction with our business partners.
  2. UMI will not disclose or provide our business partners’ personal data (Refers to personal information, such as that comprising personal information databases, as defined in the Personal Information Protection Act. Same applies below.) to any third parties except with the consent of the owner of the data or when it is permitted by laws or ordinances. However, “joint use” is not considered “disclosure or provision to a third party.”
  3. UMI will jointly use personal data in accordance with the following:
    1. i.Type of jointly used personal data: Contact information such as name, address, company, telephone number and e-mail address
    2. ii.Scope of persons participating in joint use:
      1. (a) UMI’s affiliated companies (as defined in Article 8, Paragraph 8 of the Regulation on Terminology, Forms, and Preparation Methods of Financial Statements; for the scope of applicable affiliated companies, please refer to the link below.)
      2. UMI Growth Capital Co., Ltd.
    3. iii.Purpose of use by persons participating in joint use:
      Same as the purposes of use stated in section 1
    4. iv.Name, address, and representative of party responsible for the management of jointly used personal data:
      Universal Materials Incubator Co., LTD. (Please refer to the “Company" page.)
      UMI Growth Capital Co., Ltd. (Please refer to the “Company" page.)
  4. If, as a business partner, you wish to check, disclose (including disclosure of records provided by a third party), amend, delete, add to, terminate use of, or erase your own personal information, UMI will disclose the information upon submission of the documents which we specify. For information on how to obtain those documents, including disclosure request forms, please contact us at the number provided in Section 5. below. If you wish to request the disclosure of information, please have I.D. (such as a driver’s license) ready to identify yourself. If use of information is terminated, or if information is erased, regretfully, UMI may be unable to provide services in keeping with your requirements, so we ask that you keep this in mind when making these requests.
  5. If you have any inquiries, complaints and other questions regarding the handling of personal information by us, please contact us at the number provided below:
    Partner in charge of the Management Division, Universal Materials Incubator Co., LTD. (Tel 03-5148-5241)
    Available on Weekdays 10:00 am - 3:00 pm (except on New Year’s holiday season)
  6. UMI complies with the Act on the Protection of Personal Information, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures and other laws and regulations of Japan relating to the handling of personal information, related guidelines and other rules.
  7. UMI endeavors to develop the internal system for the appropriate handling of personal information, and take appropriate safe management measures in order to prevent hazard to personal information such as divulgation, manipulation and loss. For inquiries regarding safety management measures implemented by UMI, please contact the party indicated in 5. above.
  8. UMI periodically audits the handling of personal information and consistently endeavor to improve our operation.

    9. Revised on December 2, 2025