Privacy Policy

Effective: September 26, 2022

FIRSTLIGHT Capital, Inc. (hereinafter referred to as “FIRSTLIGHT”) recognizes the importance of protecting personal information of its users. In addition to complying with Japanese law pertaining to the protection of personal information (Act No. 57 of 2003 [effective May 30]; hereinafter referred to as the “Act on the Protection of Personal Information”), FIRSTLIGHT shall endeavour to appropriately handle and protect such information in its possession in accordance with the following privacy policy (hereinafter referred to as the “Policy”). Unless otherwise stated, the terminology used in the Policy shall conform to the definitions set forth in the Act on the Protection of Personal Information.

In order to realize the principles noted below, FIRSTLIGHT shall build a personal information protection management system. FIRSTLIGHT also hereby declares that the entire company will endeavour to continuously improve the system with constant awareness of the latest IT trends and changes in social requirements and business environment. 

Principle 1

FIRSTLIGHT shall endeavour to specify the purpose for which personal information will be utilized. It will not handle personal information that is beyond the necessary scope to fulfill that purpose. FIRSTLIGHT shall also take appropriate measures to achieve this.

Principle 2

FIRSTLIGHT shall observe laws, ordinances, state policies, and other rules and regulations concerning personal information management.

Principle 3

FIRSTLIGHT shall stipulate internal regulations concerning complaints and consultation requests regarding personal information management. FIRSTLIGHT shall respond to such complaints and consultation requests swiftly and in good faith.

Principle 4

FIRSTLIGHT shall endeavour to take necessary and appropriate measures to ensure the security of personal information, including the prevention and correction of instances of personal information leakage, loss, and damage.

Principle 5

FIRSTLIGHT shall stipulate internal regulations concerning personal information protection and make appropriate revisions in a timely manner to promote constant improvements.

Osamu Iwasawa, CEO/Managing Director
FIRSTLIGHT Capital, Inc.
35F Atago Green Hills MORI Tower, 2-5-1 Atago, Minato-ku, Tokyo

1. Definition of Personal Information

The term “personal information” as used in the Policy means information relating to a living individual which falls under any of the following. Furthermore, in the event that the Act on the Protection of Personal Information and any of its relevant laws and ordinances are revised, the definition of the term “personal information” as used herein shall follow such revision(s).

  • Those containing name, date of birth, or other descriptions etc. that can be used to identify an individual (meaning any and all matters stated, recorded or otherwise expressed using voice, movement or other methods in a document, drawing or electromagnetic record) (including information which can be easily combined with other information to identify an individual)
  • Those containing an individual identification code.

2. Purpose of Personal Information Utilization

FIRSTLIGHT uses personal information for the purposes listed below. To the extent that it can reasonably be deemed relevant, FIRSTLIGHT may change the purposes for which it utilizes this information. In such cases, FIRSTLIGHT will promptly issue a public announcement or notify the individual owner of such information (hereinafter referred to as the “Individual”) of such change.

Concerned PartiesPurpose
(a) Current/Prospective Limited Partners– To provide explanations of services related to investment funds, etc. – For administrative purposes related to the establishment and management of investment funds, etc.
(b) Current/Prospective Investee Entities– To collect information necessary for invest decisions and for providing post-investment assistance, to conduct correspondence and respond to inquiries
(c) Individual/Corporate participants of the community which FIRSTLIGHT manages.– To conduct correspondence and respond to inquiries related to the community
(d) Employees and Executive Officers– For managing human resources and labor relations
(e) Job Applicants– For assessment of job applications (including for notifying the applicant with the result of their application, any applicable interview details, or hiring procedures, and for analytical purposes to improve future recruiting assessments)
(f) Business Partners/Subcontractors– For conducting business correspondence, fulfilling contracts, smoothly executing business duties, and managing business partner information
(g) Others (Any other individual or entity whose personal information has been obtained, including via the exchange of business cards with an employee or executive officer of FIRSTLIGHT or through other means, etc.)– To distribute email newsletters or notices regarding reports, events, and seminars from FIRSTLIGHT – For use in improving FIRSTLIGHT’s services, developing new services, etc. – To compile statistical data related to FIRSTLIGHT’s services in a non-personally identifiable manner

3. Proper Acquisition of Personal Information

3.1 FIRSTLIGHT obtains personal information in the proper manner and does not acquire such information by deception or other wrongful means.

3.2 FIRSTLIGHT does not acquire special care-required personal information without first obtaining consent from the concerned Individual to do so, except in the following cases:

  • Cases in which it is permitted by the Act on the Protection of Personal Information or under other applicable laws and regulations;
  • Cases in which such special care-required personal information has already been made public by the Individual, a government organization, a local government, an academic research institution, a person set forth in one of the items of Article 57, paragraph 1, or any other person prescribed by rules of the Personal Information Protection Commission.
  • Cases in which an Individual is visually observed or photographed, and the special care-required personal information is acquired in such a way that is obvious from their external appearance; or
  • Cases in which special care-required personal information is acquired in a manner that is not deemed to constitute provision to a third party under the Act on the Protection of Personal Information.

3.3 Upon receiving personal data (as defined in the Act on the Protection of Personal Information) from a third party, FIRSTLIGHT shall confirm the following in accordance with the rules of the Personal Information Protection Commission. However, this shall not apply to cases in which such personal data is acquired in a manner that is not deemed to constitute provision to a third party under the Act on the Protection of Personal Information.

  • The name or appellation and address of the third party, as well as the name of its representative in the case of a corporation (or the name of its representative or administrator in the case of non-corporate entity with such a position)
  • Circumstances under which the said personal data was acquired by the said third party

4. Secure Management of Personal Information

FIRSTLIGHT supervises its employees to the extent that it is appropriate and necessary to ensure that personal information in its possession is managed securely against risks such as loss, destruction, alteration, and leakage. In cases where the handling of personal information is subcontracted (in part or in whole), FIRSTLIGHT will conduct the necessary and appropriate supervision of such subcontracted third party to ensure that such personal information is securely managed.

For specific details regarding measures taken by FIRSTLIGHT to ensure the secure management of personal data in its possession, please contact its Personal Information Protection Supervisor.

5. Provision of Personal Information to a Third Party

FIRSTLIGHT does not provide personal data to any third parties, except in the following cases:

  • Cases in which prior consent on such action has been obtained;
  • Cases in which such action is conducted in accordance with the Act on the Protection of Personal Information or other applicable laws and ordinances;
  • Cases in which such action is necessary in order to protect individuals from life threats, physical injuries, and property damage, and where there is difficulty in obtaining the Subject’s consent;
  • Cases in which personal information management is outsourced partially or wholly (including server storage, etc.) to an external enterprise in accordance with a business outsourcing contract, FIRSTLIGHT will sign an agreement with the third party concerning personal information management and/or appropriately supervise the third party regarding security management of personal information; or
  • Cases in which business succession has taken place as a result of a merger or acquisition, company split, business transfer, or other action.

6. Use of Cookies and Other Similar Technologies

FIRSTLIGHT may use cookies and other similar technologies on this website. These technologies are used to help FIRSTLIGHT assess demand for its services and improve its services. Users who wish to disable cookies can do so by changing their browser settings. However, please note that doing so may render certain features of the FIRSTLIGHT’s site unusable. 

7. Sharing of Personal Information

In order to provide better services, FIRSTLIGHT will shares personal data with its parent company Uzabase, Inc. and partnership funded by FIRSTLIGHT etc under strict control and with appropriate security measures in place.

Shared Personal Data

Personal data obtained by FIRSTLIGHT such as names, e-mail addresses, genders, phone numbers, dates of birth, addresses, industries of expertise, areas of specialization, brief CVs, career summaries, detailed work histories, employers, and job titles

Scope of Sharing

Uzabase, Inc., FIRSTLIGHT-I Limited Liability Partnership(LLP), UBV Fund-I Limited Partnership(LPS), UBV Fund-I Growth Limited Partnership(LPS), FIRSTLIGHT-Ⅱ Limited Liability Partnership(LLP), UBV Fund-ⅡLimited Partnership(LPS)and any other LLPs and/or funds that FIRSTLIGHT may participate or operate as a partner in the future

Purpose of Shared Usage

Identical to the purpose stipulated in Article 2 of the Policy.

Usage of personal information by Uzabase, Inc. shall be limited to cases in which such usage is required for such purposes as complying with laws and regulations, investigations of fraud, and internal audits, etc.

Responsible Party for Shared Usage of Personal Data

FIRSTLIGHT Capital, Inc. (contact details are below)
https://firstlight-cap.com/en/contact/

8. Provision of Personal Information to Third Parties in Foreign Countries

FIRSTLIGHT may provide personal data to third parties located in foreign countries (i.e., any countries or territories located outside the borders of Japan) to be used, stored, or otherwise handled in the following cases. To view a list of the names and information on the relevant privacy regulations of countries to which FIRSTLIGHT may provide personal data, see here (Japanese only).

Third parties to whom FIRSTLIGHT provides personal data take measures to ensure that such data is adequately protected, including through compliance with the local laws and regulations governing the protection of personal information in their respective countries.

When Providing Personal Data to Third Parties

If the recipient of personal data is a third party located in a foreign country, such data shall only be used within the scope required to fulfill the purposes stipulated above.

When Outsourcing the Handling or Storage of Personal Data

FIRSTLIGHT may provide personal data (in part or in whole) to a subcontracted third party located in a foreign country or outsource the storage of such data via a cloud-based service or other means. In such a case, FIRSTLIGHT shall conduct necessary and appropriate supervision of such subcontracted third party to ensure the protection of such data.

9. Procedures for Consultations and Disclosure Requests Concerning Personal Information Management

Upon receiving a complaint, a request for notification of purpose of use, disclosure, correction, or termination of use of an Individual’s personal information, FIRSTLIGHT shall respond accordingly once the Individual’s identity has been confirmed. To make such a complaint or request, please contact FIRSTLIGHT’s Personal Information Protection Supervisor.

10. Procedures for Disclosure Requests

The following types of personal data may be disclosed by FIRSTLIGHT upon request for a notification (hereinafter referred to as “Personal Data for Disclosure”) of purpose of use, disclosure, correction, revision, termination of use, or deletion, or disclosure of a record of third parties to whom it has shared such data (hereinafter collectively referred to as “Disclosure, etc.”). Personal data obtained by FIRSTLIGHT from companies to which it has outsourced business operations shall be exempt from the scope of Personal Data for Disclosure.

  • Personal data acquired by FIRSTLIGHT in the course of its business from (a) Current/Prospective Limited Partners and/or (b) Current/Prospective Investee Entities
  • Personal data pertaining to Individual/Corporate participants of the community which FIRSTLIGHT manages
  • Personal data pertaining to the management of human resources and labor relations for FIRSTLIGHT executive officers and employees
  • Personal data pertaining to individuals seeking employment at FIRSTLIGHT; however, resumes and other personal data acquired from staffing agencies is exempt from the scope of Personal Data for Disclosure and therefore FIRSTLIGHT is unable to comply with a request for Disclosure, etc. in such cases.
  • Personal data pertaining to Business Partners/Subcontractors
  • Personal data pertaining to any person(s) for whom FIRSTLIGHT has acquired personal information via the exchange of business cards with an employee or executive officer of FIRSTLIGHT or through any other means

To request the disclosure of Personal Data for Disclosure etc., please contact FIRSTLIGHT’s Personal Information Protection Supervisor.

FIRSTLIGHT is required to confirm the identity of the Individual requesting the disclosure of Personal Data for Disclosure, etc. In some cases, FIRSTLIGHT may request that a copy of an official identification document to be submitted via postal mail to complete such confirmation.

11. Major Changes and Notifications

In case of major changes and notifications regarding personal information protection, FIRSTLIGHT will make public announcements through its website and/or other channels.

12. Revisions to the Principles

In order to constantly improve personal information management, FIRSTLIGHT may change and revise the Principles, under circumstances FIRSTLIGHT shall release the revised Policy on the company website(s) that it operates. When such revision requires customers’ consent under relevant laws and ordinances, FIRSTLIGHT shall obtain such consent in a manner designated by FIRSTLIGHT.

13. FIRSTLIGHT Personal Information Protection Supervisor

Osamu Iwasawa, CEO/Managing Director
FIRSTLIGHT Capital, Inc.
flc_corp@firstlight-cap.com

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