Privacy Policy - Japan

Fitch Ratings Japan Limited (hereinafter referred to as the "Company") collects, stores, and uses the personal information and non-personal information defined below in accordance with this Privacy Policy (hereinafter referred to as the "Policy"). This Policy is based upon the "Act on the Protection of Personal Information (Japan)", the "Financial Instruments and Exchange Act (Japan)" and other relevant Japanese laws, and describes how the Company collects and protects the information of users (including potential users) (hereinafter referred to as "Users") of the website, and users of other services provided by the Company, obtained on the website or through interviews, e-mail, and other business communications. Unless otherwise specifically noted here, the Company shall not transfer, share, license, purchase, sell or loan User information to third parties. This Policy describes how the Company currently collects and uses information. The Company shall review and change how it handles information on an as-needed basis. Any changes made to this Policy shall be listed on the website. Therefore, regularly check this Policy. By using the website, or any products or services provided by the Company through the website, Users consent to the terms of this Policy.

This Policy only applies to information collected through the website or through the means specified above. The Company assumes no responsibility for the handling of information by websites owned or operated by third parties.

1. Collecting Personal Information

Personal information refers to information on living individual Users that can be used to identify specific individuals using their name, birth date, and other listed details contained within the information. The Company shall acquire personal information such as names, addresses, places of work, company names, telephone numbers and e-mail addresses through the use of the website by Users, through communications such as those in the rating process, interviews, e-mails or through recruitment activities. However, the collection and use of said information shall be done through means that comply with the relevant Japanese laws and regulations. Users are required to enter personal information such as their name, work e-mail address, work address, work telephone number and name of their place of work as part of the website registration process, and also to consent to the terms of service listed on the website. Personal information provided by Users with their consent may also be collected through online forms, order/registration forms, questionnaire surveys and other such means. In any of the above cases, the Company shall only collect information that has been provided by the Users themselves. The provision of personal information is not required to browse the website. However, in such a case, not all functions of the website will be available for use.

2. Collecting Non-Personal Information

In addition to personal information, the Company may also collect and track (i) information that cannot be used to identify individual Users, including statistical data on Users, such as age, profession and gender, as well as domain names, computer types, browser types and other anonymized statistics related to usage of the website, (ii) information, such as company names, that can be used to specify Users that are not individuals, and (iii) records of User usage of the website ((i) through (iii) are hereinafter referred to as "non-personal information").

3. Tracking Tools

The Company may utilize specific Internet technologies such as cookies, function keys and web beacons (hereinafter referred to "Tracking Tools") in order to improve usability of the website for the User. Tracking Tools are files and tools that are placed on the User's computer and are used to determine the type of web browser and the operational status of the computer the User is using to access the website.

The Tracking Tools enable the Company to recognize Users each time they visit the website, allowing the website to be optimized for each User (for example, if a User has already completed the registration process, the cookies will become active when they visit the website, and as such there will be no need for them to re-register). Personal information and non-personal information collected using this kind of technology shall be used and provided in compliance with this Policy.

4. Intended Usage of Personal Information and Non-Personal Information

The Company shall use collected personal information for the purposes outlined below. (1) Personal information collected in business operations related to the credit ratings business shall only be used for those purposes deemed necessary for the fair and accurate performance of the credit ratings business. (2) Personal information obtained through recruitment activities shall only be used for purposes related to those recruitment activities. Other information (including information provided by Users when registering on the website) shall only be used for (3) internal-company purposes, including statistical analysis of User behavior, product development, content improvement and customization of website contents and layout, and (4) making contact with the User, including for items (a) through (d) detailed below. With the exceptions of (i) when required to do so in order to comply with legal or regulatory requirements, (ii) when there has been express consent from the User, (iii) when it is necessary to protect the legal rights over the content of the website and it is difficult to obtain User consent, and (iv) when permitted by law to do so, the Company shall not use any User personal information for purposes other than those stated above.

The Company may use collected non-personal information internally or externally for purposes such as, but not limited to, researching and identifying market segments or needs, or for performing marketing activities. The Company shall also use non-personal information collected in business operations related to the credit ratings business for the purposes listed in (1) above.

The Company may make contact with Users using a User's personal information and non-personal information regarding (a) changes to the User's account status and/or terms of service, (b) the Policy, (c) other policies, contracts, and transactional information related to use of the website and/or (d) products and services it is believed the User may be interested in at the Company's discretion. Users who do not wish to receive marketing information may opt out by notifying the company of this through an e-mail to tokyo.compliance@fitchratings.com .

5. Provision of Personal Information and Non-Personal Information to Third Parties

The Company shall provide third parties with personal information it has collected (i) when entrusting all or part of the handling of personal information to a third party within the scope required for achieving the intended usage, (ii) when there is a business succession due to a merger or for other reasons, or (iii) when using said information jointly with its affiliate companies (including affiliate companies based in Japan and those outside of Japan). In the case of (i), the Company shall provide appropriate supervision to the third-party entrusted with said information as deemed necessary.

The Company may provide third parties with non-personal information for purposes such as, but not limited to, researching and identifying market segments or needs, for performing marketing activities, or when points (i) through (iii) above apply.

Except in the cases outlined above, the Company shall not disclose personal information or non-personal information to third parties without prior consent from the User, or except when it is permitted by law to do so.

6. Joint Usage

Regarding (iii) in section 5 above, (a) Items of personal information that may be used jointly include User information such as the User's address, name, place of work, job title, telephone number and e-mail address, as well the contents of communications with the Company, the results of usage of the Company's services, or areas that may be of interest. (b) The scope of those who may jointly use said information is limited to Fitch Ratings Inc., Fitch Ratings Ltd., Fitch Solutions Inc., Fitch Solutions Ltd., Fitch Learning Inc., BMI Research and their affiliated companies, and Fitch Group Inc. and its affiliated companies.　　　　　　　 (c) The intended usage by users of said information is detailed in "4. Intended Usage of Personal Information and Non-Personal Information". (d) Those responsible for managing joint usage of personal information and non-personal information are detailed below. Fitch Ratings Japan Limited – Personal Data Manager Address: Kojimachi Crystal City East Wing 3rd Floor, 4-8 Kōjimachi, Chiyoda-ku, Tōkyō-to, 102-0083 Phone：03-3288-2628

E-mail：tokyo.compliance@fitchratings.com

7. Links

The website may contain links to other websites on the Internet. The Company does not guarantee nor accept responsibility for any of the contents, or the protection of personal information on these websites.

8. Security Measures

The Company shall take reasonable precautionary measures in order to prevent the loss, unauthorized use, unauthorized access, leakage, falsification and/or destruction of collected personal information. Said precautions involve contractual and administrative measures along with physical and/or technical measures. The physical measures include firewall-based protection and the use of encryption technology if required. The Company is striving to develop a website that is both safe and reliable for its Users. However, please note that the confidentiality of any information or materials sent or received via the website or e-mail cannot be guaranteed.

9. Legal Compliance

Regarding the handling of personal information and non-personal information, the Company shall comply with the "Act on the Protection of Personal Information (Japan)", "Financial Instruments and Exchange Act (Japan)" and any other relevant Japanese laws and guidelines.

10. Areas of Jurisdiction

This Policy has been written based on Japanese law and shall be interpreted based on the Japanese laws. Any disputes that arise shall be submitted to the jurisdiction of the Tokyo District Court.

11. Contact Information

If a User requests notification, disclosure, corrections, additions, deletion, suspension of usage or erasure of personal information and/or its use, or the cessation of provision of said personal information to third parties, the Company shall, upon confirming the User's identity through procedures prescribed by the Company itself, respond appropriately in accordance with the "Act on the Protection of Personal Information (Japan)" and any other relevant Japanese laws and guidelines.

The party responsible for data management for the Japanese language version of the website is Fitch Ratings Japan Limited, who will perform said data management duties through cooperation with Fitch Ratings Inc. or any of its affiliate companies, or through entrusting said data management to these group companies as and if it is required.

If you have any questions or concerns regarding the Company's privacy policy or its handling of information protection, please get in contact using the details below.

E-mail：tokyo.compliance@fitchratings.com

By using this website, Users consent to this Policy and the Company's handling of Users' personal information and non-personal information in accordance with the provisions set forth in the Policy. Users who do not consent to the provisions set forth in the Policy will not be able to use the website. If changes are made to this Policy and the User continues to use the website after said updated Policy has been made available, the User thereby consents to the changes in this Policy.