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Handling of Personal Information

1. Purpose of Use

When utilizing services of SBI Art Auction Co., Ltd. (“SBI”), the client’s personal information shall be used for the following purposes. Client permission shall be obtained before using personal information for any other reason.

• Trading, brokering, or mediation of SBI products

• Sponsoring auctions related to SBI products

• Conducting appraisals of art, etc. held by client

• Conducting other business entrusted to SBI by client

• Proper managing of client credit for new or ongoing transactions

• Sending SBI newsletters or other e-mails, etc. desired by client

• Providing information on services and products provided by SBI group companies or other affiliated companies

• Responding to opinions, inquiries, etc. of client

• Analyzing trends and purchase history of client regarding SBI products

• Investigating and accessing analysis of SBI homepage ease-of-use and use cases

• Recruitment activities

2. Common Use of Personal Information

SBI may allow common use of personal information listed in Item (1) “Items of Personal Information Subject to Common Use” held by SBI among the parties described in Item (2) “Parties Authorized for Common Use”. Notwithstanding the foregoing, personal information regarding recruitment described in Item (1)d may only be used for the purpose described in Item (3)e. Also, if certain common use is restricted under relevant laws or regulations, such as the Financial Instruments and Exchange Act and Insurance Business Act, personal information will be handled in compliance with such laws or regulations.

1) Items of Personal Information Subject to Common Use

a. An individual’s name, address, date of birth, contact information, such as telephone number and e-mail address, information on transaction needs, publicized information, and other information relating to one’s personal attribution.

b. Transaction records, point information, type of products and services offered to customers, and other information relating to individual transactions.

c. Control numbers, such as customer and transaction numbers, and other information necessary for management of transactions.

d. Information on applicants in recruitment of the SBI Group Companies, applicant’s name, gender, date of birth, address, contact information such as the telephone number and e-mail address, educational background, professional experience, reason for application, and other information relating to recruitment of SBI Group Companies.

2) Parties Authorized for Common Use

The SBI group companies listed on the following website (hereinafter, the “SBI Group Companies”). Notwithstanding the foregoing, parties authorized for common use may be changed from time to time as needed. http://www.sbigroup.co.jp/company/group/overview.html

3) Purpose of Common Use

a. On the Occasion of Use of SBI Group Companies’ Services as a Registered Member

For personal identity authentication at and after log-in, automatic display of membership information in various situations, and other purpose related to improvement of the registered members’ convenience when using SBI Group Companies’ services.

b. Execution of Transactions with SBI Group Companies

For delivery of products, provision of services, settlement of price, response to inquiries, confirmations by SBI Group Companies, provision of applicable after-sales services and other purpose related to operations necessary to execute a transaction when a customer is making reservations and purchasing products or services, applying for a prize competition, or otherwise engaging in transactions with SBI Group Companies.

c. Advertising and Marketing by SBI Group Companies

• For provision of information by SBI Group Companies through various e-mail newsletter.

• For provision of information regarding SBI Group Companies’ services through e-mail, mail, and telephone.

• For provision of contents and advertisements in light of personal attribution, such as gender, age, residence, hobbies, and taste, as well as purchase history, or browsing history of websites managed by SBI Group Companies.

• For development of new services and improvement of existing services by analyzing customers’ usage of SBI Group Companies’ services.

• For drawing of prizes for surveys, campaigns, and prize competitions, as well as shipping, and contacting to applicants for matters relating to such drawing of prizes.

d. Response to Inquiries

For response to inquiries directed to SBI Group Companies by e-mail, mail, or telephone, etc.

e. Recruitment

Personal information regarding applicant’s personnel information, including resume, submitted for the purpose of seeking an employment opportunity at SBI Group Companies, will be used for evaluation and selection process of recruitment.

f. Others Incidental Use

For use necessary for provision of SBI Group Companies’ services that are incidental to the abovementioned items a through e.

g. Others

SBI Group Companies may use, in course of providing their services to customers, personal information for purpose other than the purposes listed in the items a through f above. In such case, such use will be disclosed on an applicable website on which SBI Group Companies provide the relevant services

4) Name of the Company Responsible for the Management of Personal Information

SBI Holdings, Inc.

5) For Inquiries Related to Common Use

General Affairs & Human Resource Department, SBI Holdings, Inc.

Telephone number (main): +81-3-6229-0100

3. Outsourcing

SBI may choose to outsource certain operations to any third party. When doing so, SBI shall outsource to third parties that have installed requisite protection measures for handling client’s personal information, according to the regulations stipulated by the “Act on the Protection of Personal Information” (Act No. 57, 2003, later revised, and hereinafter referred to as “Personal Information Protection Act”), Article 23 Paragraph 4, Number 1.

4. Management and Storage of Personal Information

Personal information shall be strictly managed. If the handling of such information is outsourced to another company, SBI shall manage and monitor the outsourcing company to confirm that such company has management infrastructure equal to or greater than that of SBI, and is providing appropriate management.

5. Disclosures, Corrections, Additions, and Deletions

With regard to the personal information held by SBI, when a client makes a request for disclosure of his/her own personal information, SBI shall disclose such information without delay, after confirming the identity of the client making the request. In the event of a possibility of damage to life, limb, assets, or other rights and interests of the client or a third party, or in the event of a possibility of a significant hindrance to the execution of SBI business, or in the event of a breach of laws or regulations, SBI may choose not to disclose all or a portion of information. With regard to the personal information held by SBI, when the client desires to correct, add, or delete incorrect client information, SBI shall make such corrections, additions, or deletions to the extent necessary, after confirming the identity of the person making the request. In the event SBI halts use or deletes client information in whole or in part, SBI may be rendered unable to provide services desired by the client.

6. Lack of Consent to Terms

SBI only obtains personal information from the client that is required to conduct business, and such information enables SBI to provide services. In cases where the client does not consent to all or some of the Personal Information Protection Policy or to SBI handling personal information, SBI may not be able to provide a satisfactory level of service, or any service, to the client.

7. Third-Party Disclosure and Provision of Personal Information

Excepting any of the following circumstances, SBI shall not disclose or provide personal information of the client to a third party.

1. The client has consented to disclosure;

2. Providing or disclosing statistical or other data through which the client cannot be identified;

3. Disclosure is based on a regulation or ordinance;

4. Obtaining the client’s consent in advance is difficult, or when it is necessary to protect person’s life, body, or property;

5. Obtaining the client’s consent in advance is difficult and is especially necessary to promote the wholesome development of children or the improvement of public health; or

6. Cases in which the handling of personal information is necessary for cooperating with a state organ , a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the client is likely to impede the execution of the affairs concerned.

8. Contact Information and Method for Receiving Inquiries Related to Personal Information

Inquiries regarding personal information of a client of SBI are to be received by the following methods. Please understand that there will be occasions when SBI cannot accept disclosure requests and other such requests that are not based on these methods.

Information Desk Procedures

Please make requests by telephone, post, or email to the following points of contact.

<Contact Information>

Management Department, SBI Art Auction Co., Ltd.

TFT Building, East Wing 7F, 3-6-11 Ariake, Koto-ku, Tokyo 135-0063 JAPAN

Telephone: 03-3527-6692

Email: artauction@sbigroup.co.jp

9. Transfer of Business

There are occasions when SBI needs to transfer all or a part of SBI’s business, by assignment or transfer, to a third party. The client will serve as the preliminary consenting party regarding this transfer. SBI will use the personal information received from the client to the extent necessary until the ongoing purpose for using such information has been achieved.

This English translation of the original document in Japanese is provided for the convenience of clients; however, in the case of any discrepancy between the English and Japanese versions or any question of interpretation, the Japanese document shall control.