Tokyo March 11, 2010 Download Westernfield Holdings Privacy Statement from March 11, 2010

Privacy Statement

We recognize the importance of keeping client information confidential and protecting our clients' right to privacy. We commit to continue remaining vigilant in protecting that information. Accordingly, we undertake to protect the privacy of our clients by adhering to the following principles:

1. We do not collect information that would personally identify our clients, unless such information has been knowingly provided to us by our client. We may collect information concerning clients' operating systems, browser type, domain name, Internet address, and details of the website from which they have connected to the Internet. Beyond this, we may also collect information such as your name, address, e-mail address, telephone number, identification number such as Social Security number, income levels, financial goals and investment objectives. Such information will only be collected and stored by if it has been provided to us by you in your communications with us.

2. We will protect and safeguard all information disclosed by our clients according to strict standards of security and confidentiality. To this extent, we will take all necessary steps to prevent unauthorized access to our IT systems.

3. We will retain and use client information to better serve our clients and provide information about products, services, and other opportunities that may be of interest to them. Moreover, such information may be used to optimize the services we provide such as integrated financial services solutions, improve responses to inquiries and requests, perform risk control and fulfill our obligations to you. Where permitted and appropriate, we may also use this information for marketing and product development purposes.

4. No information relating to clients will be disclosed to third parties, unless such disclosure has been authorized by our client, or is required by law. It is our policy not to rent or sell personal information. Where disclosure has been authorized by our client, the information will be shared with non affiliated third parties in order to carry out and finalize transactions, mail statements and other information, help us to verify information such as identity, provide us with consulting, legal, accounting and other services, help us to maintain and further develop our services and perform marketing where appropriate. Where required by law for instance, your personal information will be shared with government and regulatory bodies, exchanges, law enforcement agencies and other as required by law and in order for us to fulfill our compliance and governance obligations.

5. We require our employees to treat all information in the strictest confidence and protect the privacy of our clients. In order to deliver the best solution and provide efficient service to you, your information is shared internally among advisors, investment managers, trustees etc.

6. Our website may use cookies, i.e. small data files that are stored on your computer's hard drive for identification purposes. Cookies allow the web server to recognize you during your next visit to the website. However, it should be noted that cookies cannot read data off your hard drive.

7. Our clients have the opportunity to verify the accuracy of the personal information which we have collected from them. We would encourage all our clients to ensure that such information is accurate and updated as circumstances change to facilitate identification, correct mailing addresses, correct e-mail addresses etc.

8. Our website may contain links to other websites. We accept no responsibility or liability for the data policy and procedures of such websites, or for the contents thereof. We advise you to familiarize yourself with the data protection policies of these websites.

European Economic Area Users

When you provide Westernfield Holdings with your Personal Data, you acknowledge that this information may be stored and processed on servers located outside the European Economic Area ("EEA") and you consent to your Personal Data being exported outside the EEA and being stored and processed at WesternField Holdings discretion on any of its servers wherever located.

Your rights

Regarding the information held about you by Westernfield Holdings, you may, for example, request us to provide you with a list and a description of this information, request us to amend any inaccuracies, or notify us that you do not consent to our continued use of this information by contacting us as set out below.

WesternField Holdings
Shinjuku Park Tower S 20/F
3-7-1 Nishi-Shinjuku
Shinjuku-ku Tokyo 163-1035
Japan

Phone: +81-366887679
Fax: +81-366887083

Intellectual Property Rights

Copyright: the information contained on Westernfield Holdings websites is the exclusive property of Westernfield Holdings and is protected by copyright and other proprietary rights. Nothing contained in these sites may be copied, reproduced, distributed or publicized in any manner without Westernfield Holdings permission.

Trademarks: WesternField Holdings websites contain trademarks which are owned and registered by WesternField Holdings. No license to use these trademarks is hereby granted or implied. No reproduction is permitted without Westernfield Holdings permission.

Linking: when you intend to be linked to any Westernfield Holdings website, you are required to request permission from Westernfield Holdings with your name, address, telephone number, e-mail address, and the URL of your website. WesternField Holdings reserves the right to reject to link to those websites whose contents or linking methods are not deemed by us to be appropriate for WesternField Holdings websites.

Updated 4:36 am