PRIVACY POLICY

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December 1, 2015

Japan Investment Advisors, Inc. (hereinafter referred to as "the Company") will comply with laws and regulations regarding the protection of personal information, and will continue to conduct its business in a manner that ensures the appropriate acquisition, handling, and management of personal information. The Company has formulated and announced the following Declaration of Personal Information Protection regarding our approach and policy for the protection of our customers' personal information.

Compliance with related laws and regulations

The Company will comply with the Act on the Protection of Personal Information, the Act on Investment Trusts and Investment Corporations, the Financial Instruments and Exchange Act, other related laws and regulations, guidelines issued by the competent ministers, guidelines issued by related industry organizations, and this Declaration on the Protection of Personal Information.

Use of personal information and its purpose of use

The Company handles the personal information of our customers within the scope necessary to achieve the following business activities and purposes of use, except in cases where we have obtained the consent of the customer or where it is treated as an exception under laws and regulations. Specifically, the general contents of personal information include the customer's name, address, date of birth, contact information such as telephone number and e-mail address, and information about the customer's place of work. In accordance with the Cabinet Office Ordinance on Financial Instruments Business, etc., the Company does not use or provide to third parties special non-public information (sensitive information), such as information on race, creed, family origin, legal domicile, health care, or criminal record, for purposes other than those deemed necessary for appropriate business operations.

(1) Description of business
  • General leasing business
  • Investment business
  • Finance business
  • Investment and financial consulting services
  • Job placement services
  • Real estate transaction duties
  • Financial instruments transaction duties
  • Duties incidental to the above (including duties permitted to be handled in the future)
(2) Purpose of use
  • To make various proposals and provide information on products and services of our group companies and partner companies
  • To fulfill the obligation to confirm the identity of a customer based on the Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act, and other laws and regulations.
  • To make judgments regarding the appropriateness of providing financial products and services, including judgments in light of the principle of suitability.
  • To confirm the identity of the customer or the identity of the customer's agent in accordance with laws and regulations, and to confirm the eligibility of the customer to use financial products and services, etc.
  • To provide information to third parties to the extent necessary for the proper execution of business
  • To provide customers with reports on transaction results, deposit balances, etc.
  • To perform administrative processing, screening, and record keeping related to transactions with customers
  • To research and develop financial products and services through market research, data analysis, questionnaires, etc.
  • To appropriately carry out the entrusted work in cases where all or part of the processing of personal information is entrusted by other businesses, etc.
  • To exercise rights and fulfill obligations based on contracts and laws with customers.
  • To send direct mail and make other proposals regarding financial products and services, etc.
  • To terminate various transactions and to manage the administration after the termination of transactions
  • To understand and manage various risks and for internal management purposes.
  • To obtain information necessary to respond to inquiries from customers.
  • To send greeting cards, etc., and to provide information on various seminars, receptions, etc.
  • To carry out other transactions with customers in an appropriate and smooth manner.
  • To appropriately execute the entrusted work in cases where the Company is entrusted with all or part of the work of managing the personal information of unitholders by an investment corporation as a general administrative agent.
  • To solicit and sell securities and other financial products and to provide information on services provided by the Company or its affiliates, etc. under the Financial Instruments and Exchange Law.
  • To recruit human resources for our company.
  • To provide personal information to banks, sales companies, or our affiliates with which we have a contractual relationship, to the extent necessary to achieve the above purposes.

In the event that the need arises to use the customer's personal information for purposes other than those stated at the time of receiving the personal information from the customer, the Company will notify the customer in advance or make a public announcement of the purpose of use, except in certain cases stipulated by law. The basic method of notifying customers of the purpose of use of their personal information shall be in writing, but may also include notification by e-mail or telephone (including automated voice). As for the method of public announcement, the Company's basic method of notifying customers of the purpose of use of personal information is by posting it on the Company's website or by notifying them in writing.

3. Response to complaints from customer

It is our policy to respond to any complaints from our customers in a prompt, cooperative, sincere, and professional manner.

4. Restriction on provision to third parties

As a general rule, the Company do not provide our customers' personal information to third parties. Hothe Companyver, the Company may provide your personal information to parties other than us if the Company have your consent, if required by law, if the Company entrust the handling of your personal information to a third party within the scope necessary to achieve the purpose of use, or if the Company share your personal information with a specific party as specified in the next section.

5. Joint use

The Company may share your personal information with our group companies within the scope of the purpose of use in order to provide you with high value-added services by utilizing their respective expertise and strengthening cooperation. The Company will be responsible for receiving and addressing complaints and other concerns regarding the management of personal information that is shared. The Company will stop the provision of your personal data to a third party if you request us to do so.

6. Safety Management Measures

The Company will strive to keep our customers' personal information accurate and up-to-date. In order to prevent the leakage, loss, or damage of customers' personal information, the Company have established internal rules for the protection of personal information, and the Company will review and revise them as necessary to establish an appropriate internal system. To prevent the loss, destruction, alteration, or leakage of personal information, the Company will implement strict security measures, including measures against unauthorized access and computer viruses. In addition, we will appropriately supervise and check the compliance status of our officers, employees, and contractors, as well as handle complaints in an appropriate manner.

7. Procedures for requesting disclosure, etc.

In accordance with the Act on the Protection of Personal Information, the Company will respond to requests from customers for disclosure of the content of retained personal data, correction, addition, deletion, suspension of use, deletion, or suspension of provision to a third party in cases where the content of retained personal data is contrary to the facts. We will confirm the identity of the person making the request, and respond to the request in an appropriate and timely manner in accordance with our prescribed procedures. The Company also accepts complaints and other inquiries from customers regarding the handling of their personal information. For more information, please contact the person in charge of your company or the contact information below.

(1) Contact for requests for disclosure

Group Legal & Compliance Department
Kasumigaseki Common Gate West Tower 21F 3-2-1 Kasumigaseki Chiyoda-ku Tokyo, 100-0013, Japan.
TEL:+81-3-6804-6805
Office hours: 9:00 a.m. to 5:00 p.m. (except Saturdays, Sundays, national holidays, and year-end and New Year holidays)

Please contact the following for procedures related to personal data held by our former workers.

Human Resources Department
Kasumigaseki Common Gate West Tower 21F 3-2-1 Kasumigaseki Chiyoda-ku Tokyo, 100-0013, Japan.
TEL:+81-3-6804-6805
Office hours: 9:00 a.m. to 5:00 p.m. (except Saturdays, Sundays, national holidays, and year-end and New Year holidays)

(2) Request method
Please fill out, seal, and submit the prescribed form "Personal Information Disclosure and Correction Request Form".
(3) Method of verifying the identity of the person making the request for disclosure, etc. (including proxies)
The identity of the person making the request for disclosure, etc. (including proxies) will be confirmed by presenting documents such as a passport or driver's license that can be used as official proof of the person's identity.
(4) Fee amount and collection method
Depending on the nature of the customer's request, the Company may charge the actual cost. The fee will be paid by transfer to a financial institution account designated by the Company.
(5) Matters necessary to identify the retained personal data that is the subject of the request for disclosure, etc.
We will ask you to provide your name, date of birth, address, telephone number, account number, etc.
(6) Method and timing of response to requests for disclosure, etc.
In principle, we will respond within two weeks. However, depending on the nature of the request, it may take longer in some cases. The Company will respond in writing as soon as the Company confirm receipt of the "Request for Disclosure, Correction, etc. of Personal Information" form and payment of the prescribed fee (only in cases where a fee is charged). Please note that the response will be mailed to the customer's registered address.
(7) Method of confirming the right of representation when the person requesting disclosure, etc.
The Company will confirm the granting of the right of representation through a letter of attorney or a direct telephone call with the person in question.

8. About Cookies

A cookie is a small text file that the website sends to your device for the purpose of keeping records. It identifies your device, typically your web browser, but it cannot identify you as an individual. Cookies on our website gather analytical data to improve performance. You can choose whether to allow us or third-parties to set cookies which are not strictly necessary for the functioning of the website via the cookie banner and settings provided on the individual websites (available where legally required).
     

9. Changes

The content of the above information is subject to change based on amendments to laws and regulations or other reasons. In such cases, the Company shall post such changes on the Company's website, etc., and such changes shall become effective at the time of posting.

10. Compliance with Laws and Regulations and Improvements

In order to ensure the safe management and proper handling of our customers' personal information, the Company will review this Declaration of Personal Information Protection from time to time and strive for continuous improvement.