In order to protect personal information of you, we hereby declare that we will comply with the Protection of Personal Information Law as well as all other related laws and regulations, establish our own guidelines and system in consideration of international trends, and carry and maintain the privacy policy as follows:
(1) We will take reasonable measure to obtain, use and provide the appropriate personal information that is necessary for our business coverage and scale.
(2) We specify the purposes of use of the obtained personal information as follows and will use it only to the extent required to achieve such purposes, except for cases where we obtain the prior consent from the person concerned or use of personal information is permitted by the laws and regulations.
The purposes of use include the following purposes related to the operation of Investment Management Business, Investment Advisory and Agency Business, Type II Financial Instruments Business and other businesses we may operate and ancillary business thereof (including the business we will be permitted to operate):
1. To perform tasks regarding transactions, contracts, etc. with the person concerned and/or business contacts;
2. To verify identification of the person concerned, business contacts necessary in the course of our business;
3. To provide information, dispatch of materials and contact in the course of our business;
4. To exercise rights and/or fulfill obligations pursuant to contracts and/or laws, regulations, etc.;
5. To perform businesses concerning transactions conducted by us, acquisition, brokerage, sale, transfer, leasing or real property management of invested assets regarding the person concerned, or information gathering, research, analysis and discussion on these matters (including but not limited to legal research and credit research);
6. To appropriately and smoothly implement any other transactions with the person concerned and business contacts;
7. To seek advices or services from independent professionals including attorneys at law, certified public accountants, certified tax accountants, real estate appraisers and judicial scriveners, etc. in order to achieve the above purposes;
8. To use for human resources and labor management, employment selection/hiring procedures, and communication and procedures after resignation in relation to our officers and employees (including prospective employee and retired employee).
(3) We will not disclose personal information to a third party except in the following cases:
• A case where personal information is disclosed with the consent of the person concerned;
• A case where the disclosure of personal information is required by the law;
• A case where the disclosure of personal information is required to protect human lives, physical safety and property and it is difficult to obtain the consent of the person concerned;
• A case where the handling of personal information is entrusted to the extent necessary for achieving the use purpose; and
• A case where personal information is disclosed to the successor as a result of business succession due to merger, corporate division, business transfer or other similar transactions.
(4) We will comply with the Protection of Personal Information Law and other related laws and regulations, guidelines and rules established by the governmental authority.
(5) We will take reasonable measures to keep personal information accurate and updated, and to prevent unauthorized access to personal information or loss, destruction, falsification and leakage thereof.
(6) We will establish our “Personal Information Protection Management System”, carry it into effect steadily, maintain it and take reasonable measure to improve it continuously.
(7) We will promptly and sincerely respond to the inquiries of our customer with respect to the personal information and requests for disclosure of the personal information.
(8) Inquiries and complaints concerning the use of personal information:
EGW Asset Management Inc.
Compliance Department
Telephone: +81 3 5771 3939
Reception hours: 9:30am to 6:00pm, Monday to Friday (except public holidays and the Year-End and New Year holidays)
(9) Authorized Personal Information Protection Organization with which we are Affiliated
We are an Association Member of the Japan Investment Advisers Association, an authorized personal information protection organization (authorized by the Financial Services Agency). The Association’s Personal Information Office handles complaints and requests for advice concerning the handling of personal information by Association Members.
Japan Investment Advisers Association Personal Information Office
Telephone: 03 3663 0505 (http://www.jiaa.or.jp/)
Office hours: 9:00am to 5:00pm, Monday to Friday (excluding Saturday, Sunday and public holidays)