Declaration on the Protection of Personal Information
In conducting our business as a financial instruments business operator, our company may acquire and use personal information (Information defined in the Act on the Protection of Personal Information (hereinafter “the Protection of Personal Information Act”) contained in customers, business partners, various printed materials, and publicly available information obtained from the Internet. Our company and its officers and employees shall comply with the Act on the Protection of Personal Information and other relevant laws and regulations to promote the protection of privacy.
1．Compliance with laws and regulations concerning personal information and safety management measures, etc.
Our company will comply with the Personal Information Protection Act, related laws and regulations, and the guidelines on the Personal Information Protection Act published by the Personal Information Protection Committee (including, but not limited to, guidelines on the Act on the Protection of Personal Information in the Financial Sector (“Guidelines for the Protection of Personal Information in the Financial Sector”), hereinafter collectively referred to as “Personal Information Protection Law Guidelines”) with respect to the handling of personal information.
Our company shall establish internal rules concerning the handling of personal information and personal data as defined under the Personal Information Protection Act, introduce and implement appropriate security measures for the personal information and personal data it holds, and take necessary measures to prevent unauthorized access, falsification, destruction, leakage, loss, etc.
Our company will comply with this policy and review it periodically to maintain the compliance to the policy will be performed.
2．Usage of Personal Information
Personal information collected by our company in the course of our business activities includes names of client, company, department, title, company address, contact phone number including mobile phone, fax number, email address, and business qualifications etc.
Our company shall handle the acquired personal information within the scope necessary for the following business operations and operations for which the use of personal information is expected.
1)Business Profile:
•Investment Advisory and Agency Business and Business Associated therewith
•Type II Financial Instruments Business and business incidental thereto
•Other services with which our company may be engaged and services incidental thereto
2)Business expected to use personal information
•Businesses Related to Type II Financial Instruments Business
•Operations related to investment advisory contracts
•Investment Advisory and Investment Agency Business
•Reporting of investment results and contracted assets
•Processes related to treatment of foreign collective investment scheme equity and similar rights
•Determining the appropriateness of products and services provided
•Confirmation that the person is the principal or an agent of the principal
•Business affairs related to transactions with customers
•Research and development of financial products and services through market research, data analysis, and surveys
•Invitation to seminars and provision of economic and market analysis information by our company and its affiliates
•Other businesses that require the use of personal information
Our company will not acquire, use or provide to a third party any information deemed sensitive (sensitive) in the Financial Services Personal Information Protection Guidelines (Information on race, religion, creed, family origin, registered domicile, medical history, or criminal history, etc.), except as regulated in the Financial Services Personal Information Protection Guidelines.
3．Provision of personal data to third parties
Our company will not provide personal data to a third party without obtaining prior consent from the person concerned, except as otherwise provided by laws, regulations, contract or this policy.
4．Outsourcing of Personal Data
Our company may outsource all or part of the handling of personal data to outside companies to the extent necessary for the above business contents and the purpose of use. When such outsourcing is performed, a confidentiality agreement and/or contractual undertakings is concluded with the outsourcing party, and necessary and appropriate supervision is performed on the outsourcing party to ensure that personal data is managed safely.
5．Sharing use of personal data
Our company, including Heitman LLC, our parent company, and other affiliated group companies may jointly use personal data in order to carry out the business which our company can carry out and the business incidental to them jointly with our company.
The Personal Data to be shared will be the name, gender, company name, department name, job title, company address, contact phone number including mobile phone, fax number, email address, business qualification, etc., and other information necessary for our company to carry out its business.
Heitman International LLC Tokyo Branch is responsible for managing these personal data.
6．Transfer of personal information overseas
Personal information may be transferred to a country other than the country of residence of the individual concerned (The countries where our company or our group companies have offices or outsourcing party to be used by us are located, the countries provided for in the European Economic Area Agreement as of January 23, 2019 as set forth in the 2019 Public Notice of the Personal Information Protection Commission No. 1, and the United States are applicable.) and stored, processed, or modified. The privacy regulations of these countries may differ from those of the country in which the individual resides.
7．Contacts for handling, including disclosure of personal information, suspension of use, correction and deletion of personal information, and suspension of provision of personal information to third parties, and complaints, etc.
With respect to personal information held by our company, in accordance with the provisions of the Personal Information Protection Act and the Guidelines for the Protection of Personal Information, if you or your legal representative discloses, suspends, corrects or erases the use of, or requests to discontinue the provision of such personal information to a third party, or if you have any complaints, etc., please contact us at the following address.
Heitman International LLC Tokyo Office/Compliance Department
•Address: Hibiya Mitsui Tower 33rd Floor, -1 -2 Yurakucho 1, Chiyoda-ku, Tokyo 100 0006
•Tel: 03-6550-8885
- Email: tokyo.compliance@heitman.com
8．Authorized personal information protection organizations which we have regular/full memberships
Our company has regular/full memberships of the Type II Financial Instruments Firms Association and the Japan Investment Advisers Association, both of which are authorized personal information protection organizations certified by the Financial Services Agency. Each association accepts complaints and consultations regarding the handling of their members’ personal information at the following contact information.
(1)Type II Financial Instruments Business relating matters.
Type II Financial Instruments Firms Association
General Affairs Division, General Affairs Department
Tel: 03-6910-3980 (representative number)
Reception hours: Monday – Friday (except public holidays)
9 AM to 11:30 AM , 0:30 PM to 5 PM
Office : Taiyo Life Nihonbashi Building 12th floor, Nihonbashi 2- 11 -2, Chuo-ku, Tokyo 103 – 0027
(2)Investment advisory business, investment advisory business or investment agency business relating matters
Japan Investment Advisers Association
Association Secretariat Personal Information Complaint Office
Tel: 03-3663-0505
Office: Tokyo Securities Kaikan 7th Floor, 1 -5 -8 Nihombashi Kayaba-cho, Chuo-ku, Tokyo 103 – 0025