To Be a Good Company

Privacy Policy

Handling of Personal Information

The Company's various business activities are underpinned by customer confidence. Through asset management, we aim to contribute to economic expansion, leading to a more affluent and comfortable society. Based on this principle, Tokio Marine Asset Management complies with all laws relating to the protection of personal information and other ordinances and guidelines, including the Personal Information Protection Law and the My Number Law relating to the use of personal identification numbers, abides by the Japan Securities Investment Advisers Association's "Guidelines Relating to Handling Personal Information" and the Investment Trusts Association, Japan's "Guidelines Relating to Protection of Personal Information," and conforms to the Tokio Marine Group Privacy Policy. As outlined below, the Company takes appropriate measures for the handling of personal information and safety management. Furthermore, we thoroughly train and educate staff engaged in work for the Company to ensure proper handling of entrusted personal information, carry out inspections to ensure that standards are being met, and implement continuous improvements in the eventuality that problems arise.

* "Personal information" as referred to in this document excludes personal identification numbers.

1. Acquisition of Personal Information

The Company acquires personal information by legal and honest means within the scope required for the execution of its business. Furthermore, we may record calls to our service desks and other communications to ensure understanding of and correct response to inquiries.

2. Acquisition and Purpose of Use of Personal Information

The Company acquires and uses personal information as necessary through legal and honest means for the execution of the businesses and operations given below ("Purpose of Use"). In the event of changes to the Purpose of Use, the parties concerned shall, in principle, be notified, and the changes announced on the Company website and through other channels.

  • 1.
    Description of Business
    • 1.
      Investment management and related businesses
    • 2.
      Investment advisory duties, agency operations and related businesses
    • 3.
      Type II Financial Instruments Business and business related to this
    • 4.
      Other businesses that can be undertaken in the role of investment manager, adviser or agent, Type II Financial Instruments Business and related businesses (including businesses that may be handled in the future)
  • 2.
    Principal Businesses
    • 1.
      Business relating to investment advisory contracts with customers (advisory business) and investment discretionary contracts
    • 2.
      Provision and advice regarding information relating to marketable securities
    • 3.
      Reports to customers on management results, contract asset balances, etc.
    • 4.
      Guidance, provision and control of the Company's management products or services
    • 5.
      Market surveys and R&D into financial products and services through data analysis and questionnaires
    • 6.
      Guidance for various types of events, campaigns and seminars, and provision of various types of information
    • 7.
      Other communications necessary for the correct and smooth execution of customer transactions
    • 8.
      Verifying that the provision of products and services is in accordance with compatible rules and regulations
    • 9.
      Confirming the identity of the customer

Agreement of the parties concerned will be obtained in the event of acquiring personal information beyond the scope of the Purpose of Use, with the exception of situations stipulated under 16-3 of the Personal Information Protection Law.

3. Supply of Personal Information to a Third Party

The Company will not provide personal information to a third party without the agreement of the individuals concerned with the exception of the following cases:

  • Cases in accordance with the law, including those stipulated under the Personal Information Protection Law
  • Provision to a delegated party, within the scope required for the execution of the Company's business

4. Handling of Sensitive Information

The Company will not obtain, use or supply to a third party any sensitive information, except in cases stipulated under the Personal Information Protection Law and other ordinances and guidelines.

Note: Sensitive information is defined under the "Guidelines for Personal Information Protection in the Financial Field, No. 6."

5. Shared Use of Personal Information by Tokio Marine Group Companies and Partner Companies (Excluding Personal Identification Numbers)

The following personal information is shared between Tokio Marine Group companies and partner companies only when it may be categorised under Purpose of Use as set out in item 2 of this policy.

  • 1.
    Personal information: Name, address, telephone number, email address
  • 2.
    Personal information manager: Tokio Marine Asset Management

6. Handling of Personal Identification Numbers

The use of personal identification numbers is restricted by law and the Company will not acquire, use, or supply to third parties, such information, except in cases stipulated under the My Number Law.

7. Notice, Disclosure, Revision and Suspension of Purpose of Use of Retained Personal Information Based on the Personal Information Protection Law

  • 1.
    Request Procedure for Notice, Disclosure, Revision and Suspension of Purpose of Use of Retained Personal Information
    Requests for the disclosure of personal information should be made by telephone as indicated in "8. Inquiry Desk." A Personal Information Disclosure Application Form will be sent, which needs to be completed and returned. At this point, depending on the type of applicant, you may be required to submit the following documentation for the purposes of confirming the identity of the applicant and determining the information required.
    • 1.
      Application by the individual
      • Authenticated copy of seal registration certificate (bearing current address and within three months of issue)
      • Copy of driving license, health insurance card, passport or other document issued by a public body
    • 2.
      Application by a representative
      • The individual's confirmation documents specified in [1] above
      • Authenticated copy of seal registration certificate (bearing current address and within three months of issue) for the representative
      • Copy of driving license, health insurance card, passport or other document issued by a public body for the representative
      • Documents to confirm power of attorney in the case of a legal representative (family register, legal proof of commencement of guardianship, etc.)
      • Letter of attorney in the case of a delegated representative
  • 2.
    Method of Response
    Once an application for disclosure has been received, confirmation and investigation of the contents of the application are carried out. A response is sent in writing to the applicant the following day. In the case of applications by a representative, response is made to the representative after confirming that disclosure presents no damage to the rights or interests of the individual concerned.
    The Company may decline a disclosure application if responding may threaten the life, person, property or other rights and interests of the individual or a third party, significantly impede the proper execution of the Company's business or be in violation of laws and regulations. In such a case, a response will be provided explaining the reasons.
  • 3.
    Handling Charges
    A fee of ¥864 (including ¥64 consumption tax) is levied for notification of Purpose of Use or application for disclosure of retained personal information. Please transfer this sum to bank account specified by the Company. The cost of transfer is to be borne by the applicant.

8. Inquiry Desk

The Company responds appropriately and swiftly to complaints and enquiries regarding handling of personal information.

For all enquiries regarding handling of personal information, safety management procedures for personal information and retained personal information, please contact:

Tel: +81-3-3212-8421 (9:00 to 17:00, closed weekends, public holidays and New Year)

The Company is a member of the Japan Securities Investment Advisers Association and Investment Trusts Association, Japan, which are Authorized Personal Information Protection Organizations. Both associations operate customer inquiries windows for complaints or consultation in relation to handling of personal Information by their members.

Contact:
Japan Securities Investment Advisers Association
Customer Inquiries for complaints/consultation: +81-3-3663-0505
Investment Trusts Association, Japan
Customer Inquiries for complaints/consultation: +81-3-5614-8440

9. Personal Information Management

The Company has established adequate security countermeasures for the prevention of leakage and loss and for the safe management of personal information, including handling regulations, access control, restrictions on external use, measures to prevent improper external access, and other safety management measures. In addition, we endeavor to ensure that such systems are kept accurate and up-to-date to meet the requirements of Purpose of Use. We have determined selection criteria for consignees in the case of entrusting the handling of information to external contractors, and conduct appropriate monitoring of such parties, including confirming their data management systems and supervising the status of business execution following consignment.

Note: The above does not apply to the personal information of parties engaged in the Company's business.