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.
The Company will properly handle personal information, individual numbers and specific personal information (individual numbers and specific personal information are hereinafter collectively referred to as "Specific Personal Information, etc.") and take safety control measures as described below in compliance with the Act on the Protection of Personal Information (the "Privacy Act"), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the "My Number Act"), other relevant laws, ordinances and guidelines, 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 Tokio Marine Group Privacy Policy.
The Company will conduct training and review for the Company's employees to ensure to properly handle personal information and specific personal information, etc., and make continuous improvement if any problems are found.
* In this Privacy Policy, "personal information" and "personal data" exclude Specific Personal Information, etc.
1. Collection of Personal Information
The Company will collect personal information from customers and shareholders in a lawful and proper manner to the extent necessary for its business. (Please see Clause 7 "Handling of Specific Personal Information, etc." below with respect to Specific Personal Information, etc.)
2. Purpose of Use of Personal Information
The Company will use personal information within the scope necessary for the following purposes and the purposes stated in Clause 5. "Joint Use with the Company's Group Companies and Business Partners" below (the "Purposes of Use").
- 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)
- 1.
- 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
- 1.
Purposes of Use are specifically defined and made clear to customers, and are announced on the Company's website, etc. The Company will make an effort to limit the Purposes of Use according to the situation in which the information is obtained. If there is a change in the Purposes of Use, the Company will notify each principal or announce on its website, etc. to that effect. When handling personal information beyond the scope necessary for achieving the Purposes of Use, the Company will seek each principal's consent except for cases prescribed under items in Paragraph 3 of Article 18 of the Privacy Act.
3. Provision of Personal Data to/from Third Parties
(Please see Clause 7 "Handling of Specific Personal Information, etc." below with respect to Specific Personal Information, etc.)
(1)The Company will not provide personal data to a third party without the relevant principal's consent, unless:
- it is permitted under laws or ordinances;
- it is required to protect the life, body or assets of a person and it is difficult to obtain the principal's consent;
- it is especially required to improve public health or promote sound development of youths and it is difficult to obtain the principal's consent;
- it is required to cooperate with a government agency or local government or its contractor in its conduct of statutory affairs and it is possible that the conduct is hindered if the principal's consent is obtained;
- the third party is an academic research institute or the like and the third party needs to handle the personal data for the purpose of academic research (including where part of the purpose of handling the personal data is academic research and excluding where a right or interest of an individual might be unjustly infringed);
- the personal data is provided to a consignee within the scope necessary for carrying out the Company's business (please see Clause 4 "Outsourcing of Handling of Personal Data and Specific Personal Information, etc.")
- the personal data is provided along with business transfer for a merger or any other reason; and
- the personal data is used jointly with a group company or a business partner of the Company (Please see Clause 5 "Joint Use with the Company's Group Companies and Business Partners").
(2)Unless otherwise prescribed by law, rule or regulation, the Company, when providing personal data to a third party, shall record matters concerning such provision (what type of personal data was provided to whom, etc.), and when collecting personal data from a third party, shall confirm and record matters concerning such collection (what type of personal data was received from what type of provider, how the third-party provider collected such data, etc.).
(3)The Company may provide (or outsource or jointly use) personal data to (or with) third parties establishing a system conforming to standards necessary for continuously taking action equivalent to the one that is required to be taken for handling personal data pursuant to the Privacy Act ("Equivalent Action").
If a customer desires to be notified of the details of information on the measures necessary to ensure the continuous implementation of the Equivalent Action by any such third party, the customer must make an inquiry to the contact point stated in Clause 10 "Contact Information" below.
4. Outsourcing the Handling of Personal Data and Specific Personal Information, etc.
The Company may, within the extent necessary for achieving the Purposes of Use, outsource the handling of personal data and Specific Personal Information, etc. to an external party. When outsourcing the handling of personal data and Specific Personal Information, etc. to an external party, the Company will exercise the necessary and appropriate oversight of outsourcees, such as selecting appropriate outsourcees based on the selection criteria at the outsourcees, executing outsourcing agreement with each outsourcee, and checking their handling of personal data and other information management systems.
For example, the Company outsources the handling of personal data and Specific Personal Information, etc. in relation to the following cases:
- (i) Operations to maintain and operate information systems
- (ii) Operations relating to the preparation and submission of payment records, etc.
5. Joint Use with the Company's Group Companies and Business Partners
(1)Purpose of use and personal data items
Personal data may be used jointly by the Company, Tokio Marine Group companies and their business partners in the following manner. There is no joint use of Specific Personal Information, etc.
- a. The following personal data may be used jointly by the Company, group offices of the Comapny, Tokio Marine Group companies and their business partners for the purpose of use stated in 2-(1) through 2-(9) in Clause 2 above.
[Personal data items]
Address, Name, Telephone number, E-mail address - b. The following personal data may be used jointly with Tokio Marine Holdings, Inc. in order to confirm the non-existence of anti-social forces at the start of various transactions and to maintain such transactions thereafter.
[Personal data items]
Address, name, telephone number, date of birth, sex, and other items about the individual as may be necessary for the purposes of the use.
(2)Business operators and other joint users
- Group offices: Please see here for the group offices of Tokio Marine Asset Management.
- Group companies: Please see here
for the group companies of Tokio Marine Holdings. - Business partners: There is no business partner with whom the Company jointly uses personal data.
(3)Party responsible for personal data management
Tokio Marine Asset Management Co., Ltd.
(Please see here for its address, name of its representative, etc.)
6. Handling of Sensitive Information
The Company will not collect, use, or provide to any third parties personal information requiring special care and information concerning membership of labor unions, family, domicile of origin, health condition and medical treatment, or sexual orientation (except for information released by the individual himself/herself, government agency, local government, academic research institute, or any party provided in each of the items in Paragraph 1 of Article 57 of the Privacy Act or in each of the items in Article 6 of the Ordinance for Enforcement of the Privacy Act, and information which is collected through visual observation or by taking a photograph of the individual and hence the external appearance is evident) except for cases provided by the Privacy Act, other relevant laws, ordinances and guidelines.
7. Handling of Specific Personal Information, etc.
The purpose of use of Specific Personal Information, etc. is limited under the My Number Act, and the Company will not collect or use Specific Personal Information, etc. beyond the prescribed purpose of use. The Company will not provide Specific Personal Information, etc. to any third parties except in cases permitted under the My Number Act.
8. Notice of Matters, Disclosure, Amendment, or Suspension of Use of Personal Data and Specific Personal Information, etc. Held by the Company under the Privacy Act
Please direct requests for notice of matters, disclosure (including disclosure of records of third party provision), correction, suspension or the like of use of personal data and Specific Personal Information, etc. held by the Company under the Privacy Act ("Requests for Disclosure, etc.") to the "Contact Office" indicated in Clause 10 "Contact Information" below. After confirming the identification of the requesting party and having the requesting party complete a form designated by the Company, the Company will provide a response at a later date. The Company will charge a prescribed fee for responding to each request for notice or disclosure of purpose of use.
Please see here for details on Requests for Disclosure, etc.
9. Safety Control Measures
The Company will take safety control measures for personal data and Specific Personal Information, etc. including measures to prevent divulgence, loss or damage to personal data and Specific Personal Information, etc.
Please see here for specific security control measures.
10. Contact Information
The Company will appropriately and promptly respond to any complaint or consultation regarding the handling of personal information, Specific Personal Information, etc.
If you have any inquiry or matter for consultation regarding the handling of personal information and Specific Personal Information, etc. by the Company, please contact the office indicated below.
Please also contact the office below if you do not desire explanations of services via e-mail or direct mail, etc. from the Company.
Contact Office
Tokio Marine Asset Management Co., Ltd
Telephone: +81-3-3212-8421
Address: 1-8-2 Marunouchi, Chiyoda-ku, Tokyo, 100-0005, Japan
(open from 9:00 to 17:00 excluding Saturdays, Sundays, holidays and the new year holiday periods.)
See here for its address, name of its representative, etc.
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.
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
