Basic Privacy Policy
ＨＯＭＥ ＞ Basic Privacy Policy
Established on June 1, 2008
Last revised on April 1, 2023
Marubeni Asset Management Co., Ltd. (hereinafter referred to as “Company”) acknowledges the importance of protection of personal information, and will establish and comply with the privacy policy (hereinafter referred to as “Policy”) stated below, based on the idea that it is a social responsibility for the Company to appropriately handle, manage, and protect personal information. In addition, with regard to individual numbers and specific personal information (which are respectively defined in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures), the Company will separately establish and comply with the “Basic Policy on the Protection of Individual Numbers and Specific Personal Information.”
1. Compliance with related laws and regulations, etc.
In handling personal information, the Company will comply with the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”) and other related laws and regulations/guidelines, etc.
2. Purpose of use of personal information
Excluding the cases where the Company obtains a prior consent from the subject individual, and the exceptional cases where it is permitted by laws and regulations, etc., the Company will handle personal information to the extent necessary to achieve the purposes of use stated below. However, if the purpose of use is clear, in light of the circumstances in which the personal information is acquired, or if it is permitted by laws and regulations, etc., a clear indication of the purpose of use may be omitted.
（１）
In the relationship between the investors of investment corporations (hereinafter referred to as “Investment Corporations”) by which the Company is entrusted with the asset management under the Act on Investment Trusts and Investment Corporations (hereinafter referred to as the “Investment Trust Act”) and the Investment Corporations, to have the investors exercise their rights or perform the Company’s obligations owed to the investors under the Investment Trust Act and other related laws and regulations. In addition, to perform the Company’s obligations and exercise its rights as well as to deal with various matters incidental thereto
（２）
In the relationship of the Company’s customers pertaining to asset management as the investment management business, investment advice as the investment advisory business, the type II financial instruments business or the real estate brokerage under the Financial Instruments and Exchange Act (hereinafter referred to as the “FIEA”) (hereinafter collectively referred to as “Company’s Customers”) as well as their investors and the Company’s Customers, to have the investors exercise their rights or perform the obligations owed to the investors under the FIEA and other related laws and regulations. In addition, to perform the Company’s obligations and exercise its rights as well as to deal with various matters incidental thereto
（３）
To create and submit various reports, etc. of the Investment Corporations and the Company’s Customers under the Investment Trust Act, the FIEA, and other related laws and regulations, as well as to create and manage information of various data pertaining to the Investment Corporations’ investors and the Company’s Customers’ investors
（４）
To perform business pertaining to acquisition, intermediation, sale, transfer, lease, management as well as investment advice, information collection, research and analysis, and review with respect thereto (including but not limited to legal research and credit check) of assets pertaining to the Investment Corporations by which the Company is entrusted with the asset management and the Company’s Customers in the investment management business and the investment advisory business
（５）
To analyze the market trend, research customer satisfaction, or research and analyze product development, etc.
（６）
To perform business concerning borrowing of funds and issuance of additional investment units by the Investment Corporations, as well as to perform business concerning borrowing of funds and other fund procurement by the Company’s Customers
（７）
To notify the investors of the Investment Corporations and the investors of the Company’s Customers of information, etc. concerning the business of the Investment Corporations or the Company’s Customers
（８）
To deal with inquiries or requests, etc. for materials to the Investment Corporations or the Company’s Customers
（９）
To perform business concerning the settlement business, and other accounting and taxation of the Investment Corporations or the Company’s Customers
（１０）
To perform business pertaining to information collection, research and analysis, and review with respect to transactions conducted by the Company (including but not limited to legal research and credit check)
（１１）
To conduct verification at the time of transaction under the Act on Prevention of Transfer of Criminal Proceeds
（１２）
For employment screening, employment procedures, or various notifications/procedures after retirement
（１３）
For provision to third parties to the extent necessary to perform proper business
（１４）
To perform business incidental or related to the above
3. Proper usage
The Company will not use its customers’ personal information in a way that is likely to promote or trigger illegal or unjust acts.
4. Provision of personal data to third parties
The Company will not provide obtained personal data to any third party except for the following cases:
（a）
Cases in which there is consent of the subject individual;
（b）
Cases based on laws and regulations;
（c）
Cases in which there is a need to protect the life, body, or property of an individual, and it is difficult to obtain the consent of the subject individual;
（d）
Cases in which there is a special need to improve public health or promote healthy child development, and it is difficult to obtain the consent of the subject individual;
（e）
Cases in which there is a need to cooperate with a national government organ, a local government, or a person entrusted thereby with performing the functions prescribed by laws and regulations, and obtaining the consent of the subject individual is likely to interfere with the performance of those functions;
（f）
Cases otherwise provided for in the Personal Information Protection Act.
5. Group shared use
The Company may, to the extent permitted by applicable laws and regulations, etc., and in order to appropriately and smoothly control the management among the group, respond to inquiries, etc. from business partners, give announcements and provide information to business partners, and conduct other transaction with business partners, and to the extent necessary for the purposes of use stated in paragraph 2 above, share retained personal data including personal information regarding business partners of the Company or the Company’s Customers (company name, name, company address, telephone number, fax number, e-mail address, and other information that can be read from business cards) with Marubeni Corporation, which is our parent company, and other Marubeni Group companies (however, limited to companies which transfer the Company’s officials and personnel or companies to which they are transferred). The Company (whose address and representative name are as stated in paragraph 12 below) will be responsible for management of personal data including personal information in this shared use. With regard to inquiries about the shared use of such personal data including personal information, please contact us via <Inquiries> stated in paragraph 11 below.
In addition, other Marubeni Group companies will mean Marubeni Corporation’s consolidated companies stated in Marubeni Corporation’s Consolidated Financial Statements.
6. Acquisition, etc. of sensitive information
Except for the cases set forth in the Guidelines for Protection of Personal Information in the Finance Sector, the Company will not, in the finance sector, obtain, use, or provide to any third party any special care-required personal information as well as information regarding membership of any labor union, family origin, registered domicile, medical or health care record, sexual activities (except for those falling under special care-required information of these; except for information that is open to the public by those listed in the Personal Information Protection Act, such as the subject individuals, national government organs, local governments, and academic research institutions, or those listed in the Ordinance for Enforcement of the Act on the Protection of Personal Information [hereinafter referred to as the “Ordinance for Enforcement of Personal Information Protection Act”], or seemingly-clear special care-required personal information that is acquired by visual observation, filming or photographing of the subject individual).
7. Safety management measures
The Company will strictly manage personal data to keep it accurate and up-to-date, and endeavor to erase such personal data without delay when it is no longer necessary to use it. The Company will take the necessary and appropriate organizational, personnel, physical, and technical safety management measures for preventive and security measures against the leakage, loss, or damage of personal data, and for safety management of personal data. If the Company handles personal data in a foreign country, the Company will take such safety management measures after grasping the system, etc. regarding the protection of personal information in such foreign country. Also, if the Company outsources all or part of the handling of personal data, the Company will take appropriate measures to protect personal data under laws and regulations, etc., and provide the necessary and appropriate supervision of the contractor to ensure the safety management of outsourced personal data. For the content of the Company’s safety management measures for personal data, please contact us via <Inquiries> stated in paragraph 11 below.
8. Procedures for disclosure, etc. of retained personal data
If the Company receives a request for disclosure, correction/addition/deletion, suspension of use/erasure, suspension of provision to a third party or disclosure of records of provision to a third party (hereinafter collectively referred to as “Disclosure, etc.”), or notification of the purpose of use with respect to the Company’s retained personal data in accordance with the Personal Information Protection Act in writing, in principle, the Company will appropriately respond to it without delay under laws and regulations, etc. as soon as the Company can confirm that it is the request by the subject individual or his/her authorized agent by the confirmation method specified by the Company. However, the Company may not respond to the request for the Disclosure, etc. or notification of the purpose of use in certain cases where it is likely to harm the life, body, property or other rights and interests of the subject individual or third parties. In that case, the Company will notify the subject individual or his/her agent of the reason without delay. For the details of the procedures, please contact us via <Inquiries> stated in paragraph 11 below. In addition, with regard to notification of the purpose of use or disclosure of the retained personal data, or the disclosure of the records of provision to a third party, the requester may be required to bear a prescribed fee.
9. Report of leakage, etc.
If there are any leakage, loss, or damage of personal data handled by the Company or any other events pertaining to ensuring the safety of personal data that are stipulated as those which are highly likely to harm the rights and interests of individuals in the Ordinance for Enforcement of Personal Information Protection Act, the Company will report the occurrence of such events to the supervisory authority, etc. in accordance with the provisions of the Ordinance for Enforcement of Personal Information Protection Act.
In addition, in such cases, the Company will notify the subject individual of the occurrence of such events in accordance with the provisions of the Ordinance for Enforcement of Personal Information Protection Act; provided, however, that the same will not apply to the case where the notification to the subject individual is difficult and the Company takes the alternative measure necessary to protect the subject individual’s rights and interests.
10. Continuous improvement
The content of the Policy will be applied as of the date of posting on the Website. The Company will continuously review the content of the Policy and revise it from time to time as necessary to improve the management system, etc. of personal information.
11. Inquiries
With regard to inquiries for the content of safety management measures of personal data taken by the Company and the handling of personal information by the Company, requests for Disclosure, etc. of retained personal data, requests for notification of the purpose of use, and complaints, please inquire with the contact information below. When receiving complaints, etc. about the handling of personal information, the Company will endeavor to respond to them appropriately and promptly within a reasonable period.
【Inquiries concerning the matters stated in the investor register of the Investment Corporations】
With regard to the request for correction, addition or deletion of the matters stated in the investor register of the Investment Corporations, please contact the Stock Transfer Agency Business Planning Department at the Head Office of Mizuho Trust & Banking Co., Ltd., which is the administrator of registers.
【Inquiries concerning other personal information】
The request for correction, addition or deletion pertaining to personal information other than the above will be made to the Company. Please inquire with the following contact information:
Company name: Marubeni Asset Management Co., Ltd., Compliance Department
Address: Otemachi Building 5F, 1-6-1 Otemachi, Chiyoda-ku, Tokyo, 100-0004, Japan
Tel: +81-3-6256-0200
(Open: 9:15-17:00 [excluding Saturdays, Sundays, national holidays])
In addition, the Company is a member of the Investment Trusts Association, Japan and the Japan Investment Advisers Association which are certified personal information protection organizations under the Personal Information Protection Act. The said Associations receive consultations and complaints regarding the handling of personal information by the member companies. The contact information will be as follows:
【Contact information of the Investment Trusts Association, Japan】
Investment Trusts Association, Japan, Member Inspection Dept., Investor Enquiry Section
Tel: +81-3-5614-8440
【Contact information of the Japan Investment Advisers Association】
Japan Investment Advisers Association, Complaints Office (office in charge of personal information)
Tel: +81-3-3663-0505
12. Name, address, and name of representative of the business operator handling personal information
Name: Marubeni Asset Management Co., Ltd.
Address: Otemachi Building 5F, 1-6-1 Otemachi, Chiyoda-ku, Tokyo, 100-0004, Japan
Name of representative: Yoshiyuki Yokoyama
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