KINKA Asset Management Co., Ltd. (the “Company,” “we,” or “us”) handles the personal information of clients, business counterparties, and other related parties in the course of its business. We comply with the laws, regulations, and other standards governing the protection of personal information, and — mindful of international practice — have established our own internal rules and management framework. We hereby adopt the following Privacy Policy and commit to implementing and maintaining it. We review this Policy from time to time and strive for its continuous improvement.
1. Our Approach
In protecting and using personal information appropriately, we comply with applicable laws and regulations, with the relevant ministerial and agency guidelines that apply to our business, and with the provisions of this Policy. We safeguard your personal information in accordance with strict security and confidentiality standards.
2. Purposes for Which We Use Personal Information
We collect your personal information in order to conduct our investment advisory business, investment management business, and the other businesses set out in our Articles of Incorporation — so that we can carry out transactions with you safely and reliably and provide you with better services. Specifically, we collect personal information for the following purposes:
- To exercise our rights and perform our obligations in conducting the financial instruments business, the real estate brokerage business, and the other businesses set out in our Articles of Incorporation, in accordance with applicable laws and regulations;
- To carry out general administrative work and other operations related or incidental to our business;
- To conduct the research, analysis, collection of materials, and provision of information necessary to carry out our business;
- To verify the identity of the parties named on application forms, contracts, and similar documents required in the course of our business; and
- To disclose or provide personal information to third parties to the extent necessary for purposes (1) through (4) above.
3. Proper Acquisition of Personal Information
We acquire your personal information only by lawful and fair means.
4. Security Management Measures
To prevent the loss, destruction, alteration, or leakage of personal information, we have established internal rules such as our Personal Information Protection Regulations and implement appropriate security measures, including safeguards against unauthorized access and computer viruses. Where we engage a third party to handle your personal data on our behalf, we require that party to apply equally rigorous controls. We also train all officers and employees who handle personal information on the importance of personal information protection and information security.
5. Use and Provision of Personal Information
The personal information we hold — including real estate information, as well as names, addresses, and other necessary details relating to you and your family members — may be provided to third parties where required by law, or, to the extent necessary to achieve the purposes of use described above, by means such as written documents, postal mail, telephone, fax, email, or advertising media. We will cease providing such information upon your request. (This does not apply, however, to personal information that we acquired after obtaining your individual consent to its provision to a third party.)
6. Requests for Disclosure and Related Procedures
We recognize that you have the right to request the disclosure, correction, suspension of use, and deletion of your own personal information. Once we have confirmed that the requester is the individual concerned — or, where unavoidable, a duly authorized representative — we will, absent any special reason not to, take the requested action, such as disclosure, correction, or suspension of use. To make such a request, please contact us using the details below.
7. Inquiries and Complaints
We accept questions about our handling of personal information, requests such as those for disclosure, complaints, and other inquiries relating to personal information through the channels set out below. We will provide specific guidance on the applicable procedures on an individual basis when we receive your request.
Please contact us by telephone or postal mail using the details below.
Shiroyama Trust Tower 33F, 4-3-1 Toranomon, Minato-ku, Tokyo 105-6033, Japan
8. Changes to This Policy
The information set out above may be revised in response to amendments to laws and regulations or for other reasons.