HC Asset Management Co., Ltd. ("HC"), in accordance with its Basic Commitment and Standards of Conduct, engages in business activities that contribute to society, while endeavoring to earn the trust of all customers and meet the expectations of stakeholders.
HC appropriately protects personal data obtained from its stakeholders in the course of business activities in accordance with the following Basic Policy, recognizing that personal data is an important asset of each stakeholder and also an important asset for HC, leading to the creation of new value. This Basic Policy applies to personal data held by HC in Japan.
Appropriate Acquisition of Personal Information
- Where it is necessary for us to obtain personal information, we will only do so by lawful and fair means within the scope of achieving the following purposes.
Purposes and Use of Personal Information
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We will handle stakeholders´ personal information in the case of the businesses mentioned in (1) below within the scope necessary to achieve the purposes of use mentioned in (2) below, and we will not use stakeholders´ information beyond the scope necessary to achieve the purposes of use, unless we obtain consent from stakeholders beforehand or it is permitted to do so based on laws or regulations.
When the need to use a stakeholder´s personal data for any purpose other than the stated purpose of use arises, HC will notify the stakeholder to that effect and will obtain the stakeholder's consent before using the information for such purpose.
- 1) Details of our businesses
- Our financial instruments business and operations are associated with financial instruments business in Japan.
We also conduct other operations permitted for financial instruments business operators and other operations associated with such business (including operations that we will be permitted to handle in the future.)
- 2) Purposes of use
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- To perform or solicit transactions and related services concerning financial instruments business (as prescribed in the Financial Instruments and Exchange Act)
- To determine the appropriateness of providing products and services that is in line with the principle of suitability, etc.
- To confirm that the customer is the person himself/herself or the agent of himself/herself
- To report to the customer the results of transactions and deposit balances, etc.
- To carry out administrative work related to transactions with customers
- To carry out research and development for financial instruments and services through the implementation of market research, data analysis and questionnaires, etc.
- To send information about our seminars and co-sponsored seminars, our e-mail newsletters, and announcement, etc.
- If the processing of all or part of the personal information has been consigned by other business operators, etc. to appropriately carry out such consigned operations
- To introduce HC and our affiliated companies or allied companies and also introduce related services
- To manage recruitment information to and communication with applicants for employment
- To manage employment-related data
Provision of personal information
- Except for cases based on laws and regulations, cases when we consign personal information within the scope necessary to achieve the purposes of use, etc., and cases permitted by laws and regulations, we will not provide personal information without the consent of the stakeholder to third parties outside our organization.
Outsourcing of handling of Personal information and Sharing of Personal information
- We may outsource all or part of the handling of your personal data to third parties approved by us in order to accomplish the purposes of use. We will supervise any such outsourcing service provider as necessary to ensure the personal data is secure in accordance with applicable laws and guidelines.
We may, in whole or in part, share personal information with our affiliated companies for the purposes of use. When we share personal information with our affiliated companies, we shall clearly disclose or provide notice of the following points in advance.
- Items of personal data shared
- Range of persons that can share the information
- Purposes of use by persons sharing the information
- Persons with responsibility for the management of the relevant personal data
Security Control of Personal information
- While maintaining the accuracy and up-to-database of personal information, we strive to prevent unauthorized access to personal data or the leakage, loss, or damage of personal data and continually enhance and remediate information security management.
- We will take quick and appropriate measures in the unlikely event of the leakage, loss, or damage of personal data.
- When outsourcing the handling of personal information to other institutions, we will monitor the institutions concerned to ensure that appropriate measures are taken to protect stakeholders' personal information.
Procedures concerning Requests for Disclosure etc.
If we receive a request from a stakeholder for notification of the purposes of use, disclosure, or amendment, or the cessation of use, etc. (hereinafter referred to as "Disclosure, etc.") in relation to personal data concerning the stakeholder that we retain, based on the Act on the Protection of Personal Information, we will respond to this request in accordance with the following procedure, except in the case when Disclosure, etc. is not required by laws and/or regulations.
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(1) Persons permitted to carry out procedure to request Disclosure, etc.
- 1) The stakeholder himself/herself
- 2) The legal representative of the stakeholder if the stakeholder is a minor or an adult ward
- 3) A person who has been entrusted by the stakeholder himself/herself and has carried out our prescribed procedure (appointed representative)
- (2) Documents to be submitted concerning Requests for Disclosure
You may request disclosure of the personal information regarding yourself which we maintain, or request the amendment, removal or updating of such personal information to our Information Helpdesk for Personal Information at the postal address by post. If we receive your request by post, we will send our prescribed request form and list of identity confirmation documents to your address.
Please complete all prescribed fields of our prescribed request form, enclose the identity confirmation document*, and post these documents to our Information Helpdesk for Personal Information.
Once we have confirmed receipt of these documents and the fee(4), we will send a confirmation notice of the receipt to you.
*Identity confirmation document
A copy of one of the following documents: 1) driver's license; 2) health insurance card; 3) passport; 4) pension booklet; 5) resident registry; or 6) duplicate of original alien registration (Original document required for 6)
- (3) Requests for Disclosure through Agent
When your agent is making a Request for Disclosure on your behalf, include the following documents in addition to (2) above.
- 1.Matters Concerning the Agent (We would like to confirm whether the agent is a person with parental authority or other legal representation.)
- 2.Identity confirmation document* of the Agent
- Power of Attorney (The person to whom the personal data refers should stamp a power of attorney with his or her seal and attach a seal registration certificate. When the agent is a person with parental authority or other legal representative, the person making the request may submit a copy or an abridged copy of the family register or a certificate of residence indicating the relationship with the person to whom the personal data refers instead of a power of attorney.)
- (4) Fee for Requests for Disclosure or Notification of Intended Use
- We will charge a fee for requests for disclosure or notification of intended use.
Fee for each request: 1,000 (excluding tax)
- (5) Method of Responding to Requests for Disclosure
- We will respond in writing to the address written on the request form you submitted.
- (6) Use of Personal Data Obtained in Connection with Requests for Disclosure
- We will handle personal data obtained in connection with Requests for Disclosure only for the purpose of complying with Requests for Disclosure. We will not return submitted documents. After a request for personal data has been answered, we will maintain and dispose of the documents in an appropriate manner.
- Note: Reasons for Not Disclosing Personal Data. In the cases indicated below, we will not be able to comply with Requests for Disclosure of personal information. In cases where we decide not to respond to inquiries as requested, we will notify the person making the request to that effect and give the reason. Even in cases where we do not disclose the personal data or provide notification of intended use, we will retain the prescribed fee. When the principal's identity cannot be confirmed, such as when the address on the completed request form, the address on the completed documents for confirming the identity of the person to whom the personal data refers, and the registered address do not match
- When it cannot be confirmed that the agent has duly authorized power of attorney
- When there is a deficiency in the prescribed documents for submission
- When we cannot identify the personal data on the basis of the information contained in the request
- When the information subject to the request does not fall within the scope of "retained personal data" as defined in Article 2, paragraph (5) of the Act on the Protection of Personal Information
- When there is a risk of harm to the life, body, or property of the person to whom the personal data refers or to a third party
- When there is a risk of considerable obstruction to the appropriate operation of our business
- When disclosure would constitute a violation of another law or regulation
Reviewing and Improving Our Management Systems to Protect Personal Information.
- We will educate all of our executives and employees so that they understand the importance of protecting personal information and handle stakeholders' personal information properly. Additionally, we will continually review and improve our management systems to protect personal information.
Contact (Information Helpdesk for Personal Information)
- When a stakeholder requests the Disclosure, etc. of personal data held by HC Asset Management, or when making an inquiry, complaint, or seeking consultation, etc. with regard to our security control measures for personal information or other handling of personal information, please contact the following.
Information Helpdesk for Personal Information
Corporate
HC Asset Management Co., Ltd.
2-11 Kanda-Jimbocho, Chiyoda-ku, Tokyo 101-0051
Office hours: 9:00~18:00
(Monday-Friday, excluding Saturday, Sunday and public holidays)
Please note that we do not accept requests through direct visits to our company.
Authorized Personal Information Protection Organization with which we are Affiliated
We are an Association Member of both the Japan Investment Advisers Association and the Japan Securities Dealers Association, which are authorized personal information protection organizations authorized by the Financial Services Agency. The Association's Personal Information Office handles complaints and requests for advice concerning the handling of personal information by Association Members.
- Japan Investment Advisers Association
Personal Information Office
TEL: 813-3663-0505
(http://jsiaa.mediagalaxy.ne.jp/index.html)
Office hours: 9:00~17:00
(Monday-Friday, excluding Saturday, Sunday and public holidays)
- Japan Securities Dealers Association
Personal Information Consultation Office
TEL: 813-3667-8427
(http://www.jsda.or.jp/privacy/index.html)
Office hours: 9:00~17:00
(Monday-Friday, excluding Saturday, Sunday and public holidays)
- The Investment Trust Association, Japan
Investor Enquiry Section
TEL: 813-5614-8440
(https://www.toushin.or.jp/english/about/map/)
Office hours: 9:00~17:00
(Monday-Friday, excluding Saturday, Sunday and public holidays)
Amendments
To ensure even greater protection of stakeholders´ personal information or owing to changes in laws and regulations, etc., we may amend our Personal Information Protection Policy and the Handling of Personal Information from time to time.
