Pledge to Protect Personal Information
This “Pledge to Protect Personal Information” prescribes the policy of Nippon Value Investors KK to properly protect and utilize personal information in accordance with the Act on the Protection of Personal Information of Japan, the Guidelines on Personal Information Protection in the Financial Industry of the Financial Services Agency of Japan, and other associated laws and regulations.
Nippon Value Investors collects and uses personal information, including names, addresses, telephone numbers, e-mail addresses and other items (“personal information” hereafter) in performing its business operation. We will handle this personal information in a fair and proper manner that complies with laws and regulations concerning the protection of personal information, government agency guidelines. In addition, we will revise and improve this pledge as required in response to clients’ requests and other feedback, changes in laws and regulations, and other items. Revisions to this pledge will be announced on our website. Please view the pledge on a regular basis to check for revisions.
1. Collection, use and provision of personal information
We shall collect and use personal information for the following business operations and business tasks (“purposes of use” hereafter) as required and by using methods that are legitimate and fair.
We shall not use personal information for the purpose other than the intended purpose without the prior consent of the individual or when the use of the information is permitted under Article 16, Paragraph 3 of the Act on the Protection of Personal Information of Japan and other applicable laws and regulations.
When there is a change in the purposes of use, as a rule, we will notify the associated individuals or make a public announcement by using our website or other method.
(1) Business operations
| ・ | Investment advisory businesses and associated operations |
|---|---|
| ・ | Management of non-Japanese investment trust funds and associated operations |
| ・ | Other operations that can be performed by an operator of an investment management business, investment advisory business, and manager of non-Japanese investment trust funds and associated operations (including operations that may be allowed in the future) |
(2) Major business tasks
| ・ | Clerical tasks associated with investment advisory contracts (advisory operations) or discretionary investment contracts with customers |
|---|---|
| ・ | Provision of information or advice concerning securities |
| ・ | Provision to customers of reports concerning investment performance, contractual asset balances and other items |
| ・ | Provision and management of information about investment products and services of Nippon Value Investors |
| ・ | Research and development for financial products and services by performing market surveys, analyzing data, distributing questionnaires and performing other activities |
| ・ | Provision of information about events and seminars and other types of information |
| ・ | Other communications and activities required to perform transactions with customers properly and efficiently |
We shall not provide personal information to third parties without prior consent from the individual except as permitted under Article 23, Paragraph 1 of the Act on the Protection of Personal Information of Japan and other applicable laws and regulations.
2. Proper management of personal information
We shall take appropriate safety measures to protect the personal information from leaks, losses, alterations, unauthorized access and other problems. Furthermore, we shall strictly supervise employees who handle personal information we have collected and carefully select and supervise third party service providers that handle the personal information.
We will provide thorough training for employees so that personal information is handled properly, perform inspections to verify the proper handling of this information, and constantly work on revising and improving these activities.
3. Disclosure, corrections, termination of use and other actions for personal information based on the Act on the Protection of Personal Information of Japan.
Please refer to “4. Contact information” for how to contact us with a request concerning the disclosure, correction, deletion, termination of use or other item regarding personal information that we hold.
4. Contact information
We will respond promptly and properly to all inquiries concerning the handling of personal information.
Please use the following contact information for inquiries concerning the handling of personal information, measures for the safe management of personal information, as well as inquiries concerning the personal information that we collected.
Nippon Value Investors KK
Compliance Department (Tel: 81-3-6551-2800)
5. Name of certified personal information protection organizations and contact information for complaints : Japan Investment Advisers Association (Tel: 81-3-3663-0505)
The above-mentioned certified personal information protection organization will accept and handle complaints from clients with respect to handling of personal information by us.