Privacy Policy

Pursuant to the provisions of laws and regulations, the Company will acquire and process personal information, etc. related to customer(s) and business contact(s) (hereinafter collectively referred to as “customer(s)”) and applicant(s) for hiring (including internship, etc.), (Name, Address, Birthday (Year Month, Day), Gender, Nationality, Languages, My Number, Phone No. or other contact information including e-mail address, Title, Information relating to the Company where the subject is working, Customer’s needs and transaction records, Income, Career/educational background, Job-related qualifications, and any other information necessary for recruitment activities, etc.) using appropriate and lawful methods, to the extent necessary for the fulfillment of the purposes of use specified in 3: "Purposes of Use of Personal Information, etc." below.

When acquiring personal information, etc. from a third party, the Company will check the information provider's status of compliance with laws and regulations to confirm that the third party has acquired the personal information, etc. in a lawful manner, and preserve records of the confirmed matters, pursuant to laws and regulations, etc.

The following are major information sources, from which the Company acquires personal information, etc.

1. Information directly entered by customers at seminars, etc., held by the Company;
2. Information stated in commercially available books, such as Kaisha Shikiho and Yakuin Shikiho, and information published in newspapers and on the Internet;
3. Information obtained from customers through transactions with customers or products and services, etc., provided to customers;
4. Information directly obtained from applicant(s) for hiring; and
5. Information acquired to the extent permitted under laws and regulations, etc., through domestic and foreign affiliates of Aberdeen group, Aberdeen’s employees and other third parties (Including employment placement agencies, etc.).

The Company may obtain the personal information, etc. from the telephone communication recordings or surveillance camera recordings.

The following are the Company's business contents for which the Company uses the personal information, etc. and the purposes of use of the personal information, etc. (hereinafter referred to as the "purposes of use"), and the Company will use the personal information, etc. to the extent necessary for the fulfillment of the purposes of use, unless otherwise provided in laws and regulations, etc.

(1)Business contents

All the businesses which the Company is permitted to conduct under laws and regulations; for example, the discretionary investment management business, non-discretionary investment advisory and intermediary business, type II financial instruments and exchange business, businesses incidental to the financial instruments business and notified and approved businesses as stipulated in the Article 35 of the Financial Instruments and Exchange Act, and other businesses which can be conducted by the Company and any businesses incidental thereto (including ‘clerical works permitted per My Number Act to use My Number’ and ‘businesses which the Company may be permitted to conduct in the future’).

The Company may outsource services handling personal data or specified personal information to a service provider, to the extent necessary for the fulfillment of the purposes of use listed in 3 above. Fur such outsourcing, the Company conducts necessary and appropriate supervision of the outsourcee (including overseas domiciled companies).

The major services outsourced from the Company include the following:

• Various services related to the business described in 3 (1) above (including services for the preparation and storage of ledgers and other documents related to the business).
• Services for printing or sending documents, etc., addressed to customers, etc..
• Services to provide specialized advice on legal, tax, accounting matters, etc.
• Services related to the operation, maintenance and management of information systems and internal control, etc.
• Recruitment activities.

To fulfill the purposes of use listed in 3 above, the Company may share the personal data with its affiliates, as detailed below:

The Company will not provide the personal data to third parties, except for the cases listed below:

1. When the prior consent (including in electronic form) is obtained from the subject;
2. When the whole or part of the handling of personal data is outsourced to the extent necessary for the fulfillment of the purposes of use (The Company will supervise the outsourcing vendors as necessary and appropriate);The Company will outsource the handling of personal data to an overseas outsourcing vendor only if it is permitted under laws and regulations, etc.;
3. When the personal data is shared with the domestic or foreign group affiliates described in 5 "Shared Use of Personal Data" above (however, shared use with affiliates will be limited to the extent permitted under laws and regulations, etc.);
4. When personal data is provided to a third party pursuant to laws and regulations, etc.
5. When it is necessary to protect human life, limb or property and it is difficult to obtain the subject’s consent;
6. When personal data is provided in line with business succession due to a merger, business assignment, company split or any other reason; or
7. When a third party or the group auditor of Aberdeen group effectively carries out an audit of the Company to the extent necessary for the performance of the Company's business and the auditor accesses, checks, etc., the items listed in 5 (1) above.

When the Company provides/receives the personal data to/from a third party, the Company will maintain and preserve the records on items related to the provision (hereinafter collectively referred to as "records on a third-party provision"), pursuant to laws and regulations.

The procedure for requesting the provision of information shall be in accordance with the procedure in the Section 8 below, regarding the “records on a third-party provision”, “personal information protection regime in the foreign country where a third party is located to which personal data is provided”, “security management measures taken by the third-party in the foreign country” and “measures taken by the Company toward such third-party in the foreign country”, etc.

The Company will never provide specified personal information, etc. to any third party, irrespective of consent of the subject, except in such case as set forth in terms of My Number Act.

The Company will appoint the ‘Chief Personal Data Controller’ responsible for the handling of the personal data and the ‘Chief Controller for handling of clerical works related to My Number’, and establish other organizational structures for the handling of the personal data and specified personal information, etc. (hereinafter collectively referred to as “personal data, etc.”), will make efforts to ensure that the personal data, etc. is accurate and up to date, and take necessary and appropriate security management measures, including information security measures such as measures against unauthorized access and computer viruses to prevent any loss, destruction, falsification, leakage, etc., of the personal data, etc.. The Company will provide education on the importance of the protection of personal information to all the executives and employees who handle the personal data, etc., and will appropriately supervise its outsourcing vendors when the Company outsources the handling of the personal data, etc. to the outsourcing vendors.
Concerning the detailed contents of our security management measures, please submit such request to the contact information.

When the Company receives from a subject a request for information on purposes of use, disclosure, correction, addition, deletion, suspension of use, erasure, suspension of provision to third parties, etc., (hereinafter referred to as the "disclosure, etc.") with respect to the retained personal data of the person in question, the Company will swiftly respond to the request in an appropriate manner after confirming the identity of the requesting person.

If you would like to submit a request for the disclosure, etc., of the retained personal data, please make your request using the contact information below.

Please be advised that you may be required to pay certain expenses actually incurred for the disclosure.

In this case, you will be required to make the payment by account transfer to the bank account specified by the Company, in principle.

In principle, we will disclose by the method selected by you among electromagnetic record provision, paper-based record provision or any other methods specified by the Company, but if disclosure by such method requires a large amount of cost or if it is difficult to disclose by such method, we will notify you in advance and may disclose with a paper-based document.

The Company may reject your request, or take a measure other than the requested measure, if the Company is permitted to do so under laws and regulations, etc. In such case, the Company will notify you or the agent of the rejection or other measure in writing, together with the reason for it.

If you do not wish to permit the Company to use your personal information for sending direct mail or in direct marketing such as telephone marketing, please notify us using the contact information below. After the Company receives such notice, the Company will immediately suspend the handling of the personal information for such purposes.

The Company will make efforts to ensure that the personal data, etc. is accurate and up to date, to the extent necessary for the fulfillment of the purposes of use. If there is any inaccuracy in the information related to you, the Company will correct the information, so please submit a written request using the contact information below.

The information described above may be changed due to the revision of laws and regulations, etc., or any other reason. In cases where such a change is made, the Company will publicly disclose the change by presenting written information at the office counters, etc., of the Company's business offices, or posting information on the Company's website, etc.