Tosei Asset Advisors, Inc. shall ensure that all executives and regular employees are fully aware of the importance of handling the personal information of customers with care, and with the aim of offering high-quality products and services, it shall implement the privacy protection-related measures below while meeting its social responsibilities as a company.
1. Basic policy
Tosei Asset Advisors makes it a priority to comply with the applicable laws, regulations, and guidelines relating to the protection of personal information and to strive to manage and use personal information of customers appropriately.
2. Secure management of personal data
Tosei Asset Advisors shall separately stipulate internal standards with regard to the handling of personal information and related systems and establish a manager to oversee personal information protection, as well as implementing system-related precautions and safety measures in order to prevent unauthorized access, etc.
Furthermore, Tosei Asset Advisors shall aim to sustain effective and appropriate management by continuously reviewing and improving the Basic Policy, the standards for handling personal information, and the organizational structure for implementing them.
3. Appropriate acquisition of personal information
When acquiring personal information from customers, Tosei Asset Advisors shall do so by appropriate and legitimate means. Moreover, it shall clearly state the purposes for which information will be used and acquire only information that is required to fulfill those purposes.
4. Purpose of use
Personal information provided by customers shall be used only within the scope of the indicated purpose of use and not for any other purposes.
5. Restrictions on provision to third parties
Except in the cases below, Tosei Asset Advisors shall not provide or disclose personal information provided by customers to any third parties.
- The customer provides prior consent
- It is not possible to identify an individual based on the disclosed information
- Disclosure is required by applicable laws and regulations
- A national government institution, local government, or a party acting on their behalf requires the cooperation of Tosei Asset Advisors in order to carry out legally mandated duties and there is a risk that requesting the consent of the customer could interfere with the execution of those duties
- The purpose is to protect the assets and interests of Tosei Asset Advisors
In cases where Tosei Asset Advisors discloses or provides information to any third party after obtaining the customer’s consent, it shall ensure that the third party has made arrangements to protect personal information and that the information is only provided or disclosed to suitable persons.
6. Disclosing, revising, adding, deleting, or stopping/eliminating use of personal information
If a customer wishes to verify or revise personal information in the possession of Tosei Asset Advisors, the company shall handle the request promptly, to the extent that it is reasonable and necessary to do so. As part of this process, it may be necessary to verify the identity of the person making the request.
7. Secure management measures relating to third-party suppliers
In cases where Tosei Asset Advisors outsources the acquisition and handling of personal information to any third party, the supplier shall be obliged to implement rigorous management of personal information, and its performance shall be stringently monitored and supervised.
8. Internal training
Tosei Asset Advisors shall educate and train employees with regard to personal information protection and ensure that internal personnel are kept thoroughly informed.
The website of Tosei Asset Advisors may include links to external websites. The company bears no liability with regard to matters such as the protection of personal information on external sites accessed via these links.
Purpose of Using Personal Information
Tosei Asset Advisors shall use acquired personal information for the following purposes:
- To conduct solicitation and other sales activities, contract-related administrative procedures, etc., for the purpose of real estate leasing-related business
- To conduct solicitation and other sales activities, contract-related administrative procedures, etc., for the purpose of real estate management-related business
- To conduct solicitation and other sales activities, contract-related administrative procedures, etc., for the purpose of investment advisory business relating to real estate, securities, and other financial assets
- To conduct solicitation and other sales activities, contract-related administrative procedures, etc., for the purpose of Type II financial instruments business stipulated in the Financial Instruments and Exchange Act
- To conduct market trend analysis, customer satisfaction surveys, or research and analysis for product development, etc., relating to the above business
- To fulfill Tosei’s obligations, exercise its rights, or implement measures associated with fulfilling its obligations and exercising its rights
Personal information that has been legitimately obtained from the following public sources may be used for purposes 1 to 4 above.
- Real estate registers
- Cadastral maps
- Commercial registers
- Credit information agencies
- Other appropriately and legitimately disclosed personal information
Shared Use of Personal Data
The Tosei Group works to meet the diverse needs of customers by leveraging the combined strengths of its companies through consolidated management. As a result, personal data possessed by Tosei Asset Advisors may be shared with other companies in the Tosei Group, as outlined below.
- Users of shared information
In accordance with the applicable laws and regulations, data may be shared with companies covered by Tosei Corporation’s consolidated financial statements. The main companies belonging to the group are indicated in “Tosei Group.”
* N.B.: The specific companies are subject to change.
- Purposes of using shared information
Users of shared information shall use it for the following purposes:
- Developing, introducing, proposing, and supplying products and services related to real estate securitization business, real estate development business, real estate leasing business, real estate fund business, real estate management business, or alternative investment business (including sales activities such as information provision, accepting orders, delivery, billing and receiving and holding seminars, events, etc.) and marketing analysis (including market surveys on products and services conducted via questionnaires, etc.)
- Types of personal information for shared use
Details such as the customer’s name, address, date of birth, phone number, credit information, and transaction information shall be shared to the extent required for the “Purposes of using shared information” indicated above.
- Usage purpose
Contact information for inquiries about personal data management:
Tosei Asset Advisors, Inc.
4-2-3 Toranomon, Minato-ku, Tokyo 105-0001
Contact Information for General Inquiries Concerning Personal Information, Including Requests to Disclose, Revise, or Stop using Personal Information
Tosei Asset Advisors, Inc.
Risk Compliance Office
Tel.: +81-3-3436-2058 (Hours: 9 a.m. - 6 p.m., except Saturdays, Sundays, and year-end/start-of-year holidays)
With regard to revision, addition, or deletion of items recorded in the investors’ registry, please contact the investors’ registry administrator.
Mitsubishi UFJ Trust and Banking Corporation Securities Agency Division
Address: 7-10-11 Higashisuna, Koto-ku, Tokyo
Tel.: 0120-232-711 (toll-free only in Japan)
Tosei Asset Advisors is also a member of the Investment Trusts Association, Japan, and the Japan Investment Advisers Association. Inquiries, complaints, etc., regarding the handling of personal information by member businesses may be directed to either of these authorized personal information protection organizations.
Name: Investment Trusts Association, Japan investor support line
Hours: 9 a.m. – 11:30 a.m., 12:30 p.m. – 5 p.m. (except Saturdays, Sundays, national holidays, and holidays designated by the association)
Name: Japan Investment Advisers Association Secretariat Office complaint line (personal information manager)
Hours: 9 a.m. – 5 p.m. (except Saturdays, Sundays, national holidays, and holidays designated by the association)
Updated: May 30, 2017