Policies on the Protection of Personal Information

I. Name of Company Handling Personal Information

Financial Products Group Co., Ltd.

II. Privacy Policy

Statement on Safeguarding Personal Information

The business activities of Financial Products Group Co., Ltd. (hereafter, “FPG”, “the Company” and “we”) hinge on the financial products trading business,real estate business,insurance brokerage business,trust agreement agency business and M&A advisory business. Personal information collected from our clients in the course of executing these business activities and personal information about our executives and employees and their dependents (hereafter, collectively referred to as “personal information”) is vital to operations, and management recognizes that a concerted effort to safeguard personal information is an essential corporate social responsibility. Therefore, we will handle any personal information collected through our business activities in accordance with the following policies, and our commitment to protecting such information will not only give clients, executives and employees peace of mind but also fulfill our corporate duty.

Policies

1. Collecting, Using and Providing Personal Information

2. Laws, National Guidelines and other Standards (hereafter, “laws, etc.”)

We will strive to stay current on laws, etc. that pertain to operations involving the use of personal information, ensure that executives and employees engaged in our operations are aware of and comply with such laws, etc.

3. Security of Personal Information

4. Questions and Complaints

We will set up a point of contact for questions and complaints regarding our handling of personal information, establish and maintain a system to expedite actions if/when necessary, and respond with all sincerity to any questions and complaints that are brought to our attention.

5. Continuous Improvement

Hisanaga Tanimura
Representative Director-President
Financial Products Group Co., Ltd.

Established on April 28, 2008
11th Edition:Amended on Septemmber 1, 2016

III. Handling Personal Information

1. Person Responsible for Management of Personal Data at FPG

Personal Data Control Officer (Contact: See details under Contact Point for Questions and Complaints below.)

2. Purpose of Use

A. Purpose of Use of personal information except Specific Personal Information

Business Activities

Purpose of Use

Type of Personal InformationPurpose of Use
Client information
  • (1) To solicit, sell, trade, broker and offer financial products, insurance products or trust products (collectively, “Financial Products”) in accordance with the Financial Instruments and Exchange Law, Insurance Business Law, Trust Business Act and any other applicable laws and to undertake the handling of private placements along with the introduction and provision of associated services.
  • (2) M&A advisory business and associated operations.
  • (3) Real estate business (real estate specified joint enterprise and real estate brokerage) and associated operations.
  • (4) Trust agreement agency business and associated operations.
  • (5) To confirm the identity of clients or their agents, in accordance with the Law to Prevent Transfer of Criminal Proceeds and miscellaneous related laws.
  • (6) To confirm the authority of a corporate representative or its agent, when the client is a corporation.
  • (7) To determine if the solicitation, sale, trade, brokering or offering of products, handling of private placements or introduction and provision of services is client-appropriate, in light of such standards as the principle of suitability.
  • (8) To administer the process of contract execution with customers related to our services.
  • (9) To exercise rights and fulfill obligations, in accordance with contracts and laws related to our services.
  • (10) To ensure smooth and accurate execution of business with clients, including service-related communication connected with transactions as well as mailings, such as greeting cards.
  • (11)To facilitate the cancellation of transactions and follow-up after a transaction has been cancelled.
  • (12)To pursue research and development on financial products and services through market surveys, data analysis and questionnaires.
  • (13)To present and explain financial products and services and introduce upcoming seminars organized by the Company through direct mail and other means of contact.
  • (14)To present products and services offered by affiliated companies and other sources.
  • (15)To respond to client inquiries and comments.
  • (16)To ensure security of the Company, especially in regard to the use of information systems and access into facilities.
  • (17)To properly execute services outsourced to us in such cases where we are entrusted with all or some personal information processing tasks by another company.
Referrer (accountants, tax advisers, etc.) information
  • (1) To introduce our Financial Products.
  • (2) To introduce M&A advisory business and associated operations.
  • (3) To introduce real estate business (real estate specified joint enterprise and real estate brokerage) and associated operations.
  • (4) To introduce trust agreement agency business and associated operations.
  • (5) To confirm the authority of a corporate representative or its agent, when the referrer is a corporation.
  • (6) To administer the process of contract execution with referrers related to our services.
  • (7) To exercise rights and fulfill obligations, in accordance with contracts and laws related to our services.
  • (8) To ensure smooth and accurate execution of business with clients, including service-related communication connected with transactions as well as mailings, such as greeting cards.
  • (9) To facilitate the cancellation of transactions and follow-up after a transaction has been cancelled.
  • (10) To pursue research and development on Financial Products and services through market surveys, data analysis and questionnaires.
  • (11)To present and explain Financial Products and services and introduce upcoming seminars organized by the Company through direct mail and other means of contact.
  • (12)To present products and services offered by affiliated companies and other sources.
  • (13)To respond to referrer inquiries and comments.
  • (14)To ensure security of the Company, especially in regard to the use of information systems and access into facilities.
  • (15)To properly execute services outsourced to us in such cases where we are entrusted with all or some personal information processing tasks by another company.
Business partner informationTo facilitate mainly communication with business partners, fulfill contracts and request execution of agreements.
Shareholder information(1) To carry out stock-related procedures.
(2) To communicate with shareholders and respond to inquiries.
Information on individuals from whom we have received a request for materials or a question (clients, tax accountants, public accountants)To respond to inquiries and explain our services.
Information on job applicants, including successful hires(1) To screen individuals for employment and communicate with them.
(2) To execute administrative formalities for new hires.
Employee informationTo deal with hiring and labor issues, such as matters pertaining to personnel and general affairs.

B. Purpose of Use of Specific Personal Information

Type of Specific Personal InformationPurpose of Use
Specific Personal Information of the executives and employees of our group companies and their dependents
  • (1) Preparation, submission, etc. of certificates of employment income, retirement income and withholding taxes, declaration of exemption for dependents, declaration of exemption for insurance premium and special exemption for spouses and other registration statements, application, declaration, payment record, report, etc. (collectively “Registration Statements”).
  • (2) Preparation and submission, etc. of Registration Statements related to health insurance and welfare pension insurance.
  • (3) Preparation and submission, etc. of Registration Statements related to the insured in the third grade of the national pension plan.
  • (4) Preparation and submission, etc. of Registration Statements related to employment insurance.
  • (5) For the member of employees’ stock ownership association, preparation and submission, etc. of legally required documents on the association.
  • (6) For the stock option holder, preparation and submission of record of stock option exercise.
  • (7) Operation related to the (1)-(6) above.
Specific Personal Information of individual payees
  • (1) Preparation and submission, etc. of payment record for remuneration, fee, contract money and prize money.
  • (2) Preparation and submission, etc. of payment record for real estate rentals, etc.
  • (3) Preparation and submission, etc. of payment record of compensation for acquisition of real estate, etc.
  • (4) Preparation and submission, etc. of payment record of brokerage fee for sales or lease of real estate, etc.
  • (5) Operations related to the (1)-(4) above.

3. Termination of Direct-Marketing Materials

We use personal information in our direct-marketing activities, such as direct mail and telemarketing. However, we will refrain from using an individual’s personal information for this purpose, if that person submits a formal request to stop.

4. Procedures for Requesting Disclosure

We will respond to six types of requests: (1) Request for disclosure, (2) Request for notification of the intended use of personal information, (3) Request for corrections, (4) Request for additions, (5) Requests for deletion and (6) Request for termination of use or termination of provision to third parties (collectively, (1) to (6) are hereafter referred to as “Request(s) for Disclosure”) by you or your representative in regard to the personal information we have about you in our records. The procedures for requesting disclosure are outlined below.

a) Making a Request for Disclosure

A Request(s) for Disclosure must be made by mailing in a request for a form along with the documents required for a request for disclosure. When mailing us your request, please use a delivery-confirmation service, such as delivery-certified mail or simplified registered mail. Please write “Personal Information Request enclosed” on the envelope in red ink. After reviewing your request and documentation, we will mail you the appropriate form(s) for your Request(s) for Disclosure.

b) Submitting documents

To make a request for disclosure or notification of intended use, you must fill in all required fields on the proper request form and mail in the completed form along with one of the following documents that identifies you: driverユs license, resident card or health insurance card.

* Blacken out the field showing place of family registry (permanent address).

c) Request for Disclosure, etc. by an authorized agent

If you appoint an agent to request disclosure of personal information on your behalf, the following documents must be enclosed with the application form.

(1) One of the following documents (copy) identifying the person you have named as your authorized agent: driver’s license, resident card or health insurance card. * Blacken out the field showing place of family registry (permanent address).

(2) Power-of-attorney You must stamp the document with your registered seal and attach a seal impression registration certificate for the seal you have used. If your authorized agent is a legal representative, such as a person in parental authority, he/she may submit a document showing your relationship with him/her instead of the power-of-attorney.

d) Service charge on Request for Disclosure, etc.

For each request for disclosure of personal information or notification of purpose of use, we will apply a service charge of \1,050 (includes consumption tax). This amount must be paid by bank transfer to our designated account. The applicant is responsible for the cost of the bank transfer. Applicants should bear in mind that we will not be able to execute a request for disclosure or notification if the required fee is not paid in full.

e) Method of reply

We will reply in writing to the address of the applicant, as provided on the request form.

5. Contact Point for Questions and Complaints

For further information about personal information management at FPG or to ask a question or make a complaint, please contact the General Affairs Division by phone, postal mail or email.

Phone:
      0120-707-107 (toll-free in Japan)
Address:
      29th Floor, JPTOWER
      7-2, Marunouchi 2-chome
      Chiyoda-ku, Tokyo 100-7029
Hours:
      9am - 5pm (closed on days that the Company is not open for business, including weekends,
      national holidays and the year-end/New Year break)
email:
      click here