Policies on the Protection of Personal Information
I. Name of Company Handling Personal Information
Financial Partners Group Co., Ltd.
Statement on Safeguarding Personal Information
The business activities of Financial Partners Group Co., Ltd. (hereafter, “FPG”, “the Company” and “we”) hinge on the Leasing Fund Business,Real Estate Fund Business,Insurance Sales Business, and M&A 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.
1. Collecting, Using and Providing Personal Information
- We will collect personal information by lawful and fair means.
- We will use personal information only within the scope necessary to achieve the purpose of use.
- We will not provide personal information, except for Specific Personal Information, to a third party without the prior consent of the individual(s) concerned. We will not provide Specific Personal Information to a third party even if consented by the individual(s) concerned, except in cases that fall under any of the items of Article 19 of the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure.
- We will not use collected personal information for any use beyond the stated purpose.
- Should the need arise for personal information to be used beyond the stated purpose, we will obtain consent again for the revised purpose of use before actually using such 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
- We will establish and maintain a system to expedite swift corrective measures, to underpin the security of personal information and thereby prevent various risks to personal information, including unauthorized access, leaks, loss and destruction.
- We will perform inspections and immediately remedy any contravention or incident found. We will also implement pre-emptive measures to address weak points.
- We will provide thorough training for executives and employees to ensure the 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 and respond with all sincerity to any questions and complaints that are brought to our attention.
5. Continuous Improvement
- To ensure proper handling of personal information (hereafter, “Proper Handing”), we will monitor and audit compliance with internal rules concerning Proper Handling, to find violation, incidents, accidents or weaknesses (if any), while the management revising or re-considering it accordingly.
Financial Partners Group Co., Ltd.
Established on April 28, 2008
17th Edition: Amended on July 1, 2023
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
- Financial products trading business (securities trading, securities trading intermediary, private placement of securities, securities offering and services for handling private placement of securities) and associated operations.
- Insurance agency business and associated operations.
- M&A business and associated operations.
- Real estate fund business (real estate specified joint enterprise and real estate brokerage)
- Trust agreement agency business and associated operations.
【Purpose of use if obtained other than in writing directly from the person concerned】
|Type of personal information
|Purpose of use
|Accounting firm information by phone
|To provide information about our service
|Recruitment applicant information data obtained from recruitment agencies
|For employment consideration
|Data on publicly available information on qualified invoicing providers
|To comply with the Qualified Invoice System
Purpose of Use
|Type of Personal Information
|Purpose of Use
|Referrer (accountants, tax advisers, etc.) information
|Business partner information
|To facilitate mainly communication with business partners, fulfill contracts and request execution of agreements.
|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
|To 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 Information
|Purpose of Use
|Specific Personal Information of the executives and employees of our group companies and their dependents
|Specific Personal Information of individual payees
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 in regard to the personal information we have about you in our records and records provided by a third party (2) Request for notification of the intended use of personal information that we have (3) Request for correction of personal information that we have, (4) Request for addition of personal information that we have, (5) Requests for deletion of personal information that we have 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. The procedures for requesting disclosure are outlined below.
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 making the request in (1) above, you can choose either the providing electromagnetic records or delivering documents as the method of disclosure by us. 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.
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).
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.
When we receive the request to disclose personal information and records provided by a third party and notification of the purpose of use of personal information, we will apply a service charge of \1,100 (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.
When we disclose the request in (1) of Procedures for Requesting Disclosure, in principle, we will disclose it by the method selected by the requester. However, if you choose the method by providing the electromagnetic method and it is difficult for us to disclose it by that method, we will disclose it in writing to the address stated in the invoice of the claimant. In cases other than the above, we will reply in writing to the address of the applicant, as provided on the request form.
5. Safety management measures
We will take the following safety management measures to prevent leakage, loss or damage of personal data.
(a) We will formulate handling rules regarding the handling method, responsible person / person in charge, and their roles / responsibilities at each stage of handling personal data.
(b) We will appoint a person in charge of handling personal data and clarify the employees who handle personal data and the scope of personal data handled by those employees. We establish a system to report and contact the person in charge when we grasp the facts or signs of violating laws and regulations and handling rules.
(c) We will provide regular training to employees regarding points to note regarding the handling of personal data.
(d) In areas where personal data is handled, we will control the entry and exit of employees and restrict the equipment they bring in and will take measures to prevent unauthorized persons from viewing personal data.
(e) We will implement access control to limit the scope of the person in charge and the personal information database handled.
(f) When handling personal data in a foreign country, we will implement safety management measures after understanding the system regarding the protection of personal information in the country concerned.
6. 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 Compliance Department by phone or postal mail.
0120-504-393 (toll-free in Japan)
29th Floor, JPTOWER
7-2, Marunouchi 2-chome
Chiyoda-ku, Tokyo 100-7029
9am - 5pm (closed on days that the Company is not open for business, including weekends,
national holidays and the year-end/New Year break)