Touchstone Capital Management | Privacy Policy
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Privacy Policy

1. Compliance with Applicable Laws and Regulations

The Company understands the importance of protecting personal information and that it has an important responsibility to do so. It will abide by the Law concerning Protection of Personal Information, other related laws and ordinances, guidelines of competent authorities, and any other declarations by approved organizations representing the protection of personal information.

2. Purposes of Use of Personal Information

The personal information of customers collected by the Company will be used to the extent necessary in connection with the scope of our business and under purposes of use, and will not be used for any other purposes unless customers’ consent is obtained, or applicable laws and ordinances permit such usage. The Company will display its Privacy Policy and Purposes of Use of customers’ personal information in its head office.

Exceptional Cases

(1) When required under applicable laws and ordinances.

(2) When it is deemed necessary to protect the life or ensure the safety of individuals or protect property.

(3) When it is deemed especially necessary for the improvement of public health and the promotion of the well-being of children.

(4) When it is deemed necessary to cooperate with national governmental agencies, local municipal bodies or their proxies in order to perform the operations prescribed by laws and ordinances.

Scope of Our Business

(1) Real estate transaction consulting

(2) Sales, lease, brokerage, management and appraisal of real estate

(3) Real estate investment advisory

(4) Asset management consulting

(5) Type II Financial Instruments business

(6) Financial Instruments trader

(7) Financial instruments investment advisory and agency

(8) Money lending business

(9) Security and safeguarding business

(10) Investment in real estate and its securitized products

(11) All related businesses to those specified above

Purposes of Use

Purposes of use of personal information in connection with securities transactions:

(1) Soliciting, selling, and providing private placement, information, and services relating to securities and other financial products based on the Financial Instruments and Exchange Law;

(2) Soliciting, selling, and providing services and information relating to the financial products handled by the Company and its related and affiliated companies;

(3) Providing advisory services and executing lease agreements in accordance with Building Lots and Buildings Transaction Business Act and related ordinances;

(4) Reviewing the suitability of the products and services offered by the Company under the principle of suitability;

(5) Identifying individual customers, their agents or, where the customer is a legal entity, the person responsible for a particular transaction, including any representative or agent of such a legal entity;

(6) Informing a customer of the outcome of a transaction, account balances or any other matters;

(7) Carrying out administrative work in connection with any transaction with a customer;

(8) Carrying our research and development of products and services through market research, data analysis, and questionnaire surveys, etc.;

(9) Performing delegated services involving the handling of personal information in an appropriate manner on behalf of any other party;

(10) Any other purposes in connection with the adequate and smooth performance of transactions between the Company and its customers.

(11) Providing to any third parties to the extent necessary for the purpose of use to accomplish any of the above (1) to (10).

In addition, the Company in principal will not gather sensitive information such as information concerning an individual’s ethnic groups and/or race, political views, religion (religion, idea and belief), family origin and/or domicile of origin, health history/records, and/or criminal records and in the event it does acquire said information, it shall not use it or provide it to any third parties.

3. Providing Personal Data to Third Parties

The Company will not disclose any personal data to a third party without obtaining customer’s prior consent.
However, in addition to the cases stipulated in Article 2 under Exceptional Cases and where the receiving party is not considered a third party under relevant laws and regulations, the Company may provide and/or use personal data, while complying with relevant laws and regulations, to and from the following:
· Outsourcing parties
· Parties involved in mergers
· Members of corporate group

4. Handling of “Individual Number” and “Specific Personal Information” defined under “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures”

Except for purposes specifically stipulated by relevant laws and regulations, the Company will not acquire or utilize “Individual Number” and “Specific Personal Information”. In addition, the Company will not provide these information to third parties, unless specifically stipulated by relevant laws and regulations.

5. Assurance of Accuracy of Personal Data

To the extent necessary for the implementation of the purpose of use, the Company will make efforts to keep the personal data accurate and up-to-date. Unless a retention period is set forth under applicable laws or ordinances, the Company will establish the retention period for personal data in custody according to its purpose of use, and will erase or dispose of the relevant personal data after the elapse of the applicable period.

6. Safety Operational Procedure and Supervision over Outsourcing Parties

To protect customers’ personal information against unauthorized disclosure, loss or destruction, the Company will incorporate appropriate company organizations and strict security measures for the protection of personal information by means of establishing, and reviewing and revising from time to time, internal regulations regarding the protection of personal information. The measures include suitable “organizational”, “physical” and “technical” procedures to safeguard and secure the information that is collected.

Organizational Safety Operational Procedures

In order to ensure that personal information is safely maintained, the responsibility and access of the directors and employees will be clarified, safety procedures will be established and executed, and these procedures will be audited and reviewed.

Physical Safety Operational Procedures

Agreements with directors and employees regarding the non-disclosure of personal information will be entered into and directors and employees shall be trained and educated on the issues. To ensure that personal information is securely managed, directors and employees will be monitored.

Technical Safety Operational Procedures

Technical safety measures to ensure that the information systems to manage the personal information, including access control and system monitoring, will be discussed.

Supervision over Outsourcing Parties

When entrusting the handling of personal information, the Company will make appropriate selection of outsourcing parties, and take necessary and appropriate control measures to ensure its security.

7. Review and Amendment of This Policy

The Company will review and amend this policy in accordance with the personal information protection regulations and related manuals, and take any proper measures regarding the personal information protection management system and the Company’s operational structure necessary to ensure the security of Personal Information.

8. Request for Disclosure of Personal Information

When the principal requests disclosure, correction, suspension of use, etc. of his/her personal information, the Company will promptly respond to such request after verification of the identity of the applicant or his/her agent. The Company, upon request from the applicant or a representative, will undertake the process in a timely manner as described below.

(1) Specify which personal information to request for disclosure, correction, suspension of use, etc. (Applicant’s Name, Address, Phone Number, Birth Date, Name of Company he/she works for, Account Balance, Trading Record, etc.)

(2) The Company head office compliance office will be the interface for the procedure.

(3) Necessary Items

a. Application Form stored in the Head Office

b. ID of Applicant (for example a copy of a Driver’s License)

c. If a representative of the applicant, the right to represent the principal will be confirmed, and depending on the relationship with the applicant, additional paperwork may need to be submitted

(4) In addition to a response to the applicant or his/her representative verbally at our office, a response can be mailed to an address designated by the applicant.

(5) Any information obtained in this request process to identity the applicant and his/her representative will be used for this investigation or to verify the applicant or the representative’s identity.

(6) If such request is denied, applicant or his/her agent will be informed of our denial decision along with its reason.

9. Complaints and Consultations concerning Personal Information

The Company will strive to respond to questions or comments about personal information in a timely and sincere manner. Please address any inquiries or comments to the Company head office in writing or otherwise below:

 

Compliance Department
5-4-7 Akasaka, Minato-ku, Tokyo 107-0052, Japan
TEL: +81-3-5114-6622
Office Hours: Weekdays from 9:30 a.m. through 5:00 p.m.