2025/5/1
Capital Trust Japan Company Limited
Address: Ark Mori Building 31F, 1-12-32 Akasaka, Minato-ku, Tokyo
Representative Director: Hiroyuki Kamioka
(hereinafter referred to as "our company") considers customer trust to be our number one priority, and strives to appropriately handle and protect the personal information of customers entrusted to us in accordance with the following policy while complying with applicable domestic and foreign laws and regulations regarding the protection of personal information.
The terms used in the following privacy statement (personal information protection policy) are defined as follows: -
・[Personal information] refers to information about a living individual that can identify a specific individual based on the name, date of birth, and other descriptions contained in the information (including information that can be easily collated with other information and thereby identify a specific individual) and personal identification codes, etc., as defined in Article 2, Paragraph 1 of the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act").
・[Personal data] refers to a collection of information including personal information, which is systematically organized so that specific personal information can be searched using a computer, or, even if a computer is not used, such as a customer card arranged in alphabetical order, which is systematically organized so that specific personal information can be easily searched by organizing it according to certain rules, and which is placed in a generally easily searchable state using a table of contents, index, code, etc.
・[Personal data] refers to personal information that constitutes a personal information database, etc. It also includes information downloaded from a personal information database, etc. to a recording medium and printed on paper (or a copy thereof).
・[My number] refers to a number obtained by converting a resident record code, as provided for in the Act on the Use of Numbers to Identify Specific Individuals in Administrative Procedures (hereinafter referred to as the "My Number Act"), which is designated to identify the person related to the resident record in which the resident record code is written (a number, symbol, or other code that corresponds to an individual number and is used in place of the individual number, including numbers other than the resident record code), and includes information related to deceased persons that does not fall under "personal information".
・[Specific personal information] refers to personal information that includes an individual number in its contents.
・[Specific personal information] refers to personal identification numbers and specific personal information.
1. Acquisition of personal information
We will acquire personal information through legal and fair means.
Regarding the source of personal information, we will acquire personal information, etc. mainly through documents and materials submitted by customers. We may also acquire personal information in connection with transactions with customers and products and services provided. In addition, depending on the products and services you desire, we may acquire additional personal information about you, such as acquiring your credit history from a consumer credit information agency. We may also acquire personal information through job application forms, employment agencies, our employees, our group companies, and other third parties for recruitment purposes.
In addition, when providing financial services to customers, we may acquire your personal information, etc. through monitoring or other means (such as recording telephone calls and monitoring emails) in accordance with applicable laws and regulations. We do not access such information constantly or on a regular basis, but may use it for compliance and security purposes.
2. Use of Personal Information
We will use personal information only to the extent necessary to carry out the following business activities permitted by law, within the scope of the purposes of use that have been publicly announced or notified or clearly stated at the time of acquisition, and will not use the information for any other purposes.
◉ Trust business including money trusts, money trusts other than money trusts, monetary claim trusts, real estate trusts, personal property trusts, securities trusts, and comprehensive trusts
◉ Agency services for the acquisition, management, disposal, or leasing of assets of the SPC, and for the reorganization or liquidation of assets of the SPC, agency services for the collection of claims on behalf of the SPC and its creditors or debtors, and agency services for the performance of debts
◉ Transaction management business, accounting business
◉ Bond management company operations
◉ Businesses that trust companies may operate pursuant to laws and regulations (including businesses that will be permitted to be handled in the future)
◉ Property management services
◉ Safekeeping
◉ Business operations for which the use of personal numbers is permitted under the Numbering Act in connection with the above business operations
3. Purpose of use of your personal information and its disclosure
In order to safely and reliably conduct transactions with customers and provide better financial products and services, we obtain personal information about customers to the extent necessary. The most common information is the customer's address, name, date of birth, place of employment, telephone number, other contact information, role, position, title, professional responsibilities, etc. In addition, when starting a transaction, information such as asset status, credit history, personal number, and information for identity verification may be required. We obtain and use this personal information for the following purposes within the scope specified in the Personal Information Protection Act and other laws and regulations applicable to our company. In addition, in accordance with these applicable laws and regulations, we will not use or provide to third parties information on the ability to repay loans provided by personal credit information agencies for purposes other than investigating the ability to repay. In addition, we will not use or provide to third parties special non-public information such as information on race, creed, family origin, domicile, health care, or criminal history, which is specified by law as sensitive information or sensitive personal information, for purposes other than those deemed necessary for appropriate business operations or other purposes permitted by law. In addition, in accordance with the Numbering Act, personal numbers will not be used or provided to third parties for any purposes other than those for the specific personal information, etc. listed below.
Purpose of Use
1. Purpose of use of personal information (excluding specific personal information, etc.)
◉ To solicit and sell various financial products and provide information on services
◉ To accept applications for financial products, trust products and services, such as opening accounts for various financial products
◉ To fulfill identity verification obligations under the Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act and other laws and regulations
◉ To manage ongoing transactions, such as managing deadlines in trust transactions, etc.
◉ To manage and operate our entrusted assets
◉ To provide personal information to third parties to the extent necessary for the appropriate performance of business operations when managing and operating entrusted assets, etc.
◉ To carry out other business, such as cash management operations To carry out business entrusted to us by businesses, etc.
◉ To judge the appropriateness of the provision of financial products, trust products, and services, such as in light of the principle of suitability, etc.
◉ To properly carry out the entrusted business in cases where we have been entrusted with all or part of the processing of personal information by other businesses, etc.
◉ To exercise rights and fulfill obligations based on contracts with customers and laws, etc.
◉ To conduct market research, as well as research and development of financial products, trust products, and services through data analysis, surveys, etc. ◉ To send out various proposals regarding financial products, trust products, and services, such as sending direct mail
◉ Capital Services To make various proposals regarding financial products, trust products and services of the Group, or affiliated or partner companies, etc.
◉ To cancel various transactions and manage administrative tasks after transaction cancellations
◉ To conduct internal market research, development and research of financial products and services, and send various research reports, etc.
◉ To comply with applicable laws and regulations of Japan and foreign countries, manage risks, improve services, carry out our business, and for internal management purposes
◉ To conduct various investigations and analyses and prepare documents, etc. at the request of central and local governments, regulatory authorities, tax authorities, other administrative authorities, judicial organizations, exchanges, or self-regulatory organizations of Japan and foreign countries
◉ To confirm that you are the customer or that you are an agent of the customer
◉ To report transaction results, account balances, etc. to customers
◉ Administrative tasks related to transactions with customers
◉ To obtain information necessary to respond to customer inquiries
◉ To send seasonal greetings, etc., and to provide information on various seminars, receptions, etc.
◉ For other purposes to properly and smoothly carry out transactions and contracts with customers (including trust agreements, commission agreements, etc.)
◉ For personnel recruitment
2. Purposes of Use of Specific Personal Information, etc.
◉ Preparation and provision of legal documents related to trust transactions
◉ Preparation and provision of payment statements for remuneration, fees, etc. related to customers
◉ Preparation and provision of payment statements for customer dividends, surplus distributions, and fund interest
◉ Preparation and provision of payment statements for real estate usage fees, etc. to customers related to our business
◉ Preparation and provision of payment statements for consideration for the transfer of real estate, etc. related to customers
◉ Preparation and provision of other legal documents where the personal number must be included pursuant to laws, regulations, etc.
4. Shared use of personal data
Within the scope of the above-mentioned purposes of use, your personal data (excluding specific personal information, etc.; the same applies below in this section on joint use) may be shared between our company and Capital Services Group (including the group companies listed below). However, this does not apply when customer consent is required for joint use by law, etc.
Our group companies
◉ Capital Servicing Co., Ltd.
◉ Capital Advisory Japan Co., Ltd.
Items of personal data to be shared
◉ Name, address, date of birth, occupation, name of affiliation (company), job title, workplace address, telephone number, facsimile number, email address, information about the customer, such as information listed on a person's resume
◉ Information about the customer's transactions
◉ Information about the customer's needs
Name, address and name of representative of person responsible for the management of personal data related to the joint use
Capital Trust Japan Company Limited
Address: Ark Mori Building 31F, 1-12-32 Akasaka, Minato-ku, Tokyo
Representative Director: Hiroyuki Kamioka
If it becomes necessary to use your personal information beyond the scope of the original purpose stated when you provide us with it, we will notify you of or announce that purpose in advance, except in certain cases specified by law, etc.
5. About outsourcing
We outsource part of our business operations. Regarding the handling of personal data by outsourcee and subcontractors, we outsource the handling of personal information, etc. within the scope of our purpose of use, and after making an appropriate selection of the relevant outsourcee in accordance with applicable laws and regulations of Japan and foreign countries and this policy, we obtain consent that your personal data will be properly managed by the outsourcee and supervise the outsourcee. The main outsourced operations are as follows:
◉ Printing or shipping of documents to be sent to customers
◉ Operations related to the operation and maintenance of information systems
◉ Creation and storage of accounting documents related to business operations
6. Provision and receipt of personal data to third parties
Except as provided by laws, regulations, etc. and this policy, we will not provide your personal data (excluding specific personal information, etc.; the same applies below in the section on third-party provision and receipt) to a third party without your prior consent. In addition, when we provide personal data to a third party, we will conduct an appropriate investigation of the third party and provide appropriate supervision to ensure confidentiality. In such cases, the method of communication to the third party will be distribution/sending of documents (including electronic and magnetic methods) or oral. In addition, the personal information contained in the personal data provided to the third party will include address, name, date of birth, place of employment, telephone number and other contact information, role, position, title, position, and other personal information necessary for the accomplishment of the purposes of use described in this policy. In addition, if you request, we will stop providing personal data that can identify you to a third party. Specific personal information, etc. will not be provided to any party other than those confirmed to be necessary for the purposes of use specified above (contractors performing the relevant business and administrative agencies such as tax offices that request the submission of personal numbers). Furthermore, we will not transfer your personal data to a third party for a fee. When receiving personal data from a third party, we will receive it to the extent permitted by law and handle it in accordance with the law.
7. Management of personal information
◉ We take appropriate safety management measures to keep your personal information accurate and up-to-date.
◉ We take appropriate measures to prevent unauthorized access to your personal information.
◉ We take appropriate information security measures, such as measures against unauthorized access and computer viruses, to prevent the loss, destruction, falsification, and leakage of personal information.
◉ We require companies that are commissioned by us to handle your personal information to similarly manage it appropriately.
8. Requests for disclosure, correction, suspension of use, deletion from customers
If you have a request for disclosure, correction, suspension of use, deletion, or suspension of provision to a third party of personal information held by our company, or for disclosure of whether or not our company holds your personal number, we will respond according to our designated procedures after confirming that the requester is the person in question, unless there is a special reason. Please note that a fee may be charged for disclosure. For more information, please contact us at the address listed below.
9. Contact Information
Please contact us using the details below if you have any inquiries regarding the disclosure, correction, suspension of use, suspension of provision to third parties, or deletion of your personal information, or if you have any other questions.
Capital Trust Japan Company Limited
Compliance Department
ARK Mori Building 31F, 1-12-32 Akasaka, Minato-ku, Tokyo, 107-6031
TEL ：03-6230-5260 (Main)
Contact hours ： 9:00 ～ 17:30
(excluding bank holidays and Year End and New Year's holidays)
10. Authorized Personal Information Protection Organization
Our company is a member of the following organization, which is a certified personal information protection organization certified under the Personal Information Protection Act. The organization below accepts complaints and inquiries regarding the handling of personal information by member companies.
Trust Association (Trust Consultation Center)
http://www.shintaku-kyokai.or.jp/profile/profile04.html
[Complaints/Inquiries Desk] Telephone: 03-6206-3988 or 0120-817335 (toll free)
11. Revisions
The contents of the above information may be changed based on amendments to laws and regulations or other reasons. In such cases, the change will be posted on our website, etc., and the change will be effective from the time it is posted.
12. Compliance with laws and regulations, and improvements and refinements
In order to implement this policy, we will comply with laws and regulations regarding the protection of personal information and will strive to improve and enhance our handling of customers' personal information as appropriate.a
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