Privacy Policy

Nikko Research Center, Inc. (hereinafter termed “the Company”) herein declares its basic policy on the protection of Personal Information (hereinafter termed “Basic Policy”).
The Company is fully aware of its social responsibility to safeguard the Personal Information of customers when engaging in business activities. Based on this understanding, the Company confirms that all of its Employees will comply faithfully with the Law Governing the Protection of Personal Information, other laws and regulations, and the Company’s Basic Policy, and that the entire Company is committed to fair and appropriate handling of Personal Information.

Personal Information will be used within the limits necessary to achieve the purposes of use listed below, and such information shall not be used exceeding the limits necessary to achieve the said purposes. Further, the Company shall not modify the purposes of use exceeding the limits recognized to be fair and rational.

• For the purpose of undertaking commissioned research on asset management.
• For the purpose of providing information and performance rating on asset management to the Company's clients.
• For the purpose of conducting investment advisory services.
• For the purpose of conducting research and consulting of pension plans and system.
• For the purpose of conducting the Company's proprietary research.
• For the purpose of undertaking commissioned services on education and training of finance and investment.
• For the purpose of undertaking services commissioned by third parties.
• For the purpose of conducting the Company's own business, reporting, and handling inquiries.
• For the purpose of business management and internal control and administration of the Company and affiliated companies.

The Company may use and share Personal Data as follows:

(1) Items of Personal Data to be shared and used

• Information on the customer, such as name, address, date of birth, occupation
• Information related to transactions of the customer, such as transaction details, outstanding deposits, etc.
• Information on customer needs, such as in asset management

(2) The range of parties authorized for shared use

• The Company, "SMBC Nikko Securities Inc." (The Company’s parent company), and the consolidated companies and equity method affiliates of "SMBC Nikko Securities Inc.".

(3) Purposes of use by using parties

• For the purpose of a full range of research, development, information service and supply of the best and most appropriate products and services that match the needs of the customers in asset management, etc., through coordination of the entire SMBC Nikko Securities Group led by " SMBC Nikko Securities Inc." as the holding company of the entire group.
• For the purpose of business management and internal control and administration of the group companies led by " SMBC Nikko Securities Inc." as the holding company.

(4) Name of the party responsible for the management of Personal Information shared use:

• SMBC Nikko Securities Inc. (The Company’s parent company)

The Company shall not collect, use or provide to third parties information on political views, credo (religion, philosophy, and beliefs), membership of labor unions, race or ethnic group, family origin or permanent domicile, matters related health and medicine, habits related to sexual activity, or criminal record (hereinafter called“Sensitive Information”), except under the conditions described below. If such information is to be collected, used, or provided to third parties under the conditions described below, the information shall be handled with special attention and caution to avoid collection, use, or provision to third parties exceeding the extent of the said conditions.

1. In case of applications of laws and regulations.
2. In case of needs for the protection of human life, health, or property.
3. In case of special needs for improvements to public health or promotion of sound development of children.
4. In case of needs for cooperation with a government organization, local government entity or party designated by those for the execution of their affairs designated by law.
5. In case of collection, use or provision to third parties of Sensitive Information regarding membership of political, religious, or other organization, or labor union of Employees, etc.within the scope necessary for the execution of withholding tax affairs etc.
6. In case of collection, use, or provision to third parties of Sensitive Information within limits necessary in execution of transfer of rights and obligations in inheritance administration procedure etc.
7. In case of collection, use, or provision to third parties of Sensitive Information within the limits necessary in the execution of business with the consent of the Person in Question, due to the need to ensure appropriate proceedings of securities business and other business activities in the financial field.
8. In case of use of biometric information classified as sensitive information to confirm the identity of a person, with consent of the Person in Question.

1. The Company shall not collect Personal Information using fraudulent or other unauthorized means.
2. When Personal Information is collected from third parties, the Company shall not improperly infringe the interests of the Persons in Question. Moreover, the Company shall not collect information from third parties that have employed illegal means to collect Personal Information with the knowledge that such Personal Information in question had been leaked illegally.
3. The Company may collect Personal Information of customers using the following methods:
   1. Collection of Personal Information from third parties, such as database services, etc.
   2. Collection through audio recordings, video recordings, reception of e-mail, etc.
   3. Collection of information found in government bulletins, newspapers, magazines, Internet, etc.
4. If Personal Information is not provided as requested by the Company, all or part of the Company’s services may not be available.

The Company shall indicate the purposes of use of Personal Information on its Web site.
The Company shall explicitly specify the purposes of use of Personal Information in advance, when the Company obtains Personal Information directly from the Person in Question in writing.

The Company shall make the efforts to guarantee that Personal Data is accurate and up-to-date within the range necessary to achieve the purposes of use.

The Company shall implement measures that are necessary and appropriate for Personal Data security, such as prevention of leakage or loss of, or damage to Personal Data collected, by establishing a basic policy and regulations on security management and the necessary administration pertaining to security management measures.
Necessary and appropriate measures include the following.

1. The responsibilities and authority of Employees regarding the management of Personal Data security are clearly defined. Regulations related to security management, etc., have been developed and implemented, and inspection and audits are executed to examine the state of implementation.
2. Contracts, etc., are concluded with Employees on non-disclosure of Personal Data, and employee training, and other programs are executed for the necessary and appropriate supervision of Employees in ensuring the management of Personal Data security.
3. Technical measures are implemented for the management of Personal Data security, such as access control to Personal Data and information systems handling Personal Data, surveillance of information systems, etc.

The Company shall not provide Personal Data to a third party, except under the conditions below:

1. With the advance consent of the Person in Question.
2. In case of application of laws and regulations.
3. In response to inquiry or investigation by taxation office, investigative organization, juridical body and other external organizations, etc.
4. In case of need for the protection of human life, health, or property, and when the consent of the individual in question is difficult to obtain.
5. If all or part of Personal Data handling is commissioned to others, within the range necessary for the achievement of the purposes of use.
6. In case of provision of Personal Data due to consolidation or succession of business by other reasons.
7. In case of shared use of Personal Data based on Article 3 of the Basic Policy.
8. In other cases authorized by relevant laws and regulations.

The Company may outsource all or part of its handling of Personal Data within the range necessary for achievement of the purposes of use.
In such a case, the Company will execute necessary and appropriate supervision over the contractors to which Personal Data handling is outsourced, in order to ensure Personal Data security.

The Company will accept requests for notification of use purpose, disclosure, revision, addition, deletion, suspension of use, and removal or suspension of provision to third parties related to Collected Personal Data (hereinafter called “Disclosure”) in compliance with the application procedure designated by the Company. The guide is outlined below:

1. Contact when requesting Disclosure.
   Requests are accepted by Corporate Planning & Administration, Nikko Research Center, Inc.
2. Forms to be submitted to request Disclosure.
   Please submit the Application for Personal Information Disclosure designated by the Company. The application form can be downloaded and printed from the Company’s web site.
3. Method of confirmation of identity for the applicant or proxy requesting Disclosure.
   Documents for authenticating identity as designated by the Company must be submitted.
4. Charges and collection of payment
   Charges will be made in accordance with the method designated by the Company in case of notification of the use purposes or disclosure.

The Company will properly handle inquiries, complaints, etc., regarding the handling of Personal Information. All inquiries, complaints, etc., should be directed to:

• Complaint office, Nikko Research Center, Inc.
  Tel: +81-3-5677-7800

The Company shall review the content of the Basic Policy as needs arise and revise it.
The revised Basic Policy will be published on the Company’s Web site.

Specific terms used in the Basic Policy are defined as follows:

1. “Personal Information” is information concerning a living individual (including the customers, Employees of the Company, and other persons related to business enterprises, etc.), such as name, date of birth, and other descriptions, code or number attached to each individual, and visual and auditory data that can identify the individual (including information that cannot identify the individual by itself but can easily identify the said individual when associated with other information).
2. “Personal Information Database, etc.” is the aggregate of information, including Personal Information, which has been organized systematically for searching into specific Personal Information with computer, etc.
3. “Personal Data” is Personal Information that makes up the Personal Information Database, etc.
4. “Collected Personal Data” is Personal Data for which the Company is able to disclose, revise, add, delete, suspend the use, remove and suspend provision to third parties, but excludes information that may infringe public interests and other interests through disclosure of its presence or absence, or information that is expected to be removed within six months (excluding information that is to be updated).
5. “Person In Question” is the specific individual who can be identified through the Personal Information.
6. “Employees” are persons who are engaged in the Company’s business activities under direct or indirect supervision and management of the Company within its organization, including workers with established employment relationships (executive directors, full-time employees, contractual employees, part-time workers, etc.) and also those without an employment relationship with the Company (directors, executive officers (shikoyaku), auditors and workers assigned from temporary manpower services).

• Published April 1, 2005
• Updated October 1, 2009
• Updated July 16, 2019