Privacy Policy
Legal & General Investment Management Japan Ltd. (hereinafter referred to as "the Company") establishes the following basic policy regarding the handling of personal information. Detailed procedures for handling personal information are stipulated in a separate document.
[Basic Policy]
1. Compliance with Laws and Regulations
The Company recognises personal information as an important asset of individuals and regards its appropriate protection as a significant responsibility. To fulfil this responsibility, the Company shall comply with the Act on the Protection of Personal Information (hereinafter referred to as the "Act"), other relevant laws and regulations, guidelines issued by regulatory authorities, rules established by self-regulatory bodies, as well as internal regulations and other norms.
2. Purpose of Use
The Company shall disclose the purpose of use of personal information by posting it on our website and displaying it in our stores, unless otherwise notified to the individual concerned. The Company shall handle personal information only to the extent necessary to achieve the disclosed purpose of use, except where consent has been obtained from the individual concerned or where exceptions are permitted by laws and regulations.
3. Proper Acquisition
The Company shall acquire personal information by lawful and fair means in accordance with laws and regulations, and shall endeavour to ensure that the content is accurate and up to date.
4. Joint Use with Third Parties and Provision to Third Parties
The Company shall not share personal information with third parties or provide it to third parties without the consent of the individual, except where required or permitted by laws and regulations, where shared within the Company Group, or where entrusted to achieve the purpose of use.
5. Appropriate Management
The Company shall establish internal regulations and management systems concerning the protection of personal information to prevent leakage, loss, etc. of personal information, and shall provide necessary training and education to its officers and employees. Furthermore, the Company shall exercise necessary and appropriate supervision over its officers and employees, as well as over contractors to whom the handling of personal data is outsourced.
6. Continuous Improvement
The Company endeavours to continuously improve its personal information protection framework to ensure the appropriate handling of personal information.
7. Handling Requests for Disclosure, etc.
Should requests for disclosure, correction, deletion, or suspension of use of retained personal data be made, we shall endeavour to respond appropriately and promptly after verifying the identity of the individual making the request.
【 Personal Information Handling Entity】
Name: Legal & General Investment Management Japan Ltd.
Address: Toranomon Kotohira Tower 22F, 1-2-8 Toranomon, Minato-ku, Tokyo
Representative: Nagahisa Miyabe, President and Representative Director
<Appendix: Handling of Personal Information>
1. Business Activities
Our business activities are as follows.
• Investment management services (discretionary investment management) and related activities
• Investment advisory and agency services (mediation in the conclusion of discretionary investment management agreements) and related activities
• Type II Financial Instruments Business and related operations
• Other business activities that may be conducted as an investment manager, investment advisory and agency business operator, or Type II Financial Instruments Business Operator, and related business activities
• Other business activities that the Company is authorised to conduct (including activities that may be authorised for handling in the future)
2. Purpose of Use
The purposes for which the Company uses personal information are as follows.
• For administrative purposes related to discretionary investment management agreements
• For administrative purposes related to the intermediation of discretionary investment management agreements
• For the purpose of handling matters relating to Type II Financial Instruments Business
• For other ancillary business-related administrative tasks
• For the provision of services related to the business conducted by our company
• To conduct solicitation and provide information concerning the businesses conducted by our company
• For suitability checks and identity verification related to our business activities
• To conduct market research and similar activities in order to provide better products and services
• To implement procedures required by laws and regulations
• For other purposes related to appropriate and smooth transactions and communication with customers and business partners
• For management control and internal management purposes
3. Proper Acquisition of Personal Information
The Company shall acquire personal information from customers and others, or through publicly available means, within the scope necessary for its business operations. Furthermore, with regard to sensitive information (political opinions, religious beliefs, labour union membership, race and ethnicity, family background and place of origin, health and medical information, sexual life, and information concerning criminal history) as defined in guidelines concerning personal information protection in the financial sector, etc. , we shall not acquire, use, or provide such information to third parties except where permitted by laws and regulations.
4. Appropriate Management of Personal Information
The Company endeavours to prevent the leakage, loss, falsification, unauthorised access, etc., of personal information. Based on practical guidelines concerning security management measures, etc., as outlined in the Guidelines on Personal Information Protection in the Financial Sector, the Company implements necessary security management measures, etc., to manage personal information appropriately. The Company's security management measures, etc., are as follows.
• Establishment of Internal Regulations: We have established internal regulations concerning personal information protection and the handling of personal information.
• Organisational Structure: We have appointed an overall manager responsible for personal information protection and designated personal information management officers for each department. We have also established a reporting system for incidents such as personal information leaks.
• Staff Training: We conduct regular internal compliance training sessions on personal information protection.
• Inspection and Audit: Regular inspections are conducted regarding personal information management, and this is subject to internal audits.
• Prevention of unauthorised access, leakage, loss, etc.: We implement access control, locking management of offices and equipment, system access restrictions, anti-virus measures, and restrictions on removal outside the premises.
• Understanding External Environments: When handling personal data overseas, we implement security measures after understanding the personal information protection systems in those countries.
5. Provision of Personal Data to Third Parties
The Company shall not provide personal data to third parties without the prior consent of the individual concerned, except in cases permitted by laws and regulations, such as the following:
• When required by law
• When necessary to protect human life, body, or property, and obtaining the individual's consent is difficult
• Where it is particularly necessary for the improvement of public health or the promotion of the sound development of children, and it is difficult to obtain the consent of the individual
• When cooperation is necessary for a national agency, local public entity, or their entrusted agent to perform duties prescribed by laws or regulations, and obtaining the individual's consent may impede the performance of such duties
• Where, concerning personal data provided to a third party, the provision of personal data identifying the individual to said third party is to be suspended at the request of the individual, and where the necessary details have been notified to the individual in advance or placed in a state where the individual can readily ascertain them
• When outsourcing the handling of personal data to an external party for the purpose of achieving the intended use
• When engaging in joint use as stipulated in the following paragraph
6. Joint Use of Personal Data
The Company may jointly use personal data as follows.
• Items of personal data subject to joint use: Personal information such as the name, address, telephone number, fax number, email address, date of birth, age, gender, occupation, position, and the name, telephone number, fax number, and email address of the place of employment of the contact person at corporate customers, etc.
• Scope of parties jointly using the data: Our ultimate parent company, Legal & General Group PLC of the United Kingdom, and its affiliated companies as listed in its securities reports and other documents. Furthermore, the affiliated companies jointly using the data shall be companies located in the United Kingdom or the EU, which are countries possessing personal information protection systems equivalent to that of Japan as stipulated in Article 28, Paragraph 1, Article 15 of the Regulations, namely companies located in the United Kingdom or the EU, which are countries possessing personal information protection systems equivalent to Japan's. Alternatively, they shall be companies to which the personal information protection policy established by Legal & General Group PLC in accordance with UK laws and regulations applies, and which are companies that have established a compliance framework as stipulated in Article 28, Paragraph 1 of the Act and Article 16 of the Regulations.
• Purpose of joint use: As stated in this Privacy Policy.
• Name and address of the entity responsible for managing the jointly used personal data, and name of its representative:
Name: Legal & General Investment Management Japan Limited
Address: Toranomon Kotohira Tower 22F, 1-2-8 Toranomon, Minato-ku, Tokyo
Representative: Nagahisa Miyabe, President and Representative Director
7. Entrustment of Personal Data
The Company may entrust all or part of its operations to third parties and provide necessary personal data to such contractors in order to smoothly advance operations required to achieve the purposes of use. The Company shall exercise necessary and appropriate supervision over contractors, including supervision of subcontractors.
8. Disclosure, Correction, Deletion, Suspension of Use, etc. of Personal Data
Where an individual or their authorised representative requests disclosure, correction, deletion, suspension of use (including cessation of provision to third parties), or records concerning transfers to third parties (hereinafter referred to as "disclosure, etc.") in writing (including electromagnetic records), we shall, after confirming that the request is from the individual concerned, respond within a reasonable period and to a reasonable extent, using the method specified by the individual, except in cases where disclosure, etc. is not required under laws and regulations, etc. If you wish to request disclosure, etc., please contact the following reception desk.
【Contact Point】 Legal & General Investment Management Japan Ltd. Compliance Department
Telephone: 03-5532-1920
9. Continuous Improvement
To ensure the appropriate handling of personal information, we shall conduct regular reviews of our personal information management systems and the status of personal information management, striving for continuous improvement.
10. Questions, Comments, Complaints, etc. Regarding the Handling of Personal Information
For any enquiries, comments, or complaints regarding our handling of personal information, please contact the following reception desk.
Contact Point
Legal & General Investment Management Japan Ltd. Compliance Department
Telephone: 03-5532-1920
11. Certified Personal Information Protection Organisation
Our company is a member of the following Certified Personal Information Protection Organisation. For complaints regarding personal information, please contact the designated complaint resolution office below.
[Name of Certified Personal Information Protection Organisation and Complaint Resolution Contact]
Japan Investment Advisers Association (General Incorporated Association) Complaints Consultation Office
Telephone: 03-3663-0505