Privacy Policy | JAPAN POST INVESTMENT CORPORATION

Japan Post Investment Corporation (hereinafter, “we” or “us”) recognizes that it is important for us to protect and handle personal information adequately. Therefore, we have established this principle on personal information protection (hereinafter, the “Privacy Policy”) and are committed to implementing it accordingly.

1. Compliance of Applicable Laws and Regulations

We recognize that it is our social responsibility to protect and use personal information adequately when we handle personal information. We comply with the Act on the Protection of Personal Information (hereinafter, the “Act”) and all other applicable laws, regulations and guidelines (hereinafter, collectively, the “Laws”) in our business activity.

2. Collection of Personal Information

We disclose the purpose of collecting personal information through public announcements, notifications, clear statements or other appropriate means. Personal information is collected only to the extent necessary to achieve the intended purpose and only by lawful and appropriate means. We do not collect personal information through deception or other improper methods. We do not collect Special Care-Required Personal Information (as defined under the Act) without the prior consent of the data subject unless such collection is permitted under the Laws.

The personal information that we collect includes the following:

(1) Personal information obtained in the course of our own business activities
(2) Personal information of the members, other constituents or related parties of any funds in which we are involved in the formation or management (including funds of which we are a member, funds contributed by such funds, and funds in which our subsidiary is a member; hereinafter, collectively, the “Funds”).

3. Purpose of Use of Personal Information

We handle your personal information only solely to the extent necessary to achieve the purposes of use listed in item (2) below and solely in connection with the business activities listed in item (1) below (including those related to the Funds) and we do not handle personal information beyond this scope, except where we have obtained the prior consent of the data subject or where such usage is permitted under the Laws.

Additionally, we do not use personal information in an inappropriate manner that may promote or induce illegal or wrongful acts.

(1) Business Activities^※1

a. Investment management, investment advisory/agency services related to securities
b. Acquisition and holding of securities
c. Formation, management, and operation of funds and management of their assets
d. Solicitation and sale of interests in funds
e. Facilitation of mergers, demergers, business transfers, and alliances in capital, business, technical, sales, and manufacturing
f. Consulting services on fundraising, finance and general corporate management
g. Outsourcing of accounting and due diligence services related to investment business

(2) Purpose of Use^※2

a. To provide information on financial products and related services
b. To perform administrative operations related to investment management or investment advisory/agency services
c. To report to clients on investment performance and contract asset balances related to investment management services and analysis results related to investment advisory/agency services
d. To perform administrative operations related to the formation and operation of Funds
e. To report to clients on fund performance
f. To source potential investment opportunities
g. To plan capital and financial strategies for potential investee companies
h. To assess the feasibility of investments through research and evaluation of the business, technology and products of potential investee companies
i. To exercise or perform statutory or contractual rights and obligations, and to handle other administrative matters related to investments
j. To verify client identity in accordance with applicable laws and regulations and to confirm their eligibility to purchase or utilize financial products and services
k. To disclose information to third parties within the scope necessary for the appropriate execution of business
l. To properly perform outsourced tasks when the processing of personal information is delegated to us in whole or in part
m. To conduct market research and to perform data analysis and surveys for the purpose of researching and developing financial products and services
n. To propose and provide information on various products and services of affiliated companies
o. To ensure appropriate and smooth transactions with clients

4. Security Control Measures

We take appropriate security control measures to prevent loss, alteration, and leakage of personal data. In addition, we properly supervise our employees and contractors. Specifically, the following security control measures are implemented for the management of personal data:

(Information Management Policy)

To ensure proper handling of personal data, we have established an information management policy covering compliance with relevant laws and guidelines as well as the handling of inquiries and complaints.

(Procedures for Handling Personal Data)

We have established detailed procedures that for each phase in personal data processing, including acquisition/input, use/processing, storage/preservation, transfer/transmission. Responsible officers and their duties are clearly designated for each phase.

(Organizational Security Control Measures)

We have appointed officers responsible for personal data management and set up a reporting process to promptly inform them of any actual or potential violations of laws or procedures.
Additionally, we conduct regular self-inspections and are subject to audits performed by other departments or external parties.

(Personnel Security Control Measures)

We provide regular training to employees on the handling of personal data.
Confidentiality obligations regarding retained personal data are included in our work regulations and these provisions are regularly communicated and reinforced through employee educations.

(Physical Security Control Measures)

We handle personal data exclusively in secured areas. In these areas, we control access to the areas and restrict the equipment that can be brought in. Additionally, we implement measures to prevent unauthorized individuals from accessing or handling the personal data.
We implement measures to prevent theft or loss of equipment handling personal data, electronic media, and documents containing personal data. Even when transferring such items within our premises, we take steps to ensure that personal data is not easily accessible.

(Technical Security Control Measures)

We implement access control to limit the scope of employees and personal information databases.
IT systems that retain personal data are protected from unauthorized access or malicious software from external sources.

(Data Retention in Foreign Countries)

When retaining personal data in foreign countries, we implement security measures in accordance with applicable local data protection regimes.

(Supervision of Employees)

Employees handling personal data are subject to confidentiality obligations stipulated in internal regulations. We provide education and training and conduct inspections and audits to ensure compliance with security measures.

(Supervision of Contractors)

When outsourcing all or part of personal data handling to third parties, we require the contractors in writing to implement security measures equivalent to ours and conduct regular monitoring and appropriate supervision to ensure compliance.

5. Disclosure to Third Parties

We do not disclose your personal data to third parties without your prior consent except as required under Laws.

6. Collection of Sensitive Information

We do not collect, use, or disclose to third parties any Special Care-Required Personal Information, nor information related to labor union membership, lineage, place of origin, health care, and sexual life (excluding those that qualifies as Special Care-Required Personal Information) except as stipulated by the Guidelines for Personal Information Protection in the Financial Sector. Such information does not include information that is publicly available by the data subject, national or local government bodies or entities specified in the Act or its Enforcement Rules, nor information that is clearly apparent through direct observation or photography of the data subject.

7. Request For Disclosure

We promptly and appropriately respond to any request for (i) notification of the purpose of use, (ii) disclosure, correction or deletion of the retained personal data (as defined under the Act), (iii) suspension of use or erasure of the retained personal data, (iv) suspension of provision of the retained personal data to third parties or (v) disclosure of records regarding the retained personal data provided to third parties (hereinafter, the “Request For Disclosure”) in accordance with Laws. For detailed procedures, please contact the Privacy Information Support Desk listed in “9. Contact Information” below.

8. Ongoing Improvement

We continuously review and strive to improve our personal information protection framework and initiatives in light of developments in information technology and changes in social expectations.

9. Contact Information

For inquiries regarding our handling of personal information, Request for Disclosure or complaints, please contact the following support desk.

Japan Post Investment Corporation Privacy Information Support Desk
Tel: 03-6457-9881
Reception Hours: 10:00 am to 5:00 pm (JST) on our business days (generally, excluding Saturdays, Sundays, public holidays and year-end and new year holidays)

Note 1: The services are conducted within the scope of applicable laws and regulations.
Note 2: We conduct fund-related activities as a partner, member or related party of the Funds. The Funds and we are legally separate and independent entities. We do not assume any liability for the obligations of the Funds.