Privacy Policy

Shirion Partners Co., Ltd. (hereinafter called “Company”) establishes and publishes this privacy policy (hereinafter called the “Privacy Policy”), as a policy for the handling of personal information and personal identification number (hereinafter collectively called the “Personal Information, etc.”) of its customers (hereinafter called “Customer” or “Customers”). The details are as follows:

1. Compliance with laws, regulations and rules
Company complies with any and all applicable laws, regulations, rules, and guidelines given by competent ministers of Japan with respect to the protection of the Personal Information, etc., as well as the Privacy Policy.

2. Purposes of use
Company handles the Personal Information, etc. of Customer to the extent necessary to achieve the purposes of its use, unless Company obtains a prior consent of such Customer or such Personal Information, etc. is handled as an exception in accordance with relevant laws or regulations, etc.
The purposes of use by Company of the Personal Information, etc. set forth in the Exhibit are posted at the head office and branches of Company as well as on its website.

3. Safety measures
Company strives to keep the Personal Information, etc. accurate and updated. Company takes necessary and appropriate measures for safety management of the Personal Information, etc. and properly supervises its officers and its outsourcing contractors entrusted by Company to perform any of its operations, for prevention of any leakage of the Personal Information, etc. of Customers.

4. Continuous improvements
Company reviews and revises the Privacy Policy from time to time and strives to continuously improve it for proper handling of the Personal Information, etc.

5. Procedures of request for disclosure, etc.
If Customer requests Company to disclose, correct or suspend the use of, etc. any personal data relating to such Customer and possessed by Company, Company strives to appropriately and promptly respond to such request, after confirming the identity of such Customer. If Customer requests Company to disclose whether Company possesses the personal identification number of such Customer or not, Company notifies such Customer of presence or absence of such possession.

6. Questions, opinions or complaints, etc.
Company is committed to prompt and sincere response to any and all questions, opinions or complaints received from Customers in relation to the Personal Information, etc.
Please feel free to contact the following department for any question, opinion or complaint, etc.

Contact : Compliance Department (phone number: +81-3-6804-6435)


Handling of Personal Information, etc.

1. Proper handling of Personal Information, etc.
(1) Company shall not obtain the Personal Information, etc. of Customers by fraudulent or any other wrongful means.
(2) If Company acquires the Personal Information, etc. of Customer from any third party, Company shall not wrongfully impair any interest or benefit of such Customer.
(3) Company may record any communication with Customers for its operational or business reasons, as needed. Company requests Customers to understand and accept such recording in advance.

2. Purposes of use of Personal Information, etc.
(1) Company shall use the Personal Information, etc. received from Customers only for any of the following purposes.
1) Sale, purchase, solicitation or offering, etc. of securities, and any other operation or business incidental to any of them (transfer of name, introduction of interest or redemption etc.);
2) Any other operation or business which financial instruments intermediary service providers are permitted to perform, and any other incidental operation or business.
(2) Examples of purposes of use:
1) Solicitation or sale of securities or financial instruments on the basis of the “Financial Instruments and Exchange Act” of Japan (hereinafter called the “Act”), or introduction of services for such securities or instruments;
2) Solicitation or sale of financial instruments provided by Company or its affiliated or partner companies, or introduction of services for such instruments provided by any of them;
3) Determination on the appropriateness of the provision of products or services in light of the principle of suitability, etc.;
4) Identification of Customer or any agent of such Customer;
5) Reporting to Customers on their transaction results, etc.;
6) Performance of clerical works relating to the transactions with Customers;
7) Exercise of rights or performance of obligations on the basis of the contracts with Customers or of applicable laws, etc.;
8) Research or development of financial instruments or services through market researches or surveys, data analyses or implementation of questionnaires, etc.;
9) Appropriate performance of the operations entrusted to Company, in the case where any other business operator, etc. entrusts Company to process all or any part of the Personal Information, etc., or otherwise;
10) Appropriate and smooth performance of the transactions with Customers.

Further, based on the Cabinet Office Ordinance of Japan on conduct control, etc. pertaining to financial instruments business operators, with respect to any information on race, creed, family origin, permanent legal domicile, medical care covered by insurance, history of crimes, or any other special non-disclosure information, Company shall not use such information for any purpose other than the purposes that Company reasonably considers necessary for its proper operations or for any other reason, nor provide such information to any third party.

3. Main sources for acquisition of Personal Information, etc.
The sources of the Personal Information, etc. acquired by Company include, without limitation, any of the following information.
1) Information directly filled out or entered by Customers in the application form for opening an account or on the website of Company;
2) Information described in commercially available books such as “Japan Company Handbook” or “Handbook on Directors of Japanese Companies”, or information published or released in newspapers or on the internet;
3) Information received from Customers through the provision of products or services.

4. Main entrusted operations
Company entrusts its outsourcing contractors to perform a part of its operations. The operations entrusted by Company to such contractors for the handling of the Personal Information, etc. include, without limitation, the following ones.
▪ Printing or dispatch of documents to be sent to Customers;
▪ Provision of professional advice, etc. relating to relevant laws or accounting;
▪ Operation or maintenance of information systems;
▪ Storage of ledgers, books and records relating to the operations.

5. Sharing of Personal Information, etc.
(1) Personal Information, etc, which may be shared
1) Name, date of birth, address, contact information, employment information, financial information and public information.
2) Detail of individual transactions.
3) Other information necessary to oversee client relationships.
(2) Scope of the sharing of Personal Information, etc.
Capital Partners Securities Co., Ltd.
(3) Reasons for the sharing of Personal Information, etc.
1) To provide services to customers.
2) To monitor Shirion Partners Co., Ltd.’s compliance and risk management as an Entrusting Financial Instruments Business Operator.
(4) Party responsible for the sharing of Personal Information, etc.
Shirion Partners Co., Ltd.