POLICIES
Privacy Policy
In light of the importance of protecting personal information, and in order to further improve the trust of society in our business, we will handle personal information and individual numbers (hereinafter referred to as "personal information, etc.") in compliance with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Law") and the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter referred to as the "Number Act") and other related
laws and regulations and take appropriate measures for safety management of personal information and individual numbers (hereinafter referred to as "personal information, etc.") and strive to prevent leakage accidents, unauthorized outflows, etc of it.
Through education and training for employees, we will strive to handle personal information, etc. appropriately, such as not using it for any inappropriate purpose. In addition, we will promptly respond to complaints and inquires regarding the handling of personal information, etc., and review and improve measures for our
handling and safety management of our personal information, etc. appropriately.
1. Acquisition of Personal Information, etc.
We acquire personal information, etc. by lawful and fair means within the scope necessary for our business.
For example, we may obtain personal information, etc. from the following sources of information.
(Examples of sources of information sources for obtaining personal information, etc.)
・When it is provided directly by the documents filled out and submitted by the customer at the time of concluding a contract with a fund managed by us.
・When it is provided in meetings, etc. to conduct interviews with companies in which the fund managed by us invests.
(Examples of sources of information for obtaining Individual Numbers)
・When tax withholding is required for remuneration paid to lawyers, tax accountants, lecturers, etc.
2. Purpose of Use of Personal Information, etc.
We will use the acquired personal information, etc. within the scope necessary for the purposes of use set forth in "Purpose of Use of Personal Information" (Appendix 1) and "Purpose of Use of Individual Numbers" (Appendix 2). It will not be used for any other purpose. In addition, in the event of a change in the purpose of use, we will, in principle, notify the details of change to the person in writing, etc., announce them on the website or by posting them at our office, etc.
3. Provision of Personal Data (Excluding Individual Numbers) to Third Parties
Except in the following cases, we will not provide personal data (excluding individual numbers) to third parties without the consent of the individual except in the following cases;
- （１）
- When required by law
- （２）
- Cases in which the provision of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person
- （３）
- Cases in which the provision of personal information is particularly necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person
- （４）
- When it is necessary to cooperate with a national agency, a local government, or a person or organization entrusted by either of the foregoing in executing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of such affairs
- （５）
- When providing personal information to a third party in accordance with the procedures stipulated in the Personal Information Protection Law
4. Provision of Individual Numbers to Third Parties
We will not provide Individual Numbers to third parties except as stipulated by the Number Act.
5. Handling of Sensitive Information
We will not provide information (hereinafter referred to as "sensitive information") that requires special consideration in the handling of such information as race, creed, social status, medical history, criminal history, etc. so as not to cause unfair discrimination, prejudice, or other disadvantages. Except in the following cases, we will not acquire, use, or provide to third parties;
- （１）
- When required by laws and regulations
- （２）
- When it is necessary for the protection of human life, body or property
- （３）
- When it is particularly necessary to improve public health or promote the sound growth of children
- （４）
- When it is necessary to cooperate with a national agency, a local government, or a person or organization entrusted by either of the foregoing in executing affairs prescribed by laws and regulations
- （５）
- To the extent necessary for the performance of withholding tax affairs, etc., when acquiring sensitive information of employees, etc. related to affiliation or membership in political, religious, or other organizations or labor unions, etc.
- （６）
- When acquiring sensitive information, using it, or providing it to a third party to the extent necessary for the performance of the transfer of rights and obligations through inheritance procedures
- （７）
- When acquiring sensitive information to a third party to the extent necessary for business execution based on the consent of the person from the necessity of ensuring the appropriate business operation of the business
- （８）
- When biometric information corresponding to sensitive information is used for identity verification based on the consent of the person
6. Security Control Measures for Personal Data
In order to prevent leakage, loss, or damage of personal data handled by us and to otherwise safely manage personal data, we will take sufficient security measures, such as the establishment of handling standards for safety management and the development of an implementation system, and we will take appropriate measures to ensure the accuracy and recency necessary to achieve the purpose of use.
7. Outsourcing the Handling of Personal Data
When we outsource the handling of personal data to an outside party, we will confirm the information management system of the service provider and monitor the status of business execution even during outsourcing, and we will supervise the service provider as necessary and appropriate.
For example, we may outsource the handling of personal data in the following cases.
(Examples of outsourced clerical work)
Operations related to our accounting purpose
8. Disclosure, correction, suspension of use, etc. of retained personal data based on the Personal Information Protection Law
For requests regarding disclosure, correction, suspension of use, etc. of retained personal data based on the Personal Information Protection Law, please contact us using the contact information in 9 below. We will proceed after confirming the identity of the requester. In addition, if it is found that the information about the person is inaccurate as a result of conducting the necessary investigation, we will change it to an accurate one based on the results.
９．Inquiries to our company
We will respond sincerely and promptly to complaints and consultations regarding the handling of personal information, etc. For inquiries and consultations regarding our handling of personal information, etc., and retained personal data, please contact the following.
＜Contact Information>
Norinchukin Capital Co., Ltd. Planning & Coordination Division
Location: 〒100-0004 JA Building, 1-3-1 Otemachi, Chiyoda-ku, Tokyo
Telephone: 03-6378-7388
FAX:03-3212-8185
Hours: Monday ~ Friday (except for days stipulated in the Act on National Holidays, January 2, January 3 and December 31) 9 a.m. ~ 5 p.m.
10. Joint Use of Personal Information (Excluding Individual Numbers)
We may share to use personal data (excluding individual numbers) related to the employees, etc. of corporate customers involved in special operations for qualified institutional investors, etc. with Norinchukin Bank, the parent company of our company, and its consolidated subsidiaries.
- （１）Items of personal data to be shared
- Information on the names, addresses, dates of birth, telephone numbers, e-mail addresses, occupations, etc. of directors, officers and employees of corporate customers
- （２）Scope of joint users
- We, The Norinchukin Bank and its consolidated subsidiaries
- （３）Purpose of use by the user
- To utilize the comprehensive know-how of us and The Norinchukin Bank Group to develop and provide higher quality services to corporate customers and to promote transactions appropriately and smoothly.
- （４）Entity responsible for the management of the personal data
- Norinchukin Capital Co., Ltd.
〒100-0004 JA Building, 1-3-1 Otemachi, Chiyoda-ku, Tokyo
President & CEO Toru Wada
11．Cancellation of solicitation by telephone, etc.
When we receive a request from a customer to cancel solicitation by telephone, etc. as follows, we will take measures to suspend the use and provision for that purpose without delay.
- （１）Cancellation
- Business information for our company and Norinchukin Group
- （２）Procedures for cancellation
- Please contact us or the inquiry desk in 9 above.
12．Revisions
The above handling shall apply from August 31, 2022 onwards.
We may revise this "Personal Information Protection Policy" in order to protect personal information and to respond to changes in laws and regulations and other norms. Particularly important changes will be announced on our website and on our office.
Purpose of Use of Personal Information
Appendix 1
Purpose of Use of Personal Information
Based on the Act on the Protection of Personal Information (Act No. 57 of May 30, Heisei 15), we will use the personal information of customers, etc. acquired in the course of business operations to the extent necessary to achieve the following operations and purposes of use.
１．Scope of business
- （１）
- Special operations for qualified institutional investors, etc. as stipulated in Article 63, Paragraph 1 of the Financial Instruments and Exchange Act
- （２）
- Other operations that we can perform and operations incidental thereto (including operations that will be approved in the future)
2. Purpose of use
- （１）
- To consider investment from the funds we manage
- （２）
- To solicit investment in the funds we manage , to accept applications, and to conduct administrative work and reports associated therewith these
- （３）
- To judge the appropriateness of the provision of financial products and services, such as judgment in light of the principle of conformity, etc.
- （４）
- For clerical work, reporting, and provision of services related to special operations for qualified institutional investors, etc.
- （５）
- To manage the results of special operations for qualified institutional investors, etc., in continuous transactions
- （６）
- For cancellation of various transactions and post-termination management
- （７）
- To provide various information regarding our special operations for qualified institutional investors, etc., and to introduce the Norinchukin Bank, our parent company, and its group companies or provide information on its services.
- （８）
- To confirm the eligibility to use services related to special services for qualified institutional investors, etc., such as confirming the identity of the Customer or his/her agent in accordance with the Act on Prevention of Transfer of Criminal Proceeds and other laws and regulations.
- （９）
- To exercise rights and fulfill obligations based on contracts with customers, etc. and laws and regulationss
- （10）
- For research and development of financial products and services through market research, data analysis, interviews with companies, questionnaires, etc.
- （11）
- To appropriately and smoothly carry out other transactions with customers, etc.
Purpose of Use of Individual Numbers
Appendix 2
Purpose of Use of Individual Numbers
Based on the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of May 31, Heisei 25), the Company will use the acquired Individual Numbers of Customers, etc. to the extent necessary to achieve the following purposes of use and in accordance with the provisions of laws and regulations.
＜Purpose of use＞
- （１）
- Preparation of payment records for remuneration, fees, contract money, prize etc.
- （２）
- Preparation of payment records for real estate usage fees, commissions, considerations, etc.
- （３）
- Preparation of payment records for dividends of surplus
- （４）
- Other affairs permitted by laws and regulations
１ Purpose
The Norinchukin Bank and its group companies (hereinafter, collectively or respectively, referred to as the "Bank Group") shall manage transactions with the risk of a conflict of interest and appropriately conduct daily operations in order to avoid undue harm to the interests of customers and to achieve customer-oriented business conduct.
２ Bank Group subject to management
We will establish management system for those companies within the Bank Group which need conflict of interest management. Representative examples of such companies are as follows:
- The Norinchukin Trust & Banking Co., Ltd.
- Norinchukin Zenkyoren Asset Management Co., Ltd.
- JA MITSUI LEASING, LTD.
３ Identifying transactions with the risk of a conflict of interest
For the purpose of protecting the interests of customers, the Bank Group shall, in advance of businesses, identify transactions that require careful management from the following perspectives:
(Perspectives of the situation)
- Situation where there is a concern that duty of loyalty of such Bank Group under the contracts between it and its customer will not be fulfilled due to a conflict of interest.
- Situation where the interests of a customer with a contractual relationship with such Bank Group are potentially unduly harmed through a transaction conducted by such Bank Group with another customer who competes or conflicts with the former customer.
- Situation where the interests of a customer are potentially unduly harmed by using non-public information of such customer beyond a reasonable scope.
(Perspectives of the type of the business)
- M&A advisory businesses
- General Partner businesses of a partnership
- Turn-around businesses
- Syndicated loan businesses
- Corporate bond management businesses
- Wealth management businesses
(Perspectives of the type of the business)
- M&A advisory businesses
- General Partner businesses of a partnership
- Turn-around businesses
- Syndicated loan businesses
- Corporate bond management businesses
- Wealth management businesses
４ methods of managing transactions with the risk of a conflict of interest
The Bank Group shall appropriately protect customers’ interests by managing transactions with the risk of a conflict of interest by appropriately combining the following methods.
- （１）
- Blocking information between divisions/business group
- （２）
- Disclosing the situation of the conflict of interest or acquiring the customer’s consent for such situation
- （３）
- Changing the terms and conditions of the transaction
- （４）
- Cancelling one of the transactions
- （５）
- Other methods
５ Management framework for a conflict of interest
The Bank Group shall establish a supervising division for managing transactions with a conflict of interest, identify and manage such transactions, and will continuously improve the management framework for a conflict of interest through implementing the framework, including training of employees. In addition, the Bank Group shall conduct internal audits of the management framework for a conflict of interest and periodically verify its appropriateness and effectiveness.