Privacy Policy

1. Compliance with Applicable Laws and Regulations
Touchstone Capital Securities Co., Ltd. (hereinafter referred to as the "Company") hereby declares that it will strive for the protection of personal information by properly handling such information, in compliance with the Law concerning Protection of Personal Information, other related laws and ordinances, and guidelines of competent authorities, and by having all employees comply with this basic policy and related laws and ordinances.

2. Purposes of Use of Personal Information
The personal information of customers collected by the Company will be used to the extent necessary in connection with the "Scope of Our Business" and "Purposes of Use" (Exhibit), and will not be used for any other purposes unless customers' prior consent is obtained, or applicable laws and ordinances permit such usage. The Company will publish its Privacy Policy and Purposes of Use of customers' personal information via the Company's official website, and display these policies in its Tokyo Office.

    Exceptional Cases
  • (1) When required under applicable laws and ordinances.
  • (2) When it is deemed necessary to protect the life or ensure the safety of individuals or protect property.
  • (3) When it is deemed especially necessary for the improvement of public health and the promotion of the well being of children.
  • (4) When it is deemed necessary to cooperate with national governmental agencies, local municipal bodies or their proxies in order to perform the operations prescribed by laws and ordinances.

    Scope of Our Business
  • (1) Securities business and related ancillary business; and
  • (2) Business activities as permitted under the Financial Instruments and Exchange Law.

    Purposes of Use
    Purposes of use of personal information in connection with securities transactions:
  • (1) Soliciting, selling, and providing services and information relating to securities and other financial products;
  • (2) Soliciting, selling, and providing services and information relating to the financial products handled by the Company and its related and affiliated companies;
  • (3) Reviewing the suitability of the products and services offered by the Company under the principle of suitability;
  • (4) Identifying individual customers, their agents or, where the customer is a legal entity, the person responsible for a particular transaction, including any representative or agent of such a legal entity;
  • (5) Informing a customer of the outcome of a transaction, account balances or any other matters;
  • (6) Carrying out administrative work in connection with any transaction with a customer;
  • (7) Carrying our research and development of products and services through market research, data analysis, and questionnaire surveys, etc;
  • (8) Performing delegated services involving the handling of personal information in an appropriate manner on behalf of any other party;
  • (9) Any other purposes in connection with the adequate and smooth performance of transactions between the Company and its customers.

In accordance with the ordinance of Financial Instruments Business and other related rules, the Company will not use or provide to third parties, information concerning an individual's ethnic groups and/or race, political views, religion (religion, ideas and beliefs), family origin and/or domicile of origin, health history/records, and/or criminal record (hereinafter referred to as "Sensitive Information"), and any other non-public sensitive information, except for the purposes necessary for the proper operation of its business or otherwise.

3. Assurance of Accuracy of Personal Data
To the extent necessary for the implementation of the Purposes of Use, the Company will make efforts to keep the personal data accurate and up-to-date. Unless a retention period is set forth under applicable laws or ordinances, the Company will establish the retention period for personal data in custody according to its Purposes of Use, and will erase or dispose of the relevant personal data after the elapse of the applicable period.

4. Security Measures for the Handling of Customers' Personal Information
The Company will endeavor to keep its customers' personal information accurate and up to date. To protect customers' personal information against unauthorized disclosure, loss or destruction, the Company will incorporate appropriate company organizations and strict security measures for the protection of personal information by means of establishing, and reviewing and revising from time to time, internal regulations regarding the protection of personal information. The Company will also properly supervise its officers, employees and agents, conduct investigations to confirm their compliance with the internal regulations, and properly handle any complaints which may arise.

We are committed to ensuring that customers' information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

5. Review and Amendment of This Policy
The Company may review and amend this policy, and take any proper measures necessary to ensure the security of personal information.

6. Request for Disclosure of Personal Information
When the principal requests disclosure, correction, suspension of use, etc. of his/her personal information, the Company will promptly respond to such a request after verification of the identity of the applicant or his/her agent.

Procedures when requested:

  • (1) Please specify which personal information to request for disclosure, correction, suspension of use, etc (applicant's name, address, phone number, birth date, name of company he/she works for, A/C balance, trading record, etc.)
  • (2) Contact
    For such a request, please contact the Information Security Office at the Tokyo Office as specified in 7 below.
  • (3) Necessary Papers
        (A) Application form (stored in the Tokyo Office)
        (B) ID of applicant (agent's ID is also necessary in the event that a request is made through an agent)
  • (4) Any response will reach the applicant or his/her agent verbally at our office or mailed to the address designated by the applicant.
  • (5) Any information obtained in this request process will be used to identity the applicant and his/her agent, to respond to the request, and to review this request procedure.
  • (6) If such a request is denied, the applicant or his/her agent will be informed of our denial decision with its reason.

7. Queries Concerning Personal Information
The Company will establish a point of contact for handling queries and complaints from the principal. For queries concerning the handling of personal information, please contact the following:

  Touchstone Capital Securities Co., Ltd.
Internal Audit Department 		Akasaka 1-chome Center Building, 12F
1-11-30 Akasaka
Minato-ku, Tokyo 107-0052 Japan 		 
  Telephone +81-(0)3-5575-6800  
  Office Hours From 9:00 a.m. to 5:00 p.m.
(Monday to Friday, closed on national holidays and from Dec. 31 to Jan. 3)		  

8. Approved Personal Information Protection Organization
The Company is a member of the Japan Securities Dealers Association (JSDA), which has been approved as a personal information protection organization by the Financial Supervisory Agency. The Personal Information Consultation Office of JSDA accepts complaints and provides consultation regarding the handling of personal information by its member firms.

  Contact for Complaints and Consultation JSDA Personal Information Consultation Office  
  Telephone +81-(0)3-3667-8427  
  Office Hours From 9:00 a.m. to 5:00 p.m.
(However, JSDA is closed from December 31 to January 3, and on Saturdays, Sundays and national holidays.)		  
  Website http://www.jsda.or.jp/html/privacy/index.html  

Further, the following are key sources of personal information and key tasks that are outsourced.

    [Key Sources of Personal Information]
    The following are examples of key sources of personal information obtained by the Company:
  • Applications to open accounts, questionnaires (including those conducted via the Internet or by mail) and information directly filled out by customers
  • Information entered in materials sold on the market and information published in newspapers and on the Internet
  • Information received from the customer through the provision of products and services
  • Information obtained via due diligence for beneficiary interests in trust and underlying assets of deemed negotiable securities

    [Primary Tasks Outsourced]
    The Company outsources a part of its work. Of the work we outsource to third parties, the following is included:
  • Operations that provide specialized advice regarding legal affairs, accounting advice, etc.
  • Operations related to operating and maintaining information systems

9. Contact for Complaints and Consultation
* The JSDA entrusts consultation and the handling of complaints of all persons conducting financial instrument transactions, as well as the resolution of disputes, to the following organization.

  Contact for Complaints and Consultations Financial Instruments Mediation Assistance Center
(Specified Nonprofit Organization)		  
  Telephone +81-(0)3-3667-8427  
  Office Hours Monday to Friday, 9:00 a.m. to 5:00 p.m.
(closed on national holidays and from Dec. 31 to Jan. 3)		  


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