Privacy Policy

1. Basic policy on the handling of personal information

ES-CON ASSET MANAGEMENT complies with the Act on the Protection of Personal Information (2003 Act No. 57,including subsequent amendments; hereinafter, the "Personal Information Protection Law"), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (2013 Act No. 27, including subsequent amendments; hereinafter, the "My Number Act"), and other related laws, regulations and guidelines (collectively with the Personal Information Protection Law and the My Number Act, hereinafter, "Laws"). ES-CON ASSET MANAGEMENT recognizes the importance of protecting personal information (individual number and specific personal information, hereinafter, "specific personal information"; unless otherwise stipulated elsewhere in this Privacy Policy, the same applies below), and shall properly handle, protect, and manage personal information.

  1. Acquisition of personal information
    ES-CON ASSET MANAGEMENT will acquire personal information only to the extent necessary for the purpose which ES-CON ASSET MANAGEMENT has established and by proper and legal means. ES-CON ASSET MANAGEMENT will not acquire any personal information without the prior consent of the person except as permitted by laws and regulations.
    ES-CON ASSET MANAGEMENT will not acquire any personal information untruthfully or by inappropriate means.
    ES-CON ASSET MANAGEMENT will clarify the purpose of use in advance, when acquiring personal information from an individual directly, through written documents and so forth. However, when the purpose of use is clear from the situation or when Laws permit, this clarification of the purpose of use may be omitted.
  2. Management of personal data
    ES-CON ASSET MANAGEMENT strives to keep personal data as accurate and up to date as possible, and to delete those pieces of personal data without any delay when they are no longer necessary. ES-CON ASSET MANAGEMENT will educate its employees and appropriately take necessary measures in accordance with each phase, such as acquisition, handling and protection of specific personal data, to appropriately control the acquisition, usage and management of personal data, to prevent unauthorized access, leakage, loss, destruction, and tampering of specific personal information and personal data.

2. Reasons for using personal information

  1. Reasons for use of personal information (excluding specific personal information. The same applies throughout this section, “2. Reasons for using personal information”).

    Except as permitted by laws and regulations or with the prior consent of the relevant person, ES-CON ASSET MANAGEMENT will handle personal information only to the extent necessary to achieve the purposes of use in the following cases.

    1. For exercise the rights of investors (hereinafter simply referred to as “Unitholders”) and perform obligations to Unitholders in relation to the investment corporation (hereinafter referred to as the “Investment Corporation”) for which ES-CON ASSET MANAGEMENT is entrusted with asset management based on the Act on Investment Trusts and Investment Corporations (Act No. 198 of 1951, including subsequent amendments; hereinafter, the "Investment Trusts Act") and other related laws and regulations as well as the exercise of ES-CON ASSET MANAGEMENT’s rights, duties and related procedures
    2. To provide investment advice as an investment advisory business under the Financial Instruments and Exchange Act (Act No. 25 of 1948, including subsequent amendments), to exercise the rights of Investors (hereinafter simply referred to as “Investors”) and to perform obligations to investors in relation to the Company's clients (also referred to as “the Company’s Clients”), in the Type II Financial Instruments Business or Building Lots and Buildings Transaction Business. To fulfill other obligations and exercise rights of the Company and to take various actions incidental thereto
    3. To prepare and submit various reports and other documents of the Investment Corporation and the Company’s Clients, and to prepare and manage various data and information pertaining to Unitholders and Investors, in accordance with the Investment Trust Act, the Financial Instruments and Exchange Act and other related laws and regulations
    4. To facilitate borrowings by Investment Corporation, to issue investment corporation bonds and investment units, and to implement other fund-raising tasks, and to facilitate borrowings and other fund-raising tasks by the Company’s Clients
    5. For ES-CON ASSET MANAGEMENT to carry out operations related to the acquisition, brokerage, transfer, leasing, and management of assets related to the Investment Corporation and the Company’s Clients, as well as providing investment advice, information gathering, research and analysis, and investigations (including, but not limited to, legal investigations and credit investigations)
    6. To analyze market trends, conduct customer satisfaction surveys, and conduct product development surveys and analysis
    7. To provide information, etc. concerning the business of Investment Corporation or the Company’s Clients to Unitholders or Investors
    8. To respond to inquiries, requests for materials, etc. directed at ES-CON ASSET MANAGEMENT
    9. For the verification at the time of transaction on the Act on Prevention of Transfer of Criminal Proceeds (Act No. 22 of 2007, including subsequent amendments)
    10. To perform IR activities and general administrative duties related to Investment Corporation or the Company’s Clients
    11. To carry out operations related to the collection of information, research analysis and investigations (including, but not limited to, legal investigations and credit investigations) of transactions conducted by ES-CON ASSET MANAGEMENT
    12. To provide personal information to third parties within the scope necessary to achieve or execute business related to the reasons for using personal information described above in items (1) to (11)
    13. For human resource management (including wage management, health management, benefit affairs, personnel evaluation, occupational health and safety, etc.), employment selection and hiring procedures, and post-retirement communications and procedures for ES-CON ASSET MANAGEMENT 's officers and employees, etc. (including people who have been offered jobs and people who have retired)
  2. Reasons for use of specific personal information

    Except as permitted by the My Number Act, ES-CON ASSET MANAGEMENT will handle specific personal information only to the extent necessary to achieve the purposes of use in the following cases, regardless of the consent of the person.

    1. Administrative work related to the Personal Number of officers and employees (including dependents) (including administrative duties related to the following)
      1. Administrative work related to withholding tax undertaken by the employer in accordance with the Income Tax Act
      2. Administrative work related to individual inhabitant tax undertaken by the employer in accordance with local tax laws
      3. Administrative work related to employment insurance undertaken by the employer in accordance with the Employment Insurance Act
      4. Administrative work related to health insurance (application-related and benefit-related) undertaken by the employer in accordance with the Health Insurance Act
      5. Administrative work related to employees’ pension insurance undertaken by the employer in accordance with the Employees' Pension Insurance Act (application-related)
    2. Administrative work related to the Personal Number of individuals other than officers and employees (including administrative duties related to the following).
      1. Administrative work related to payment records of remuneration and fees, etc. in accordance with the Income Tax Act
      2. Administrative work related to payment records of dividends, distribution of surplus and interest on funds in accordance with the Income Tax Act
      3. Administrative work related to payment records of real estate royalties, etc. in accordance with the Income Tax Act
      4. Administrative work related to payment records of the acquisition of real estate, etc. in accordance with the Income Tax Act

3. Providing personal data to third parties

ES-CON ASSET MANAGEMENT will not provide any personal data (here, excluding personal data related to specific personal information, etc.) to any third parties, except in the following cases. With regard to specific personal information, except for cases stipulated in the My Number Act, specific personal information will not be provided to any third parties, either with or without the consent of the person.

  1. When agreed to by the person
  2. When in accordance with Laws and regulations
  3. When necessary for the protection of life, body or property under circumstances where it is difficult to obtain consent from the person in advance
  4. When necessary for the improvement of public well-being or the promotion of the healthy growth of children under circumstances where it is difficult to obtain consent from the person in advance
  5. When necessary for cooperating with national institutions, local public bodies, or the person entrusted by them, in executing operations prescribed by laws and regulations, and obtaining consent may impede the execution of those operations

4. Supervision over outsourcees

ES-CON ASSET MANAGEMENT may entrust to outsourcees all or part of the handling of specific personal information and personal data, to the extent necessary for achieving the purpose of use. ES-CON ASSET MANAGEMENT shall take necessary and appropriate safety measures for outsourcees to ensure the strict control of the security of entrusted specific personal information and personal data. ES-CON ASSET MANAGEMENT shall also perform supervision to determine whether appropriate oversight supervision is implemented when the personal information is further entrusted to other outsourcees.

5. Handling of sensitive information

Except as permitted by the Guidelines for the Protection of Personal Information in the Financial Sector, ES-CON ASSET MANAGEMENT will not acquire, use or provide to any third party sensitive information. Here, “sensitive information” is defined in the Guidelines for Protection of Personal Information in the Financial Sector as “personal information requiring attention” along with information regarding labor unions, family origin, legal address on family registry, healthcare and sex life that are not part of the “personal information requiring attention”. Notwithstanding the forgoing, information disclosed by the person concerned, national institutions, local public bodies, or the person set out in the Personal Information Protection Act or the Ordinance for Enforcement of the Act on the Protection of Personal Information is not considered “sensitive information”. Also, information obtained by visual inspection or photography which can be identified by its presence is not considered “sensitive information”.

6. Application for disclosure of personal data

ES-CON ASSET MANAGEMENT shall, in accordance with an invoice including identifying documents specified by ES-CON ASSET MANAGEMENT, immediately and without delay respond to a request from the person to receive notification of the purpose of use, or disclose, correct, append to, delete, cease use of, remove, or cease provision to a third party of personal data pertaining to that person (hereinafter, Application for Disclosure), after confirmation of identity and ownership.
For further details, apply to one of the service desks indicated in Section 8. There are cases where we will charge for sending documents that constitute a response to a request for notification of purpose of use or disclosure of retained personal data. However, ES-CON ASSET MANAGEMENT may refuse the disclosure of all or part of the personal data, and give the reason without delay, in the following cases:

  1. When it may harm the life, body, property and other rights and interests of the person or a third party
  2. When it may result in conspicuous impediment to the business operations of ES-CON ASSET MANAGEMENT
  3. When it is in violation of laws and regulations

7. Continuous improvement

In addition to complying with the Privacy Policy, ES-CON ASSET MANAGEMENT will continue to make improvements in the future by reviewing the policy in accordance with the revision of laws and regulations, and an increase or a change in public demand.

8. Inquiries and help desks

Please see the contact information below for questions and requests for disclosure, correction, and suspension of provided personal information. If ES-CON ASSET MANAGEMENT receives any complaints about the handling of acquired personal information, etc., it will investigate the details in order to deal with them in an appropriate way within a reasonable period of time.

Contact
ES-CON ASSET MANAGEMENT
Address
The Okura Prestige Tower 20F, 2-10-4, Toranomon, Minato-ku, Tokyo, 105-0001, Japan
Phone
+81-3-6230-9338
Hours
9:00 am – 5:00 pm (closed on weekends and holidays)

Please contact the administrator below regarding the investors' registry:

Contact
Stock Transfer Agency Business Planning Dept, Sumitomo Mitsui Trust Bank Ltd.
Address
2-8-4 Izumi, Suginami-ku, Tokyo, 168-0063, Japan
Phone
0120-782-031 (toll free in Japan)
Hours
9:00 am – 5:00 pm (closed on weekends and holidays prescribed by the Associations)

ES-CON ASSET MANAGEMENT is a member of the authorized personal information protection organizations, The Investment Trusts Association Japan and Investment Advisers Association. See contact below for inquiries and complaints regarding handling of personal information by designated organizations.

Contact
The Investment Trusts Association, Japan Membership Investigation Department
Investors Consultation Office
Address
Tokyo Shoken Torihikijo Building 6F, 2-1 Nihombashi-Kabutocho, Chuo-ku, Tokyo, 103-0026, Japan
Phone
+81-3-5614-8440
Hours
9:00 am – 11:30 am, 12:30 pm – 5:00 pm (closed on weekends and holidays prescribed by the Associations)
Contact
Japan Investment Advisers Association Help Desk (individual information room)
Address
Tokyo Shoken Kaikan 7F, 1-5-8 Nihombashi-Kayabacho, Chuo-ku Tokyo, 103-0025, Japan
Phone
+81-3-3663-0505
Hours
9:00 am – 5:00 pm (closed on weekends and holidays prescribed by the Associations)
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