Privacy Policy

1. Basic policy on the handling of personal information

ES-CON ASSET MANAGEMENT Ltd. (hereinafter referred to as "ES-CON AM") complies with the "Act on the Protection of Personal Information" (2003 Act No. 57 and all amendments after. Hereinafter referred to as "Personal Information Protection Law") and other related laws, regulations and guidelines (combined with "Personal Information Protection Law", hereinafter referred to as "Laws"). ES-CON AM recognizes the importance of protecting personal information and shall properly handle, protect, and manage personal information.

  1. Gleaning of personal information
    ES-CON AM will acquire personal information only to the extent necessary for the business purpose, and through proper measures.
    ES-CON AM will not acquire any personal information untruthfully, and through other improper measures.
    ES-CON AM will clarify the purpose of use, once acquiring personal information from an individual directly, through written documents and so forth.
    However, in case the purpose of use is clear from the situation or when Laws permit, such specification of usage may be omitted.
  2. Management of personal information
    ES-CON AM strives to keep personal information as accurate and up to date as possible. ES-CON AM will educate its employees and take necessary measures to appropriately control the acquisition, usage and management of personal information, to prevent unauthorized access, leakage, loss, destruction, and tampering.

2. Usage purpose of personal information

ES-CON AM will use the acquired personal information for the following purposes:

  1. For verification of identity and credit check of the individual(s) relevant to its application forms and contracts related to ES-CON AM's business (*1).
  2. For the implementation of ES-CON AM's business (including applications and contracts), as well as for necessary survey analysis, sales activities, collection of references, informational activities, and other necessary work associated with its business.
  3. For confirmation and record purpose regarding inquiries and visitors to ES-CON AM.
  4. For general affairs and other related or incidental business activities of ES-CON AM, not specified above in 1-3.
  5. To disclose or provide personal information to third parties as necessary, for the purposes specified above in 1-4.

3. Provision of personal information to third parties

ES-CON AM will not provide personal information to any third party, except in the following cases:

  1. When agreed by the applicable person
  2. When in accordance with Laws
  3. When necessary for the protection of life, body or property (including corporate asset) and a consent cannot be obtained from the person.
  4. When necessary for the improvement of public hygiene or the promotion of healthy growth of children, and a consent cannot be obtained from the person.
  5. When necessary for cooperating with the national or local institution, a local public body, or an individual or entity entrusted by one in executing the operations prescribed by Laws, and obtaining consent may impede the execution of the operations concerned.
  6. When ES-CON AM provides the information, in the extent necessary for achieving the purpose of use, to outside vendors under appropriate supervision.

4. Supervision over outsourcers

ES-CON AM may entrust all or part of the handling of personal information, to the extent necessary for achieving the purpose of use. ES-CON AM shall supervise such outsourcers as necessary in order to ensure the strict control of security of personal information entrusted. ES-CON AM shall also oversee weather its appropriate supervision is implemented to re-entrusted parties or not.

5. Application for disclosure of personal data

ES-CON AM shall promptly and appropriately respond to requests for disclosure, correction, deletion and withdrawal of personal information, after confirmation of identity and ownership. However, ES-CON AM may decide to refuse the disclosure of all or part of the personal data, and inform the reason, in the following cases:

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

6. Continuous improvement

In addition to complying with the privacy policy, ES-CON AM will continue to make improvements in the future by reviewing the policy in accordance with the revision of Laws, and rise or shift in public demands.

7. Inquiries and help desks

Please contact below for questions and requests for disclosure, correction, and suspension of provided personal information.

Try Edge Ochanomizu Bldg. 12F, 4-2-5 kandasurugadai, Chiyoda-ku, Tokyo, 101-0062, Japan
9:00AM – 5:00PM (Closed on weekends, holidays and new years)

Please contact the administrator below regarding contents of investors' registry:

Sumitomo Mitsui Trust Bank Ltd. Stock Transfer Agency Business Planning Dept.
2-8-4 Izumi, Suginami-ku, Tokyo, 168-0063, Japan
0120-782-031 (Toll-free in Japan)
9:00AM – 5:00PM (Closed on weekends, national and selected holidays)

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

The Investment Trusts Association, Japan Membership Investigation Department
Investors Consultation Office
Tokyo Shoken Torihikijo Building 6F, 2-1 Nihombashi-Kabutocho, Chuo-ku, Tokyo, 103-0026, Japan
9:00AM – 11:30AM, 12:30PM – 5:00PM (Closed on weekends, national and selected holidays)
Japan Investment Advisers Association Help Desk (Individual information room)
Tokyo Shoken Kaikan 7F, 1-5-8 Nihombashi-Kayabacho, Chuo-ku Tokyo, 103-0025, Japan
9:00AM – 5:00PM (Closed on weekends, national and selected holidays)
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