Privacy Policy

1. Basic policy for handling personal information

ES-CON ASSET MANAGEMENT (hereinafter "ES-CON ASSET MANAGEMENT") 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 ASSET MANAGEMENT recognizes the importance of protecting personal information and shall properly handle, protect, and manage personal information.

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

2. Reasons for using personal information

ES-CON ASSET MANAGEMENT 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 ASSET MANAGEMENT's business (*1).
  2. For the implementation of ES-CON ASSET MANAGEMENT'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 ASSET MANAGEMENT.
  4. For general affairs and other related or incidental business activities of ES-CON ASSET MANAGEMENT, 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 ASSET MANAGEMENT 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 assets) and a consent cannot be obtained from the person.
  4. When necessary for the improvement of public well-being or the promotion of healthy growth of children, and a consent cannot be obtained from the person.
  5. When necessary for cooperating with national or local institutions, 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 ASSET MANAGEMENT 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 ASSET MANAGEMENT may entrust all or part of the handling of personal information, to the extent necessary for achieving the purpose of use. ES-CON ASSET MANAGEMENT shall supervise these outsourcers, as necessary, to ensure the strict control of security of personal information. ES-CON ASSET MANAGEMENT shall also oversee whether or not its appropriate supervision is implemented with outside parties (outsourcers).

5. Application for disclosure of personal data

ES-CON ASSET MANAGEMENT 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 ASSET MANAGEMENT may refuse the disclosure of all or part of the personal data while giving the reasons. in the following cases:

  1. When it may harm the life, body, property or other rights 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 the Laws.

6. 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 an increase or change in public demand.

7. Inquiries and help desks

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

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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