Handling of Personal Information

As a member of the Sumitomo Mitsui Trust Group, we respect and adhere to the Sumitomo Mitsui Trust Group Privacy Policy. We make all efforts to properly manage personal information, including the following measures.

  1. Personal Information Help Desk
    Please contact our Planning and Coordination Department with any concerns or questions about how we handle personal information.
    Business Planning Department Tel. 03-3518-6954 (weekdays 9:00 to 17:00)
  2. Collecting Personal Information
    The Company collects personal information from a variety of sources:

    (Example)
    Personal information obtained from real estate companies during the course of providing clients with real estate services
  3. Intended Use
    The Company strives to clearly state the intended use of personal information, limiting the usage of such to the intended purpose.
    The Company uses personal information during the course of services outlined in (1) below within the scope necessary to accomplish the intended purpose(s) outlined in (2) below. Our use of personal information complies with the Act on the Protection of Personal Information (Act No. 57, May 30, 2003)
    The Company clearly states the intended use before obtaining personal information directly written by customers (except where not required by law).
    Upon request from the individual concerned, the Company will terminate the usage of the individual's personal information for the intended use in question.
    The Company shall not use individual's personal information other than for the intended purpose as out lined in (3) below when such use is restricted by law.
    1. (1) Services
      1)
      Investment management services, investment advisory/agency services
      2)
      Other related services (including other permitted services in the future)
    2. (2) Intended Use
      When offering products and services, the Company and affiliated companies shall use personal information for the purpose(s) stated below:
      1)
      To receive applications, inquiries about products and services
      2)
      To recommend products and services (including telephone number, electronic mail, etc.)
      3)
      To confirm the client’s identity or qualifications to use products and services according to the provisions of the Act on the Prevention of Transfer of Criminal Proceeds, etc.
      4)
      To conduct administrative duties related to ongoing business. This includes date of record administration for transactions related to investment management services and investment advisory/agency services, etc.
      5)
      To make decisions on applications and ongoing business related to investment management services and investment advisory/agency services, etc.
      6)
      To make decisions concerning the appropriateness of certain products and services, including decisions reflecting principles of compatibility.
      7)
      To provide information to third parties within the scope necessary to execute duties related to investment management services and investment advisory/agency services, etc.
      8)
      To contract personal information processing services (in part or in whole) from other parties in order to properly perform services
      9)
      To execute duties or rights based on client contracts or relevant laws
      10)
      To conduct product and service research and development through market surveys, data analysis, and/or questionnaires
      11)
      To recommend various products and services offered by affiliated companies
      12)
      To conduct administrative duties related to or subsequent to the cancellation of contracted services
      13)
      To properly assess Company and/or Group Company risk or when performing related administrative tasks or services when executing transactions and contracts with clients
    3. (3) Usage Restricted by Law
      The Company shall not use personal information other than for the intended purpose when such use is restricted by law. More specifically:
      • Specified non-public information related to race, religion, family history, domicile of origin, health, or criminal history shall not be used or provided to third parties for any purpose other than the appropriate management of services or as otherwise recognized as necessary according to the provisions of the Cabinet Office Ordinance on Financial Instruments Business, etc.
  4. Personal Information Processing Contracted to Outside Parties
    In accomplishing the intended use for personal information, the Company may rely on third parties in certain cases, including the following:
    (Example)
    Information Systems Management/Maintenance
    The Company requires third-party vendors to sign agreements for the strict management of personal information in accordance with Company policies. The Company shall also provide appropriate oversight of third-party operations related to personal information.
  5. Personal Information Provided to Third Parties
    The Company shall not provide personal client information to third parties without the permission of the individual in question. Notwithstanding, the Company may share information, contract for information processing, or provide information to third parties where set for under this Privacy Policy or as follows:
    1)
    Where required/authorized by law
    2)
    When required to protect the life, health, and/or property of an individual, and when obtaining permission from the individual in question is difficult
    3)
    When necessary to improve the public health or maintain the healthy environment of minors, and when obtaining permission from the individual in question is difficult
    4)
    When required in cooperation with the execution of legal administrative tasks by national or regional governments/government agencies or the agents of such, and when obtaining permission from the individual in question may prevent or hinder the execution of such administrative tasks
    5)
    When following procedures as set forth in Article 23, Paragraphs 2 and 3 ("opt-out") of the Personal Information Protection Law. (6. Procedures for terminating the provision of personal data to third parties, terminating the provision of real estate information)
  6. Procedures for Terminating the Provision of Personal Data to Third Parties
    When an individual files an application according to the procedures detailed below, the Company shall cease providing the personal data of said individual to third parties.
    • Terminating the provision of real estate information
      When receiving beneficial interests in real estate trusts as assets to manage under discretionary investment contracts or investment advisory/agency services, the Company may provide real estate information (a.) by certain means (b.) to third parties (c.). The individual in question may, according to procedures below (d.), request that the Company cease providing such information to third parties. Upon receipt of said request, the Company shall cease providing said information to third parties.
    a.
    Types of Personal Data
    1) Real estate property information
    2) Tenant names, addresses, telephone numbers, etc.
    b.
    Methods
    Written correspondence, mail, telephone, Internet, electronic mail, etc.
    c.
    Third Party Scope
    1) Party who is or may be a party to a transfer contract
    2) Realtors
    3) Judicial scriveners, real estate surveyors (related to incorporation/registration)
    4) Real estate survey organizations (including the Association for Real Estate Securitization)
    5) Real estate management companies
    6) Financial institutions (related to financing)
    d.
    Termination request procedures
    Once the individual in question submits the prescribed application to the appropriate department (the Planning and Coordination Department unless otherwise clearly identified), and the Company confirms a business relationship with the individual in question, the Company shall cease providing information to third parties. In the event that the Company does not have a business relationship with said individual, the Company may request more documentation. For more details, please contact the help desk identified above.
  7. Shared Use of Personal Data
    The Company may share personal data in the following situations:
    • Shared within the Sumitomo Mitsui Trust Group
      • ・
      Types of shared data
      Name, address, date of birth, telephone number, credit information
      ・
      Scope of shared use
      Sumitomo Mitsui Trust Holdings, consolidated subsidiaries noted in the Sumitomo Mitsui Trust Holdings securities report, and companies in which Sumitomo Mitsui Trust Holdings holds minority interests (information is handled in compliance with the Financial Instruments and Exchange Act and related statutes where such shared use is restricted by law)
      ・
      Intended use
      To assess risks as a necessary part of conducting Group company management
      ・
      Entity responsible for personal data
      Sumitomo Mitsui Trust Holdings, Inc.
  8. Procedures for Disclosing Personal Data
    The Company shall generally respond as follows to requests for personal data disclosure from individuals and/or agents of said individual.
    For more details related to procedures, please contact the Company's help desk for inquiries dealing with the handling of personal information noted in 1. above.

    (Application Procedures)
    With respect to requests for disclosure of personal data from the individual or individual's agent, having filled out the prescribed forms by the Company, together with documents confirming the identity of the individual, please send to the Company's help desk for inquiries dealing with the handling of personal information noted in 1. above.

    (Fees)
    The Company may ask for the payment of a fee in conjunction with the request to disclose personal data.
    Said fee is non-refundable, even in the event that the Company cannot disclose the data requested.

    (Response)
    After completing the procedures, the Company will provide a written response by mail.
  9. Other
    For other concerns or inquiries regarding the Company's use of personal information, please contact the following:
    Help Desk Japan Investment Advisers Association, Secretariat Office, Complaint Resolution Office (Personal Information Department)
    Address 1-5-8 Kayaba-cho, Nihonbashi, Chuo-ku Tokyo 103-0025 Tokyo Shoken Building 7F
    Tel. 03-3663-0505
    (Monday through Friday, 9:00 to 17:00, excluding holidays)

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