SDG Impact Japan, Inc. (hereinafter the “Company”) will comply with the “Act on the Protection of Personal Information” and other related laws and regulations, guidelines, and social order, and will strive to properly handle and protect personal information based on the following policies, including compliance with laws and regulations, rules of self-regulatory organizations, prohibition of use for other purposes, and appropriate responses to complaints, etc.
1.Purpose of Use
The Company will utilize customers’ personal information (when a customer is a corporation, including individuals belonging to the customer; the same shall apply hereinafter). The Company shall use the personal information of customers for investment advisory services, Type-II Financial Instruments Business, and other services that financial instruments business operators are permitted to handle under laws and regulations (including those that will be permitted in the future), as well as for sustainability-related consulting and incubation business. The purposes of use are as follows.
- To perform administrative work, reporting, and guidance related to the above services and businesses.
- To provide events, seminars, and services related to the above services and businesses.
- To appropriately and smoothly respond to customers, including making necessary contacts in the course of performing the above operations.
- To respond to inquiries, requests, etc. from the media.
- To confirm the identity of customers in accordance with the Act on Prevention of Transfer of Criminal Proceeds and other laws and regulations.
- To conduct joint use as described in 4. below.
In the event that we intend to use the personal information for purposes other than those listed above, we will clearly state the purpose of use and obtain customers’ consent in advance when we ask you to provide us with your personal information.
Notwithstanding the above, we do not handle customers’ Individual Numbers. In accordance with the “Guidelines for Protection of Personal Information in the Finance Sector” and other guidelines, we will not acquire, use, or provide to third parties sensitive information (i.e., personal information requiring special consideration, information concerning membership of labor unions, family origin, registered domicile, health care, and sex life), except in the cases listed in the Guidelines.
2.Provision of Personal Information to Third Parties
A customer’s personal information will not be provided to third parties except in the following circumstances.
- When we have the customer’s consent
- When the provision of personal information to a third party is permitted by law, such as when a public agency inquires based on laws and regulations
- When the Company entrusts the handling of personal information to a subcontractor with whom the Company has concluded a nondisclosure agreement, within the scope necessary to achieve the purpose of use specified to the customer.
- When personal information is provided in connection with succession of business due to a merger or other reasons
- When providing customers’ personal information to a joint user as described in 4. below.
3.Security Control Measures for Personal Information
We will comply with all laws and regulations applicable to personal information. With respect to the handling of personal information provided by customers, we will strive to ensure the proper management of personal information by appointing “Data Protection Officer” (DPO) a person responsible for the management of such information, and by developing an organizational structure to appropriately and strictly manage such information.
In addition, we will take necessary and appropriate security measures to prevent the leakage of personal information to outside parties and to prevent unauthorized access to personal information from outside parties and thus strive to ensure the secure management of our customer’s personal information.
To achieve the above objectives, we have implemented the following security management measures:
- Establishment of Personal Information Protection Guidelines: We have formulated this Privacy Policy as a basic policy to ensure the proper handling of personal information in accordance with the laws and guidelines.
- Development of Rules for Handling Personal Data: We have established various rules and regulations, including the “Personal Information Management Rules,” which specify the procedures for acquiring, using, storing, providing, and deleting personal data, as well as defining responsibilities and roles.
- Institutional Security Management Measures: We have appointed responsible personnel, clarified the scope of personal information handled by employees, and established a reporting and communication system for when there are indications or facts of violations of the Personal Information Protection Act or internal regulations. We also conduct regular inspections of the handling process.
- Human Security Management Measures: We enter into confidentiality agreements with officers and employees concerning personal information and conduct training on key points related to the handling of personal information.
- Physical Security Management Measures: We manage employee access and take measures to prevent theft, loss, or other incidents involving devices, electronic media, and documents that handle personal information.
- Technological Security Management Measures: We have introduced systems to protect the information systems handling personal data from unauthorized access or malicious software.
- Understanding of External Environments: When storing or handling personal data abroad, we will investigate and understand the systems of each country concerning the protection of personal information.
We will periodically review the above measures to ensure appropriate management and will continue to take measures for improvement.
4.Joint Use
Within the scope of the laws and regulations and the purpose of use, the Company will jointly use the customer’s name, name of the employer (organization to which the customer belongs), address of the employer, title, telephone number, facsimile number, e-mail address, and other related matters as follows.
- Scope of joint users: The following entities belonging to the SIJ Group
- RIMM Japan Inc.
- SIJ Climate Godo Kaisha
- SIJ Capital Godo Kaisha
- Climate Neo Inc.
- Purposes of use by joint users
- For marketing and guidance regarding various services provided by the SIJ Group
- For business management of the SIJ Group
- To ensure the appropriate and smooth performance of transactions with customers by the SIJ Group
- Name of the party responsible for management of personal data to be jointly used
- SDG Impact Japan Inc.
5.Inquiries Regarding Personal Information
We will respond to inquiries from customers regarding personal information in good faith in accordance with our prescribed procedures.
- When a customer makes a request for information disclosure following the Act on the Protection of Personal Information, (hereinafter referred to as a “Request for Disclosure, etc.”) for any of the following items (1) through (3) regarding personal data held by the Company, the customer is required to fill out the Company’s designated form and attach identification documents (in the case of a request made by a representative, documents showing the representative’s authority of representation and identification documents are to be included).
In principle, we do not charge a fee for requests for disclosure, etc.
- Disclosure of personal data held by the Company (including whether or not the Company holds such data) concerning the customer himself/herself
- Correction, addition, or deletion of said data (limited to cases where the data is inaccurate)
- Suspension of use or restriction on provision to third parties of said data (limited to cases in which said data is used or provided in violation of laws and regulations)
6.Contact for Inquiries about Personal Information
Please contact the following for any inquiries or comments regarding the handling of personal information.
(1) SDG Impact Japan Inc. (Contact: Legal & Compliance Division)
Address: 7F Kishimoto Building, 2-2-1 Marunouchi, Chiyoda-ku, Tokyo 100-0005, Japan
https://sdgimpactjapan.com/contact/
- Please note that when responding to inquiries, we may need to confirm the customer’s identity.
- Customers may also consult with the following organizations, of which we are a member, regarding the handling of personal information.
(2) Contact Information for the Authorized Personal Information Protection Organization
Complaints and Consultation Office (in charge of personal information)
Japan Investment Advisers Association
Address: Tokyo Shoken Kaikan 7F, 1-5-8 Nihonbashi Kayabacho, Chuo-ku, Tokyo 103-0025, Japan
Telephone number: 03-3663-0505
Hours: 9:00 a.m. to 5:00 p.m., Monday through Friday (excluding national holidays)
7.Changes to the Privacy Policy
The Company reserves the right to change this Privacy Policy without prior notice in accordance with amendments to laws and regulations or for other reasons. In the event of a significant change, the Company will post the details of the change on its website for a certain period of time.
