Declaration Of Protection Of Personal Information

Declaration of Personal Information Protection (Privacy Policy)

Established on June 26, 2007

Revised on September 20, 2012

Revised on January 31, 2014

Revised on June 29, 2017

Revised on December 12, 2019

Revised on May 31, 2021

Revised on March 10, 2022

Principal Global Investors Co., Ltd. (hereinafter referred to as "the Company") As an investment management business, investment advice and agency business, type II financial instruments business business, and companies engaged in business incidental thereto, information on individuals such as individual names, addresses, telephone numbers, e-mail addresses, etc. that can identify a specific individual (including information that can be easily compared with other information and thereby identify a specific individual). ), or items that contain an individual identification code (hereinafter collectively referred to as "personal information"). Other terms in this privacy policy are "Act on the Protection of Personal Information" (hereinafter referred to as the "Personal Information Protection Act"). It will be in accordance with the. may acquire, use, and manage the Company. In doing so, we will comply with laws and regulations such as the Personal Information Protection Act and protect personal information.

2. Protection of Personal Information and Safety Management Measures

The Company will comply with laws, regulations, and regulations such as the Act on the Protection of Personal Information, and will continuously improve this Privacy Policy, internal regulations concerning the protection of personal information, and its operation in accordance with revisions to laws and regulations, changes in social conditions, audit results, etc.

We are working on safety control measures as follows.

Formulation of Basic Policy
In order to ensure the proper handling of personal information (personal data), we have formulated basic policies such as information management regulations and compliance manuals.

Establishment of rules concerning the handling of personal data
Endeavor to keep the personal information in our possession accurate and up-to-date, and establish basic handling methods and systems for acquiring, using, storing, etc. personal data

Organizational Security Control Measures

The person responsible for information management appoints a person responsible for information management, implements the appropriate operation and strict management of personal information, and confirms that personal data is being handled in accordance with the established handling methods.

Human Security Control Measures
With regard to matters to note regarding the handling of personal data, we will thoroughly protect personal information to employees and provide education and training.

Physical Security Control Measures
Recognizing the risk of unauthorized access, leakage, loss or damage to personal information in our possession, we have implemented measures to prevent employees who can handle personal data from easily viewing personal data.

Technical Security Control Measures
Clarifying the equipment capable of handling personal data and the employees who handle such devices, and preventing unnecessary access to personal data

Understanding the external environment
Overseas Group companies that may share or store personal data shall implement
safety control measures to manage and operate personal information that is deemed to be at the same level as Japan in accordance with the global privacy standards of the Group companies. In addition, when providing personal data to a subcontractor within the scope of the purpose of use (described in 2. below), we will conclude a contract on confidentiality and personal information with the subcontractor, prohibit the use for purposes other than the original intent, take measures such as taking safety control measures, etc., and supervise the subcontractor.

2 . Handling of Personal Information

1) Personal information to be acquired

In the course of performing investment advisory services, operations related to discretionary investment contracts, investment trust management businesses, Type II financial instruments trading operations, and other operations that the Company can operate, the Company may acquire personal information, such as name, address, telephone number, fax number, e-mail address, date of birth, age, gender, occupation, position, name of employer, telephone number, fax number, e-mail address, etc.

When acquiring personal information directly from the person in question in writing, etc., the purpose of use is clearly indicated in advance in those documents, etc., but in other cases, except in cases where the consent of the person is obtained or it is handled as an exception by laws and regulations, etc., the Company will use personal information within the scope necessary to achieve the following purposes.

  1. To conduct operations related to investment advisory contracts (advisory services) or discretionary investment agreements with clients and operations incidental thereto;
  2. To conduct investment trust entrustment business and business incidental thereto
  3. To conduct Type II financial instruments business and operations incidental thereto
  4. To provide services related to investment advice and agency business
  5. To report and provide services such as investment results, contract asset balances, etc. to customers, etc. who provide services related to investment advice and agency business
  6. To judge the appropriateness of the provision of financial products and services in light of the principle of conformity, etc.
  7. To introduce the Company's services and to provide information on the Company's seminars, etc.
  8. To send materials in response to requests for information materials requested
  9. To contact those who have applied for recruitment
  10. To confirm that you are the person or your agent
  11. To contact you again if you are unable to respond immediately to an inquiry from a customer
  12. In order to appropriately and smoothly respond to customers, such as by making necessary contact

In addition, the Company will not acquire, use, or provide to third parties sensitive information such as information on political beliefs, religion, or health care without the prior and individual consent of the customer, except when permitted by laws and regulations.

2) Joint use

In carrying out the business described in "1) Personal Information to be Acquired" above, the Company may jointly use the personal data of joint users who are our group companies and customers described below. When sharing information, we will strictly comply with the Act on the Protection of Personal Information, the Financial Instruments and Exchange Act, related laws and regulations, and various regulations.

Purpose of use of joint users

・ To provide customers with comprehensive services as a group ・ For business management, business management, and risk management as a group

・ To conduct recruitment activities such as recruitment selection

Items of personal data to be shared

Personal information such as name, address, telephone number, fax number, e-mail address, date of birth, age, gender, occupation, title, name of place of employment, telephone number, fax number, e-mail address,
etc.

Scope of joint users

Group companies including Principal Global Investors LLC (U.S. corporation)

Name of the party responsible for the management of personal data related to joint use

Tokyo Chiyoda-ku, Uchisaikocho 1-chome 1-1-1 Imperial Hotel Tower 11th
Floor Principal Global Investors Co., Ltd.
Representative Hitoshi Itagaki

3) Provision to Third Parties

In cases stipulated in the Act on the Protection of Personal Information and other laws and regulations, when outsourcing the handling of personal data within the scope necessary to achieve the purpose of use, the Company will not provide personal data (personal information constituting a personal information database, etc.) to a third party without the prior consent of the person in question, except in cases where it is necessary to protect the public interest. In addition, personal information that does not fall under personal data will be handled in accordance with personal data.

3. Complaints and consultation desk of the industry group to which you are a member


The Company is a member of the Investment Trusts Association of Japan, which is an authorized personal information protection organization authorized by the Personal Information Protection Commission, and the Japan Investment Advisers Association, Japan General Incorporated Association. Each association accepts complaints and consultations regarding the handling of personal information of association members.

Complaints and Consultation Desk

Investment trust consignment business, investment trust self-recruitment business
Investment Trusts Association, Japan Investor Consultation Office
Tel: 03-5614-8440
http://www.toushin.or.jp/

Investment advisory business, business related to discretionary investment contracts
Complaint Consultation Office, Japan Investment Advisers Association
Tel: 03-3663-0505
http://www.jiaa.or.jp/

4. Inquiries to the Company
1) Procedures for disclosure, etc.

When there is a request for disclosure, correction, suspension of use, deletion, etc. of personal information, we will respond promptly after confirming the identity of the person himself/herself. For inquiries regarding this matter, please contact the following address.
In addition, when providing disclosure documents, we may request actual expenses depending on the contents of the request. (Such fees shall be deposited by transferring funds to a financial institution account designated by the Company.) )

100-0011
Tokyo Chiyoda-ku Uchisaikocho 1-chome 1-1-1 Imperial Hotel Tower 11th Floor,
Principal Global Investors Co., Ltd. Corporate Planning Department
Tel: 03-3519-7880

5. Others
Changes to this Privacy Policy and Other Changes
This Privacy Policy describes our general policy regarding the protection of personal information. Some specific services may have additional privacy policies. We also reserve the right to change all or part of this Privacy Policy from time to time. We will notify you of the changed contents by posting them on our website in a way that is easy for customers to understand.

That's All