Privacy Policy

March 2010
Daiwa Securities Capital Markets Co. Ltd.

Daiwa Securities Capital Markets Co. Ltd. (the “Company”) establishes and announces its privacy policy concerning the appropriate protection and use of personal information pursuant to the Act on the Protection of Personal Information.

This privacy policy will be reviewed from time to time and continuously improved in order to ensure that the customers’ personal information will be appropriately treated.

1.　Action Policy for Personal Information

• The Company will comply with this privacy policy as well as the Act on the Protection of Personal Information, the other relevant laws and regulations and the guidelines of the supervisory authorities (the “Laws and Regulations”).
• The Company will acquire personal information in an appropriate and lawful manner to the extent necessary for its business purposes and will not use any personal information for any other purpose.
• The Company will promptly and accurately respond to inquiries, complaints, etc. from its customers.

2.　Purposes of Use

The Company will acquire and use the personal information of its customers to the extent necessary for the accomplishment of the following purposes, except in cases where the consent of the customer is obtained or where the acquisition and/or use of such information is permitted by the Laws and Regulations as an exception:

• To solicit for, sell, or give information concerning, financial instruments pursuant to the Financial Instruments and Exchange Act.
• To determine the reasonableness of offer of the products or services in the light of the principle of suitability, etc.
• To confirm the identity of customers or their respective agents.
• To report to customers their respective trading results, account balances, etc.
• To carry out the affairs relating to customer transactions.
• To conduct market research, and research and development of financial instruments and services based on carrying out a data analysis or a questionnaire, etc.
• If the Company is entrusted by any other business entity with all or any part of its functions including any personal information, to appropriately carry out such entrusted functions.
• Other than those above, to appropriately and smoothly carry out customer transactions.

3.　Appropriate Acquisition of Personal Information

The Company will acquire customer's personal information from the following sources in an appropriate and lawful manner to the extent necessary for the accomplishment of the purpose of use.

• The informational directly filled into an account application form, questionnaire, and etc by the customers.
• The information publicized on the newspaper, internet and books.
• The information acquired by the customers through provisions of commodity and service.

4.　Ensuring the Accuracy of Personal Data

The Company will endeavor to maintain the accurate and current personal data to the extent necessary for the accomplishment of the purposes of use.

5.　Security Measures

The Company will implement the necessary and appropriate security measures, and adequately supervise its officers and employees, in order to prevent the disclosure, divulgence, leakage or the like of personal data acquired from customers.

6.　Provision of Personal Data to Third Parties

The Company will not disclose or provide to third parties any personal data of its customers without their respective prior consent, except as permitted by the Laws and Regulations.

7.　Entrustment of Handling of Personal Data

The Company may entrust the handling of personal data acquired from its customers to the third parties to the extent necessary for the accomplishment of the purposes of use, in such cases below and so on, after entering into an agreement including the requirement of the Laws and Regulations. In the case of entrustment, the Company will supervise the entity entrusted by it with necessary and adequate care, including supervision of any entity entrusted by the entity entrusted by the Company.

• Printing and mailing operations of letters for customers.
• Business operations concerning operation and management of information systems.

8.　Joint Use of Personal Data

The Company may use personal data jointly with its group companies, in order to offer higher-value-added services and financial instruments while utilizing the expertise of the group companies, within the following scope.

The Company will not jointly use undisclosed information which is defined under the Cabinet Office Ordinance on Financial Instruments Business.

In case where joint use is restricted by any Laws and Regulations, we shall not jointly use personal data unless joint use is allowed by such Laws and Regulations as in the case where customer's written consent of such use is obtained.

9.　Disclosure Request Procedure

When a request is made to the Company by its customer or his/her agent for the disclosure, modification, addition, deletion, discontinuation of use, erasure, discontinuation of the provision to third parties or the like (a “Disclosure Request”) of such person’s personal data retained by the Company, the Company will, upon confirmation of the identity of such customer or agent, respond to the Disclosure Request in writing within a reasonable period and to a reasonable extent, unless the requested disclosure or the like is not required by the Laws and Regulations.

• Items of Retained Personal Data Subject to a Disclosure Request
  Name, address, telephone number, date of birth, place of employment (company name or occupation and telephone number), trade balance (account number and account balance), trading history, etc.
• Contact for a Disclosure Request
  Relevant sales operation section of the Company.
• Documents to be Submitted
  • “Request for Disclosure of Personal Information” in the form prescribed by the Company.
  • Identity verification documents (copy of the driver’s license, passport or the like).
  • Power of attorney to confirm the grant of authority of agency (in the case of a request made by the customer’s agent. Note that the Company is unable to respond unless and until the Company confirms the grant of authority of agency.)
• Manner of Response
  The Company will respond by sending the documents to the address registered by the customer or his/her agent. Note that, even in the case of a request made by the agent, we may respond directly to the customer.
• Purposes of Use of Personal Information Obtained through a Disclosure Request
  The personal information obtained by the Company through a Disclosure Request will be used for the purposes of investigation for the request procedure, confirmation of the identity of the customer and his/her agent, fee collection, and responding to such Disclosure Request.
• Fees
  We may charge a request processing fee depending on the substance of the investigation required for a Disclosure Request.

10.　Handling of Sensitive Information

The Company will not obtain, use, or provide to any third parties any sensitive information (including, without limitation, information concerning any person’s political position, personal beliefs (religion, philosophy, or creed), membership of any labor union, race or ethnic group, family origin, registered domicile, medical or health care record, sexual activities, or criminal record), except as permitted by the Laws and Regulations.

11.　Complaints

If the Company receives a complaint or the like from its customer with respect to the security control measures for personal information or any other treatment, the Company will endeavor to promptly and faithfully respond to such complaint. For the complaint processing, please contact the following department of the Company:

[Contact for complaints]

Compliance Department
Gran Tokyo North Tower, 1-9-1 Marunouchi, Chiyoda-ku, Tokyo 100-6753
(Phone: 03-5555-6800, 9:00 a.m. to 5:00 p.m., weekdays)

12.　Authorized Personal Information Protection Organization

The Company is a member of the Japan Securities Dealers Association (“JSDA”) that is an authorized personal information protection organization approved by the Finance Services Agency. Personal Information Consultation Office of JSDA will receive complaints and provide consultation with respect to its members’ handling of personal information.

[Contact for complaints and consultation]

Personal Information Consultation Office, Japan Securities Dealers Association
(Phone: 03-3667-8427)
（http://www.jsda.or.jp/）