1. JLPS Group Statement on Personal Information Protection
- A. Who is responsible for the data processing and who can you contact?
Responsible as a controller for the processing of your personal data is:
JLPS Ireland Limited
Address: Universal House, Shannon Industrial Estate, Shannon, Co. Clare, Ireland
- B. How do JLPS Group process personal data?
JLPS Group process various personal data you provide to us when using our website for several purposes.
In principle, the following can be considered as the purposes of the processing:
- Contacting us via email or inquiry form
When you contact us by e-mail, your e-mail address, as well as any other details provided by you will be processed by us in oreder to best answer any questions or issues you may have.
When you use our inquiry form, JLPS Group process the personal data you provide in said form: name, company/organization, country/region, email address, telephone number and any data disclosed in the form in order to best answer any questions or issues you may have.
Legal basis for the processing of personal data is Article 6-1 (f) GDPR (legitimate interests). Our legitimate interest for the processing is the offering of good customer care and the optimal handling of your requests.
- Establishing and maintaining business relationships
JLPS Group maintain business relationships with our customers, suppliers, and other business contacts. For this, JLPS Group process Your Name, Your E-mail Address, Telephone Number, Corporate/Organization, Title and all other personal data you choose to disclose to us in relation to our business relationship.
The processing of the personal data is based on (Art. 6-1 (b) GDPR) (the initiation of contractual relationships and the performance of contracts) and Article 6-1 (f) GDPR (legitimate interests). We have a legitimate interest in maintaining business relationships and staying in touch with our business partners.
Log Data and Cookies
While visiting our website, the following specific data is stored upon every visit:
- Name of your internet provider
- Time and date of your visit
- Browser information
- Referral-URL (previously visited website)
- Information on your device
- Information on your browsing behavior
JLPS Group differentiates between strictly necessary cookies, which are required for the use of our websites, statistics cookies, with which JLPS Group generates aggregated data on website usage and statistics, and marketing cookies to display relevant content and advertising.
As far as data is collected by cookies, which are strictly necessary for the use of the website, the use of such cookies is based on Article 6-1 (f) GDPR. Purpose and our legitimate interests are administration and improved functionality of our website as well as preventing security issues (e.g. hacking).
Other cookies, such as statistics cookies and marketing cookies are only used if you have given us your prior consent pursuant to Article 6-1 (a) GDPR. Purpose of the processing of statistics cookies is the analysis of the use of our website as well as improved functionality with regard to the website and purpose of the processing of marketing cookies is advertising. You have the right to withdraw your consent to such cookies at any time with effect for the future.
- C. Are you obliged to provide personal data?
There is no legal or contractual obligation to provide us with your personal data when using our website. JLPS Group only asks you to provide us with the data necessary for providing our services. Without this personal data, JLPS Group are not able to offer you the full functionalities of the website and our services may be limited.
- D. With who do JLPS Group share personal data?
JLPS Group use external service providers to process personal data when providing the website and its functionalities and services to you. Processing of personal data by such service provider is carried out on our behalf and in accordance with our instructions (so-called "Processors", see Article 4-(8) GDPR).
JLPS Group engage the following service providers or categories of services providers:
- IT Service Providers (including hosting, administration and security reviews).
JLPS Group may also share personal data with recipients, which process personal data under their own responsibility for their own purposes (see Article 4(7) GDPR).
- E. Do JLPS Group transfer personal data to third countries?
Any transfer to a third country shall take place only in compliance with the applicable data protection regulations and where we can ensure that the recipients of the data will offer the same level of data protection.
JLPS Group transfer your personal data in the following cases:
- Processing of personal data by services providers located in Japan acting on our behalf, including hosting and administration of our website (see Section D). According to the EU Japan adequacy decision by the EU Commission Japan provides an adequate level of protection pursuant to Article 45 GDPR.
- F. How long do JLPS Group store personal data?
JLPS Group process your personal data as long as they are necessary for specific processing purposes.
In general, JLPS Group store your personal data for the time required for carrying out the processing for the purposes above, unless storage beyond this period is necessary to fulfill the respective processing purposes.
- G. How do JLPS Group secure personal data?
JLPS Group maintain up-to-date technical measures to safeguard data security, in particular to protect your personal information from threats when transferring data and from third parties gaining unlawful knowledge. These measures are constantly adapted to the latest state-of-the-art.
In order to prevent unauthorized access by third parties to your personal data, the connection is encrypted using SSL technology.
- H. Which rights do you have?
You have the right of access (Art. 15 GDPR), the right to rectification (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR).
When personal data is processed based on your consent, you have the right to withdraw your consent according to Art. 7 (3) GDPR. Please keep in mind that your withdrawal only affects future processing based on your consent.
To exercise the aforementioned rights, you can contact us, in particular via email under firstname.lastname@example.org. Please note that JLPS Group may require you to present proof of identity to verify the eligibility of your rights execution.
If you are of the opinion that the processing of your personal data is unlawful, you have the right to lodge a complaint with the competent supervisory authority (Article 77 GDPR). This right to complain is without any prejudice to any other administrative or judicial remedy.
- Information about your right to object in accordance with Article 21 General Data Protection Regulation (GDPR)
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you on the basis of Article 6-1 (f) GDPR (processing of personal Data based on legitimate interests); this includes profiling based on those provisions (Article 4 (4) GDPR).
Should you decide to object the processing, JLPS Group will stop to process personal data concerning you, unless JLPS Group can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves the purpose of establishment, exercise or defence of legal claims.
You also have the right to object at any time to processing of personal data concerning you for the purpose of advertising; this also applies to profiling insofar as it is associated with advertising.
Should you decide to object to the processing for advertising purposes, JLPS Group will stop to process personal data concerning you for these purposes.
Established on August 1, 2020
- Contacting us via email or inquiry form
JP Lease Products & Services Co., Ltd
JP Lease Products & Services Co., Ltd.(hereinafter "JLPS-JP") will comply with laws and regulations regarding the protection of personal information, and will continue to conduct its business in a manner that ensures the appropriate acquisition, handling, and management of personal information. JLPS-JP has formulated and announced the following Declaration of Personal Information Protection regarding our approach and policy for the protection of our customers' personal information.
Compliance with related laws and regulations
JLPS-JP will comply with the Act on the Protection of Personal Information, the Act on Investment Trusts and Investment Corporations, the Financial Instruments and Exchange Act, other related laws and regulations, guidelines issued by the competent ministers, guidelines issued by related industry organizations, and this Declaration on the Protection of Personal Information.
Use of personal information and its purpose of use
JLPS-JP handles the personal information of our customers within the scope necessary to achieve the following business activities and purposes of use, except in cases where we have obtained the consent of the customer or where it is treated as an exception under laws and regulations. Specifically, the general contents of personal information include the customer's name, address, date of birth, contact information such as telephone number and e-mail address, and information about the customer's place of work. By the Cabinet Office Ordinance on Financial Instruments Business, etc., JLPS-JP does not use or provide to third parties special non-public information (sensitive information), such as information on race, creed, family origin, legal domicile, health care, or criminal record, for purposes other than those deemed necessary for appropriate business operations.
- (1) Description of business
- The financial instruments business (handling the private placement and trading of securities) and related operations
- Businesses that can be carried out by financial instruments business operators under the Financial Instruments and Exchange Act and other laws, as well as incidental businesses
- Other operations that can be carried out by financial instrument business operators and related operations (including operations to be permitted in the future)
- The insurance agency business and related operations
- (2) Purpose of use
- To promote and sell securities and various financial products, and provide information on available services by the Financial Instruments and Exchange Act enforced by JLPS-JP or affiliated companies
- To introduce and offer insurance products by the Insurance Business Law enforced by JLPS-JP or affiliated companies
- To make various proposals and provide information on products and services of JLPS-JP group companies and partner companies
- To fulfill the obligation to confirm the identity of a customer based on the Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act, and other laws and regulations.
- To make judgments regarding the appropriateness of providing financial products and services, including judgments in light of the principle of suitability.
- To confirm the identity of the customer or the identity of the customer's agent by laws and regulations, and to confirm the eligibility of the customer to use financial products and services, etc.
- To provide information to third parties to the extent necessary for the proper execution of business
- To provide customers with reports on transaction results, deposit balances, etc.
- To perform administrative processing, screening, and record-keeping related to transactions with customers
- To research and develop financial products and services through market research, data analysis, questionnaires, etc.
- To appropriately carry out the entrusted work in cases where all or part of the processing of personal information is entrusted by other businesses, etc.
- To exercise rights and fulfill obligations based on contracts and laws with customers.
- To send direct mail and make other proposals regarding financial products and services, etc.
- To terminate various transactions and to manage the administration after the termination of transactions
- To understand and manage various risks and for internal management purposes.
- To obtain information necessary to respond to inquiries from customers.
- To send greeting cards, etc., and to provide information on various seminars, receptions, etc.
- To carry out other transactions with customers appropriately and smoothly.
- To appropriately execute the entrusted work in cases where JLPS-JP is entrusted with all or part of the work of managing the personal information of unitholders by an investment corporation as a general administrative agent.
- To recruit human resources for JLPS-JP.
- To provide personal information to banks, sales companies, or our affiliates with which we have a contractual relationship, to the extent necessary to achieve the above purposes.
If the need arises to use the customer's personal information for purposes other than those stated at the time of receiving the personal information from the customer, JLPS-JP will notify the customer in advance or make a public announcement of the purpose of use, except in certain cases stipulated by law. The basic method of notifying customers of the purpose of use of their personal information shall be in writing, but may also include notification by e-mail or telephone (including automated voice). As for the method of public announcement, JLPS-JP's basic method of notifying customers of the purpose of use of personal information is by posting it on the JLPS-JP's website or by notifying them in writing.
3. Response to complaints from customer
It is our policy to respond to any complaints from our customers in a prompt, cooperative, sincere, and professional manner.
4. Restriction on provision to third parties
As a general rule, JLPS-JP does not provide our customers' personal information to third parties. JLPS-JP may provide your personal information to parties other than us if JLPS-JP has your consent if required by law, if JLPS-JP entrusts the handling of your personal information to a third party within the scope necessary to achieve the purpose of use, or if JLPS-JP share your personal information with a specific party as specified in the next section.
5. Joint use
JLPS-JP may share your personal information with our group companies within the scope of the purpose of use to provide you with high value-added services by utilizing their respective expertise and strengthening cooperation. JLPS-JP will be responsible for receiving and addressing complaints and other concerns regarding the management of personal information that is shared. JLPS-JP will stop the provision of your data to a third party if you request us to do so.
6. Safety Management Measures
JLPS-JP will strive to keep our customers' personal information accurate and up-to-date. To prevent the leakage, loss, or damage of customers' personal information, JLPS-JP has established internal rules for the protection of personal information, and JLPS-JP will review and revise them as necessary to establish an appropriate internal system. To prevent the loss, destruction, alteration, or leakage of personal information, JLPS-JP will implement strict security measures, including measures against unauthorized access and computer viruses. In addition, we will appropriately supervise and check the compliance status of our officers, employees, and contractors, as well as handle complaints in an appropriate manner.
7. Procedures for requesting disclosure, etc.
By the Act on the Protection of Personal Information, JLPS-JP will respond to requests from customers for disclosure of the content of retained personal data, correction, addition, deletion, suspension of use, deletion, or suspension of provision to a third party in cases where the content of retained personal data is contrary to the facts. We will confirm the identity of the person making the request, and respond to the request in an appropriate and timely manner by our prescribed procedures. JLPS-JP also accepts complaints and other inquiries from customers regarding the handling of their personal information. For more information, please contact the person in charge of your company or the contact information below.
- (1) Contact for requests for disclosure
Inquiry Desk for Personal Information
Kasumigaseki Common Gate West Tower 21F
3-2-1 Kasumigaseki Chiyoda-ku Tokyo,
Office hours: 9:00 a.m. to 5:00 p.m. (except Saturdays, Sundays, national holidays, and year-end and New Year holidays)
- (2) Request method
- Please fill out, seal, and submit the prescribed form "Personal Information Disclosure and Correction Request Form".
- (3) Method of verifying the identity of the person requesting disclosure, etc. (including proxies)
- The identity of the person requesting disclosure, etc. (including proxies) will be confirmed by presenting documents such as a passport or driver's license that can be used as official proof of the person's identity.
- (4) Fee amount and collection method
- Depending on the nature of the customer's request, the Compnay may charge the actual cost. The fee will be paid by transfer to a financial institution account designated by JLPS-JP.
- (5) Matters necessary to identify the retained personal data that is the subject of the request for disclosure, etc.
- We will ask you to provide your name, date of birth, address, telephone number, account number, etc.
- (6) Method and timing of the response to requests for disclosure, etc.
- In principle, we will respond within two weeks. However, depending on the nature of the request, it may take longer in some cases. JLPS-JP will respond in writing as soon as JLPS-JP confirms receipt of the "Request for Disclosure, Correction, etc. of Personal Information" form and payment of the prescribed fee (only in cases where a fee is charged). Please note that the response will be mailed to the customer's registered address.
- (7) Method of confirming the right of representation when the person requesting disclosure, etc.
- JLPS-JP will confirm the granting of the right of representation through a letter of attorney or a direct telephone call with the person in question.
8. About Cookies
A cookie is a small text file that the website sends to your device to keep records. It identifies your device, typically your web browser, but it cannot identify you as an individual. Cookies on our website gather analytical data to improve performance. You can choose whether to allow us or third parties to set cookies that are not strictly necessary for the functioning of the website via the cookie banner and settings provided on the individual websites (available where legally required).
The content of the above information is subject to change based on amendments to laws and regulations or other reasons. In such cases, JLPS-JP shall post such changes on JLPS-JP's website, etc., and such changes shall become effective at the time of posting.
10. Compliance with Laws and Regulations and Improvements
To ensure the safe management and proper handling of our customers' personal information, JLPS-JP will review this Declaration of Personal Information Protection from time to time and strive for continuous improvement.