PRIVACY POLICY

This Privacy Policy applies to all users of our website https://www.jlps.co.jp with permanent residence in the European Union and explains how your personal data is being processed while using our website as well as the rights you have under the European General Data Protection Regulation ("GDPR").

We, JP Lease Products & Services Co., Ltd. and JLPS Ireland Limited ("JLPS Group"), take the protection of your personal data very seriously and strictly adhere to the rules of data protection laws. The following privacy policy gives you an overview of how JLPS Group ensure data protection and what types of personal data are processed for what purpose.

With regard to the terminology used in this Privacy Policy, e.g. "personal data" or "processing", JLPS Group refer to the definitions in Article 4 of the GDPR.

Please read the following information regarding the Privacy Policy carefully. In case you have further questions, please do not hesitate to contact us at any time at "Contact Us". "

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.

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.

It is our policy to respond to any complaints from our customers in a prompt, cooperative, sincere, and professional manner.

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.

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.

Items of personal information to be shared

• Customer's name, address, date of birth, contact information such as telephone number and e-mail address, and information about work place, etc.

Person responsible for the management of personal information

• JLPS-JP

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.

By the Act on the Protection of Personal Information, JLPS-JP will respond to statutory request 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, 　
100-0013, Japan.
TEL:+81-3-6804-6805
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.

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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.

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.