Jiro Yasu
Representative Director
VARECS Partners Limited
Jyujiya Building 4F
1-6-17 Nihonbashi Kayabacho
Chuo-Ku, Tokyo, 103-0025, Japan
VARECS Partners Limited and its officers, employees established the “Rules for Privacy Data Protection” and endeavor to comply with the laws and regulations relating to the Personal Information, including, but not limited to “Act on the Protection of Personal Information”, “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures”.
１．Purpose of Use of Personal Information
We will use the Personal Information entrusted to us to the extent necessary for the following purposes, not for any other purposes.
（1）Operation and performance of our Investment Advisory Business, Discretionary Investment Management Business and any other any services incidental thereto (collectively the “VARECS’s Product and Services”), including but not limited to:
- Processing administrative matters relating to transactions on the clients’ accounts
- Providing various reports to the clients
- Research, due diligence and engagement with investee companies and potential investment target.
(2) Solicitation and provision of information regarding our products and services.
(3) Determining the suitability of our product and service.
(4) Verifying the identity of clients or their authorized representatives
(5) Performance of contractual obligations and exercise of rights or performance of obligations under laws and regulations.
(6) Market research, data analysis, surveys and analysis of attribute information and behavioral history including information obtained from browsing history, etc.
(7) Performance of operations entrusted to us by other business operators, in whole or in part, for the processing of personal information.
(8) Any other purposes necessary for the proper and smooth execution of transactions with our clients and business counterparties.
Notwithstanding hereinabove, in case the Purpose of Use of Personal Information is defined by the law, such as the Numbers to Identify a Specific Individual under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, we shall not use personal information for the purpose other than set out in such law.
２．Requests for Disclosure, Correction, Suspension of Use, etc.
Requests for notification of purpose of use, disclosure, correction, suspension of use, suspension of third-party provision, disclosure of third-party provision records, etc., in accordance with applicable laws, shall be handled as follows:
(1) Documents to be submitted
① Our prescribed reqeust form ② Identification documents ③ Processing fee
(2) Processing fee
A fee of JPY 660 per request will be charged to cover postal costs.
(3) Submission address
Please send the above documents by mail to the contact address below.
(4) Scope of personal data subject to the request
Personal data held by us (including name, employer address, telephone number, company name, etc.)
(5) Method and timing of response
We will respond in writing within a reasonable period. Please note that even if the request is submitted by an agent, we may respond directly to the data subject.
３．Measures for the Safe Management of Retained Personal Data
(1) Establishment of a basic policy
This “Declaration of Personal Information Protection” has been established to ensure the proper handling of personal data.
(2) Development of internal rules
We have established “Rules for Privacy Data Protection” that set forth handling rules for acquisition, use, storage, etc.
(3) Organizational security measures
We appoint ”Privacy Officer” who plays the role as a Personal Information Manager and clearly state that violations of the internal rules are subject to disciplinary action. We also conduct periodic self-inspections regarding the handling of personal data.
(4) Human security measures
We provide training on the handling of personal data as part of annual compliance training for employees. After training, employees are required to confirm that they have not violated internal rules, including the “Rules for Privacy Data Protection”.
(5) Physical security measures
We control entry to and exit from areas where personal data is handled, and take measures to prevent theft or loss of equipment, electronic media, and documents containing personal data.
(6) Technical security measures
We manage access rights to personal data and implement security measures such as the use of security software.
(7) Understanding of external environments
When personal data is stored overseas, we confirm the personal data protection system of the relevant country and implement security measures equivalent to the above through contracts and other means. Where we have taken necessary measures to ensure the continuous implementation of appropriate safeguards by third parties, we will provide information regarding such measures to the data subject upon request, in accordance with the rules of the Personal Information Protection Commission.
4．Contact for Inquiries
For inquiries regarding the handling of personal information, please contact:
Middle office (Kanri Group) TEL: +(81) 3-3666-0306
Address：4F, Jujiya Building, 1-6-17 Nihonbashi Kayabacho, Chuo-ku, Tokyo 103-0025, Japan
5．Request or consultation desk at accredited Personal Information Protection Organization
VARECS Partners Limited is a member of JIAA, the Japan Investment Advisers Association, an accredited personal information protection organization certified by the Financial Services Agency of Japan.
The contact point for complaints and consultations regarding the handling of personal information by member investment advisory firms is as follows:
JIAA, the Japan Investment Advisers Association
Complaint Consultation Office
TEL：+(81) 3-3663-0505