Privacy Policy

(Handling of Customer's Personal Information)

NAM is committed to the appropriate management, usage and protection of the customer's personal information ("personal information") with a keen awareness of the importance of protecting such information. We will maintain and improve this policy with the aim of pursuing the appropriate protection of personal information.

1. Acquisition of Personal Information

NAM acquires personal information by lawful and fair means within the scope required for the performance of its business.

2. Purpose of Personal Information

NAM uses personal information (excluding the personal identification numbers (“Personal Identification Numbers”) stipulated in Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (“My Number Law”) in Japan) exclusively for the following purposes in the areas of investment management services, investment advisory services, Type II Financial Instruments Business, and incidental activities to them:

  • To make sales solicitations and notify customers of our products and/or services in the above business fields.
  • To assess the adequacy of our provision of products and services in light of the principle of appropriateness.
  • To verify the identity of customers or confirm their proxies.
  • To report investment results and asset balance to customers.
  • To implement clerical tasks relating to transactions with customers.
  • To conduct research and development for financial products and services through market surveys, data analyses, questionnaires, etc.
  • To conduct more appropriate and smooth transactions with customers.

NAM handles and limits the scope of use of the Personal Identification Numbers in accordance with My Number Law required to perform the following.

  • To prepare the payment records concerning the transactions with customers.
  • To prepare payment records concerning compensations, fees and awards.
  • To perform other administrative tasks related to Personal Identification Numbers stipulated by relevant laws and regulations.

3. Provision of Personal Data

NAM may offer personal data (defined in Article 2-(6) of “Act on the Protection of Personal Information” in Japan) excluding Personal Identification Numbers to third parties to the extent required when we have obtained the prior consent of the customers themselves, when we entrust business activities to such third parties for the purpose of use informed to the customers at the time of the acquirement of the personal information, when the provision of personal data is required by relevant laws or regulations or when the provision of personal data is necessary for public benefit.

4. Management of Personal Information

NAM devises appropriate measures in order to ensure the accuracy and safe management of personal information.
NAM devises measures required for the prevention of unauthorized access to personal information and other improper use.

5. Disclosure, Correction, Discontinued Usage and Deletion of Personal Information

If a customer requests disclosure, correction, termination of use or deletion of such customer’s personal information, NAM will promptly respond to such requests after identification of the customer except under unacceptable circumstances.

6. Organization Structure

NAM appoints the responsible supervisors for the management of personal information in order to assure the proper management of personal information.
NAM familiarizes all of its staff members thoroughly with the proper handling of personal information in daily business by holding seminars on the protection and proper management of personal information.

7. Compliance with Relevant Laws and Regulation

NAM complies with relevant laws and regulations relating to the protection of personal information when handling personal information.

8. Creation, Maintenance and Improvement of the Compliance Manual

NAM has formulated internal rules and a compliance manual in order to carry out this policy. It familiarizes all of its staff members with those rules and the manual while implementing, maintaining and constantly improving them.

9. Comments from Customers regarding Personal Information

We accept comments from customers regarding the handling of personal information at the consultation desk telephone number below in order to ensure the handling of information in an appropriate manner;

Consultation Service Desk Telephone

Legal and Compliance Department tel. 03-5533-4920
Business hours 9am - 5pm, Monday - Friday (JST) except Public holidays and New Years holidays