Privacy Policy

(Handling of Customer's Personal Information)

1. Acquisition of Personal Information

NAM acquires personal information by lawful and fair means within the minimum 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”) of Japan) exclusively for the following purposes in the areas of investment management services, investment advisory services, Type II Financial Instruments Business, and services incidental to the foregoing:

• To conduct solicitations and marketing of securities and financial instruments under the Financial Instruments and Exchange Act of Japan and introduce our services to our customers, based on the status of assets and past investments of customers, opinions and requests received through our call centers or by other means and the analysis and evaluation of customer’s web browsing history, etc.
• To assess the appropriateness of our provision of products and services in light of the suitability principle.
• 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 and counterparties and to conduct our internal management.
• To conduct research and development for financial products and services through market surveys, data analyses, questionnaires, etc.
• To perform transactions appropriately and smoothly with customers and counterparties.
• To respond to requests for investigation and/or reporting from the supervisory authority, financial instruments exchanges and self-regulatory organizations, etc. pursuant to relevant laws and regulations.
• To exercise rights and/or perform obligations under the customer contracts or laws and regulations, etc.

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.

NAM uses personal information within the purpose of use indicated upon acquiring such information (the “Purpose”) and to the extent necessary for the performance of our services.
NAM announces the Purpose by way of posting this Privacy Policy on our homepage.

3. Provision of Personal Data

NAM may provide personal data (excluding Personal Identification Numbers) to third parties, to the extent necessary, when we obtain prior consent of customers or entrust business activities to third parties for the Purpose, when provision of personal data is required by relevant laws or regulations or provision is necessary for the public benefit.
Customer’s Personal Identification Number will not be provided to third parties unless permitted by My Number Law, such as to submit it to the Person in Charge of Processes Using Personal Identification Number or to outsource all or part of the work of handling the Personal Identification Number to third party, etc.

4. Management of Personal Information

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

5. Security Control Measures for Personal Data

NAM establishes handling rules and implementation systems for security control and takes other adequate security measures in order to prevent the leakage, loss or damage of personal data or otherwise control the security of personal data.
NAM takes appropriate measures in order to ensure that the personal data, necessary to attain the Purpose, is accurate and up-to-date.
If NAM outsources the handling of personal data to a third party, NAM will check the third party's information management system and conduct other necessary and appropriate supervision over the third party such as to continue the monitoring of performance of its operations during outsourcing.

6. Disclosure, Correction, etc., Discontinued Usage, etc. and Cessation of Provision to Third Parties of Retained Personal Data under the Act of the Protection of Personal Information

If a customer requests disclosure (including disclosure of records of third party provision), correction, addition or deletion, termination of use or erasure and cessation of provision to third parties of retained personal data under the Act of the Protection of Personal Information of Japan, unless there is unacceptable reason, NAM will promptly respond to such requests after verification of the identification of customer.

7. 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 its officers and employees thoroughly with the proper handling of personal information when conducting day to day work by holding seminars on the protection and proper management of personal information.

8. Compliance with Relevant Laws and Regulations

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

9. Creation, Maintenance and Improvement of the Compliance Manual

NAM has formulated internal rules and a compliance manual in order to carry out this policy. NAM familiarizes all its officers and employees with those rules and manual, and implement, maintain and constantly improve such rules and manual.

10. Requests/Comments from Customers regarding Personal Information

We accept requests/comments from customers regarding the handling of personal information at the Consultation Service Desk below;

Consultation Service Desk

Revised: February 15, 2022