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Privacy Policy

May 2017
Daiwa Asset Management Co. Ltd.

Daiwa Asset Management Co. Ltd. (the "Company"), pursuant to the Act on the Protection of Personal Information, has established a Privacy Policy, and will comply with the policy and treat personal information and anonymously processed information appropriately as follows.

  1. The Company considers personal information as an important property of individual and recognizes its appropriate protection as a serious responsibility, and will comply with the Act on the Protection of Personal Information, the relevant laws and regulations, the guidelines, the company’s internal rules, and other norms to fulfill this responsibility.
  2. The Company will specify the purpose of use of personal information, and will not use personal information by exceeding the extent necessary for the accomplishment of the purpose of use of personal information unless there is a prior consent of the principal or it is permitted by laws and regulations.
  3. The Company will acquire personal information to the extent necessary for the accomplishment of the purpose of use of it, in an appropriate and lawful manner.
  4. The Company will take appropriate action to manage personal information with necessary security control measures so that leakage, loss, or the like, regarding personal information may not occur. In addition, we will conduct trainings and appropriate supervisions to employees about the handling of personal information.
  5. The Company will exercise a necessary and appropriate supervision for the entrusted person when entrusting the handling of personal data.
  6. The Company will review the privacy policy as necessary in accordance with changes of laws and regulations and will strive to improve the privacy policy continuously.
  7. The Company will strive to respond appropriately and promptly when there is a request for disclosure, correction etc., and utilization cease etc., regarding the retained personal data.
  8. The Company will strive to respond sincerely and promptly to inquiries, comments and complaints, regarding the handling of personal information.
  9. The Company will take necessary action and manage anonymously processed information appropriately according to the handling of personal information.

<Handling of Personal Information>

1. The Purpose of Use of Personal Information

The Company will use personal information to the extent necessary for the accomplishment of the following purposes.

  1. We will acquire addresses, names, telephone numbers, E-mail addresses, and call center records and will retain them as personal data in order to provide information and services in response to queries and requests from customers, to conduct market surveys to offer better products and services, and, as necessary, to comply with the requirements of laws, regulations, and industry rules.
  2. In accordance with standard business practice, we will acquire information appropriately, including the names and positions of relevant individuals, telephone numbers, E-mail addresses, CVs of representatives etc. and will retain this information as personal data to manage contact information etc. of public offices, relevant industry organizations, business partners, etc., which we are required to contact in the daily business operations.
  3. For security purposes, we will acquire information, including images of visitors to our offices recorded by security cameras, and retain this information as personal data.
  4. For the purpose of employment management, we will acquire personal information of executives and employees and retain it as personal data. In addition, we will acquire personal information of applicants for recruiting and internship and retain it as personal data.

Regarding the above personal information, we may acquire personal information separately by clearly specifying of its usage and obtaining principal’s consent as necessary, and retain it as personal data. In addition to that, we may also acquire personal information as ancillary information and retain it as personal data through research on the eligibility of distributors, entrusted persons, and business partners etc. which is necessary for ordinary business, as well as research on news, business environment and economies by various media and the like.

2. Appropriate Acquisition of Personal Information

The Company will acquire personal information to the extent necessary for our business. Moreover, the Company will not acquire, use, or provide the information related to sensitive information, which is special care-required personal information and information concerning membership of any labor union, family origin, registered domiciled, medical or health care records, and sexual activities, to any third parties, unless the information is open to public by principals, government organization, local governments and any other persons prescribed by laws and regulations.

3. Appropriate Management of Personal Information

The Company will manage appropriately with necessary security control measures to prevent leakage, loss, manipulation, illegal access or the like with regard to personal information.

4. Disclosures and Provisions of Personal Data to Third Parties

The Company will not disclose or provide any personal data without prior consent of the principal to third parties, except for the cases below and the cases permitted by laws and regulations.

  1. Cases in which a principal has provided consent.
  2. Cases based on laws and regulations.
  3. Cases in which there is need to protect human life, body or fortune, and when it is difficult to obtain a principal’s consent.
  4. Cases in which there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain a principal's consent.
  5. Cases in which there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a principal's consent would interfere with the performance of the said affairs.
  6. Cases in which personal data (excluding sensitive information) that could be identified as the said principal is blocked to third-parties from a request by the said principal and noticed the requirements to the said principal in advance or placed in a situation where such information can be easily obtained and has been notified to the Personal Information Protection Commission.

5. Disclosures and Provision of Personal Data to a Third Party in a Foreign Country

The company, except for the cases below and cases permitted by laws and regulation, will not disclose or provide personal data to a third-party (excluding a person establishing a system conforming to standards prescribed by laws and regulations as necessary for continuously taking action equivalent to the one that a personal information handling business operator shall take concerning the handling of personal data) in a foreign country (excluding those prescribed by laws and regulations as a foreign country establishing a personal information protection system recognized to have equivalent standards to that in Japan in regard to the protection of an individual's rights and interests), without obtaining a principal's consent in advance.

  1. Cases in which a principal has provided consent.
  2. Cases based on laws and regulations.
  3. Cases in which there is need to protect human life, body or fortune, and when it is difficult to obtain a principal’s consent.
  4. Cases in which there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain a principal's consent.
  5. Cases in which there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a principal's consent would interfere with the performance of the said affairs.

6. Entrustment of Handling of Personal Data

The Company, in order to facilitate the tasks necessary for handling personal data use, may entrust a whole or a part of the business and provide the necessary personal data to the a trustee. In the case of entrustment, the Company will exercise necessary and appropriate supervision over the trustee, including oversight to subcontractors.

7. Joint Use of Personal Data

The Company may use personal data of customers jointly within the following scope.

  1. The categories of personal data jointly used The customer’s name, address, date of birth, contact information such as telephone number or e-mail address, occupation, information regarding the customer’s transaction needs, contents of the transaction, information regarding the customer’s transaction such as a balance on deposit.
  2. The scope of joint users Daiwa Securities Group Inc. which is the parent company of Daiwa Asset Management Co. Ltd. and its consolidated subsidiaries.
  3. The utilization purposes of joint users The business management and the internal control of Daiwa Securities Group Inc..
  4. A person responsible for the management of the personal data Daiwa Asset Management Co. Ltd..

8. Disclosure, Correction etc., Utilization Cease etc. of Personal Data

When a person or an agent for the person asks the disclosure, correction etc., utilization cease etc. (the “disclosure etc.”) regarding retained personal data by a written request, the Company, after confirming that the request is from the principal itself, will respond in writing within a reasonable period and a reasonable scope except in cases where disclosure etc. is not required based on laws and regulations.

<Handling of Anonymously Processed Information>

1. Production etc. of Anonymously Processed Information

The Company will not produce anonymously processed information.

2. Provision of anonymously processed information to a third party

When the Company provides the anonymously processed information to a third party, the Company will disclose in advance the categories of information and its providing method, and state to a third party explicitly that the information being provided is anonymously processed information.

3. Identifying act of anonymously processed information

When using anonymously processed information, the Company will not acquire information on processing method or collate with other information in order to identify the principal concerned with personal information.

< Inquires, Comments, Complaints, etc. about Handling of Personal Information and Anonymously Processed Information>

1. Our contact information

The Company will strive to respond sincerely and promptly to inquiries, comments, complaints, regarding the handling of personal information and anonymously processed information. For an inquiry about the handling of personal information and the anonymously processed information, please contact the following.

【Contact information for an inquiry etc.】
Daiwa Asset Management Co. Ltd., Call Center
Phone: +81-3-5555-0521
Business Hours: Weekdays 9:00am-5:00pm (local time)

2. Accredited personal information protection organization

The Company is a member of The Investment Trusts Association, Japan, and Japan Investment Advisers Association that are accredited personal information protection organizations approved by the Personal Information Protection Commission. Investor Enquiry Section of The Investment Trusts Association, Japan, and Grievance Desk of the Japan Investment Advisers Association will receive complaints and provide consultation with respect to its members' handling of personal information and anonymously processed information.

【Contact information for complaints and consultations】
The Investment Trusts Association, Japan
Investor Enquiry Section
Phone +81-3-5614-8440

Japan Investment Advisers Association
Grievance Desk
Phone +81-3-3663-0505

You must read the following information before proceeding. When you have read the information set out below, please click on the "I confirm that I have read the important notice" link at the bottom of the page to acknowledge that you have read the information and to continue.

Important Notice

The information on this website is provided by Daiwa Asset Management Co. Ltd. in order to introduce the Company and to provide general information on investment trusts and investment in general. The contents are not, and should not be construed as, an offer or the solicitation of an offer to buy or sell any securities or financial products. Daiwa Asset Management accepts no liability whatsoever for any direct or consequential loss arising from any use of such content.

The information on this website is based upon sources believed to be reliable but its accuracy, completeness or correctness is not guaranteed.

The contents, numeric values, figures and any expression of opinion contained herein were based upon the best information in the circumstances prevailing at the time and are subject to change without notice.

The information such as on fund performance provided through this website shows the past track record, and does not indicate nor guarantee future performance.

As the funds mainly invest in equities, bonds and other marketable securities, therefore, in general, the base price of funds will fluctuate (with foreign exchange risk if invested in foreign currency dominated assets), responding to domestic and international market situations. Investors take responsibility for all the profits or losses arising from investment in fund products. Investors should read and confirm the contents of the fund prospectus before purchasing any fund.

The information on this website is made only for the use of people domiciled in Japan, and is not made for persons of any other countries.

The information on this website is not made for any person's use in the United Kingdom. Also, the information is not, and should not be construed as, an offer or solicitation of an offer to buy or sell any securities or financial products to any person in the United Kingdom.

The information on this website is not made for any person's use in the United States. Also, the information is not, and should not be construed as, an offer or solicitation of an offer to buy or sell any securities or financial products to any person in the United States.

Copyright of the contents contained on this website is owned by Daiwa Asset Management. Electronic or mechanical duplication, reference, reproduction or forwarding of the contents is prohibited for any purpose without the prior permission of Daiwa Asset Management.

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Legal Disclaimer Statement

You must read the following information before proceeding, and please click on the "I confirm that I have read the Legal Disclaimer Statement" link at the bottom of the page to continue.

①Important Notice

This website aims at providing certain information in relation to a Luxembourg Undertakings for Collective Investment in Transferable Securities ("UCITS") managed by Daiwa Asset Management (Singapore) Ltd. ("Daiwa AM Singapore"). The creation, hosting, maintenance and update of this website has been outsourced by Daiwa Global Funds to Daiwa Asset Management Co. Ltd. ("Daiwa AM Tokyo") which has issued and approved the information contained therein. The UCITS products referred to on this website are not distributed by Daiwa AM Tokyo.

The content of this website is dedicated to inform existing investors in the UCITS and is not, and shall not be construed as, an offer or the solicitation of an offer to buy, sell, or distribute the shares UCITS or any securities or financial products in the jurisdictions from which this website is accessed or any other jurisdiction. Also, nothing in this website constitutes accounting, legal, regulatory, tax or other advice in relation to the UCITS or any other securities or financial products Investors should seek independent accounting, legal, regulatory, tax or other advices based on their personal, financial situation and objectives.

②INTENDED AUDIENCE

This website is directed to existing investors in the UCITS and is not directed at any other persons, in particular, any persons in any jurisdiction where for any reasons (including regulatory reasons) the publication or availability of this website or the information contained therein is prohibited.

This website provides information about UCITS products, aimed at institutional investors within the meaning of Luxembourg laws and regulations1 and does not constitute investment recommendation or advice. The information contained in this website is further not intended to be distributed or passed on, directly or indirectly, to any other class of persons and no other person should rely or act upon it. In particular, the information provided by this website is not aimed at "retail investor" within the meaning of Luxembourg laws and regulations2.

The information on this website is not made for any person's use in the United States of America. Also, the information is not, and should not be construed as, an offer or solicitation of an offer to buy or sell share of the UCITS or any other securities or financial products to any person in the United States of America.

③Liability

The information contained in this website is aiming at providing general information on the UCITS based upon sources believed to be reliable, but its accuracy, completeness or correctness is not guaranteed, and it does not indicate or guarantee any future performance.
This website further contains links allowing users to access other websites which are not administered or controlled by Daiwa AM Tokyo and for which Daiwa AM Tokyo cannot be held liable in any way whatsoever. Any links on this website to other Internet locations are provided for convenience only and are at your own risk. The content, accuracy, opinions expressed and further links provided at any of such locations are not monitored or endorsed by us and we accept no responsibility for them.
Daiwa AM Tokyo further makes no warranties, representations or claims of any kind concerning the statements made on this website or on the fact that the information made available on this website is up to date.

④COPYRIGHT NOTICE

Copyright of the contents contained on this website is owned by Daiwa AM Tokyo unless otherwise stated. Electronic or mechanical duplication, reference, reproduction or forwarding of the contents is prohibited for any purpose without the prior permission of Daiwa AM Tokyo.

Daiwa Asset Management Co. Ltd 
Website Data Protection Policy

Daiwa Asset Management Co. Ltd (“Daiwa AM Tokyo” or “we”), acting as a data controller, collects personal data to operate effectively and provide you with the best services. This is why we are highly committed to safeguarding your privacy. In accordance with the provisions of the EU Regulation n°2016/679 of 27 April on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (the “GDPR”) and the law of 1st August 2018 on the organization of the National Commission for Data Protection and the general regime on data protection, as may be amended or replaced (collectively hereinafter the “Data Protection Laws”), we have developed a Data Protection Policy that covers how we may collect, use, share, protect and keep information about you as well as the rights to which you are entitled in this respect.

Please take a moment to familiarize yourself with our privacy practices.

WHICH PERSONAL DATA DO WE USE ABOUT YOU?


We collect the following categories of personal data, which are directly provided by you when you visit our website or when you require further information about our product and/or services:

  • Name
  • Contact details (such as the mail address and the email address)
  • IP address;
  • Localization data;
  • any personal data the processing of which is required for the purpose of fulfilling the services required by you.

It is to be noted that you have choices about the personal data we collect. When you are asked to provide personal data, you may decline. If you choose not to provide personal data that is necessary to provide our services, we may not be able to deliver the services (i.e. giving you the information you asked).

HOW AND WHY DO WE PROCESS YOUR PERSONAL DATA?


Personal Data supplied by you are processed in order to ensure the good functioning of the website and for our legitimate interests. Such Personal Data shall, in particular, be processed for the purposes of:

  1. providing the correct information to you regarding your investment in our Luxembourg’s Fund
  2. internal administration and analysis
  3. the development of the business relationship with you.

Our “legitimate interests” referred to above are:

  • the processing purpose described in points “2.” and “3.”
  • the exercise of our business in accordance with reasonable market standards.

In specific circumstances, we may request your consent to process your personal data:

  • To perform processing for purposes other than the one for which you initially provide us with your data.

WHO DO WE DISCLOSE OR SHARE YOUR PERSONAL DATA WITH?


We may share with and disclose your personal data to:

  • Companies of our group for the above purposes only.

In principle, your personal data is not shared with or disclosed to third parties located outside the European Economic Area. If a transfer of your data is envisaged with an entity that is not located in the European Economic Area and that is not recognized by the European Commission as offering an adequate level of protection, we will take all appropriate safeguards, before the transfer, such as enter into standard protection clauses adopted by the European Commission, in order to protect your personal data adequately.

HOW LONG WE WILL KEEP YOUR PERSONAL INFORMATION?


We will only retain your personal data:

  • For as long as it is necessary for the purpose or purposes for which it was intended to be processed;
  • For as long as required or permitted by law taking into consideration the statutory limitation period.

WHAT ARE YOUR RIGHTS?


We respect your rights to determine how your personal information is used and seek to ensure that you are able to exercise your rights at any time to the extent required by the law and the regulation. These rights include:

  • Right of access to your personal data

    You have the right to ask us for accessing to your personal data that we process and to ask for a copy of such personal data.

  • Right to rectification

    You have the right ask us to update your personal data and to request the rectification of inaccurate personal data.

  • Right to erasure (‘right to be forgotten’) and the right to restriction

    If at any time you decide you do not want us to retain any personal data we collected from you, you may request we delete your data. You may also request the restriction of the processing of your personal data such as where the accuracy of the data is being contested or the processing is unlawful. We will take reasonable measures to comply with your request to the extent required by applicable law and regulation.

  • Right to data portability

    You have the right to have your personal data transmitted directly from us to another controller only when you have asked us to do so and have consented to such sharing, and when technically feasible.

  • Right to object

    You may object to the processing of your personal data on grounds relating to your particular situation and particularly when the processing is based on our legitimate interests.
    You have also the right to object to the processing of your personal data for direct marketing purpose.

  • Right to withdraw your consent

    You have the right to withdraw your consent at any time, when the processing is based on your consent.

  • Right to lodge a complaint with the CNPD (National Commission for Data Protection)

    You have the right to lodge a complaint with the CNPD, where you believe that your data is being processed in a way that does not comply with the applicable law and regulation, by filling in an online complaint form available on the CNPD Website or by letter addressed to Commission Nationale pour la Protection des Données, Service des Réclamations, 1, avenue du Rock'n'Roll, L-4361 Esch-sur-Alzette. When you reside in another EU member state, you have the right to lodge your complaint with your local data protection supervisory authority.

1 Please note that the definition of institutional investor may not be a definition that is provided by the regulator of the home state where this website is being accessed.

2 Please note that the definition of retail investor may not be a definition that is provided by the regulator of the home state where this website is being accessed.

HOW CAN YOU EXERCISE YOUR RIGHTS?


All the above listed rights may be exercised by writing to us at the following address:

GranTokyo North Tower 9-1,
Marunouchi 1-chome, Chiyoda-ku,
Tokyo 100-6753, Japan

CONTACT US

For further information on Daiwa AM Tokyo’s handling of Personal Data, please contact:

customer_relations@daiwa-am.co.jp

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