Personal information protection declaration

Our company has formulated and published a personal information protection declaration as follows as a policy for dealing with customers’ personal information and individual numbers
(hereinafter referred to as “personal information, etc.”).

Basic policy (legal compliance)

Our company complies with the relevant laws and regulations regarding the protection of personal information, the guidelines of the competent minister, the guidelines of certified personal information protection organizations, and this personal information protection declaration.

Regarding acquisition of personal information, etc.

When acquiring personal information, our company specifies the purpose of use as much as possible and acquires it by lawful and fair means.

Purpose of use of personal information, etc.

Our company will use personal information within the scope of the following purposes in our business
(investment management business, type 2 financial instruments business, business related to these, etc.).

To solicit, sell, and operate products handled by our company and provide related services.
To determine whether the products and services provided by our company are appropriate in light of the customer’s financial profile and other factors.
To confirm your identity
To report transaction results, operational reports, etc.
To carry out administrative work related to transactions
To exercise rights and fulfill obligations based on contracts, laws, etc.
To comply with laws, regulations, self-regulatory rules, internal rules, etc.
For various risk assessments related to money laundering and terrorist financing, etc.
For other purposes, to appropriately and smoothly carry out transactions with customers and business partners.

Regarding entrustment of handling of personal information, etc.

Our company may outsource the handling of personal information to a third party. In this case, our company will oblige by contract to ensure appropriate safety management, and will provide necessary and appropriate supervision of the subcontractor.

Regarding provision of personal information, etc. to third parties.

Our company will not use personal information unless we have obtained prior consent from the person concerned, when using personal information for the purpose of use (including when outsourcing work to an outside party), or when required by law. We will not provide it to third parties.

However, the following cases do not constitute provision to a third party as specified above.

When our company entrusts all or part of the handling of personal information to the extent necessary to achieve the purpose of use.When personal information is provided due to business succession due to merger or other reasons.

About joint use of personal information, etc.

We may share your personal information with our group companies and our business partners, depending on the content of the service we provide to you. Please note that even in the case of shared use, our company remains responsible for the management of personal information.

Regarding disclosure and correction of personal information, etc.

When we are requested by a person to disclose personal information held by our company based on the provisions of the Personal Information Protection Act, we will confirm that the request is from the person in question, and then respond to the person in question. We will disclose without delay. However, if disclosure falls under any of the following, we may not disclose all or part of the information, and if we decide not to disclose it, we will notify you to that effect without delay.

When there is a risk of harming the life, body, property, or other rights and interests of the person or a third party.In cases where there is a risk of significant hindrance to the proper implementation of business operations.If it violates laws and regulations.

We strive to ensure that your personal information is always accurate and up-to-date. In addition, in order to prevent the leakage of customers’ personal information, etc., we will implement the necessary and appropriate safety control measures as described below, and will appropriately supervise our officers, employees, and subcontractors.

In addition, our company may be requested by a person to correct, add to, or delete (hereinafter referred to as “correction, etc.”) the personal information held by the company based on the provisions of the Personal Information Protection Act on the grounds that the personal information held by the company is not true. If the request is made by the person in question, we will respond without delay to the extent necessary to achieve the purpose of use, unless special procedures are stipulated by other laws and regulations. We will conduct the necessary investigation, and based on the results, we will make corrections to the personal information and notify the person accordingly. If we decide not to make any corrections, etc., we will notify the person concerned to that effect.

Regarding safety management measures for personal information, etc.

Establishment of personal data handling regulations regarding handling methods, persons in charge and their duties, etc. for each stage of acquisition, use, storage, provision, deletion, disposal, etc.• Entry/exit control, access restrictions, and measures to prevent unauthorized access to our facilities.• Implementation of regular training for employees.• Implementation of regular audits regarding the handling status of personal data.

About personal information protection management system

Our company has the Compliance Department as the department that oversees the handling of personal information, and the Compliance Department as the person in charge of personal information management.

In order to ensure the appropriate handling of customers’ personal information, our company will review this personal information protection declaration from time to time and strive for continuous improvement.

Regarding inquiries regarding personal information, etc.

Our company will strive to promptly and sincerely respond to questions, opinions, complaints, etc. regarding the handling of personal information, etc. If you have any questions, comments, or complaints, please contact the following contact point.

Compliance Department
TEL: 03-5834-3165
Email: compliance@liberta-ip.co.jp

Business days are 9:00-17:00, excluding Saturdays, Sundays, holidays, and year-end and New Year holidays.

In addition, our company is a member of the Japan Investment Advisers Association and the Type II Financial Instruments Firms Association, but the following corporations are also entrusted with the task of resolving complaints by both associations: We accept complaints from customers, so if you wish to use our service, please contact us using the contact information below.
（Specified non-profit organization Securities and Financial Products Mediation Consultation Center）

Address 2-1-1 Kayabacho, Nihonbashi, Chuo-City, Tokyo 103-0025Second Securities Hall
Telephone: 0120-64-5005 (toll-free)
(Monday to Friday / 9:00 to 17:00, excluding Saturdays, Sundays, and holidays)
Month, day, 2024 1-24-9 Taito, Taito-City, Tokyo
Bright Akihabara 7th floor
Liberta Investment Partners Co., Ltd.

© 2024 Liberta Investment Partners Co., Ltd.