danshari | Official Website of Hideko Yamashita

GLOBAL PRIVACY POLICY

Direct Publishing, Inc., located at 13F Osaka International Building, 2-3-13 Azuchimachi, Chuo-ku, Osaka-shi, Osaka, and each legal entity listed at the URL below (hereinafter, the legal entities listed at the URL below, centered around Direct Publishing, Inc., shall be collectively referred to as the “Group,” and each legal entity constituting the Group shall be referred to as a “Group Company”) shall process the personal information of the Group Companies’ customers, officers and employees of business partners, and applicants for employment (hereinafter collectively referred to as the “Data Subject” unless otherwise specified) in compliance with the applicable personal information protection laws and regulations of each country, as set forth below.

List of Group Companies: https://www.d-publishing.jp/ourgroup/

This Global Privacy Policy applies to Data Subjects residing outside of Japan. For Data Subjects residing within Japan, please refer to the Japanese version of the Privacy Policy (Privacy Policy – Direct Publishing, Inc.).

Depending on the region where the Group Company processing the Data Subject's personal information is located and the region where the Data Subject resides or is located, country-specific appendices may apply in addition to this Global Privacy Policy; therefore, please also refer to the country-specific appendices. In the event of any conflict between this Global Privacy Policy and a country-specific appendix, the country-specific appendix shall prevail.

1. Categories of Personal Information Subject to Processing

The Group Companies process the following personal information and other personal information acquired by the Group Companies in connection with their business activities (if required under applicable laws and regulations, such information shall be acquired after separately notifying the Data Subject).

(1) Personal Information Concerning Customers of Group Companies’ Services The Group Companies process the following personal information concerning customers who use the services provided by the Group Companies (hereinafter referred to as the “Group Services”; the Group Services include websites and applications related to such services (collectively referred to as the “Group Companies’ Websites, Etc.”) and responses to inquiries regarding the Group Services; the same shall apply hereinafter).

  • Registration Information: Name, username, email address, address, country of residence, date of birth, password, phone number, language used, and payment method.
  • Service Information: Usage history of the Services by customers who used the Services, payment history, and other personal information acquired by the Company regarding the Services (if required under applicable laws and regulations, the Company shall acquire such information after separately notifying the customer).
  • Cookies and Other Online Identifiers of Customers Accessing the Company’s Website: Access tokens and refresh tokens of customers who used the Services; IP addresses, provider information, device information, web browser information, internet connection information, location information, referrer information, advertising identifiers (such as Advertising ID), viewed URLs and browsing history (timestamp information), information regarding the use of services, behavioral history information, server log information, etc., of customers who accessed the Company’s website; and Attributes (age, gender, interest categories, affinity categories, in-market segments, etc. For detailed information on interest categories, affinity categories, and in-market segments, please see About Demographic and Interest Categories - Analytics Help (google.com)).
  • Purchase Information: Information related to product purchases, such as the date and time of advertisement clicks, date and time of product purchases, order numbers, ASP (Application Service Provider) names, credit card information (last four digits of the credit card number), and device IDs of individuals who purchased Group Company products via Group Company advertisements or affiliate advertisements.
  • Questionnaire Response Information: Respondent's name, email address, facial photograph, and content of questionnaire responses.
  • Inquiry Information: Name, email address, inquiry items, and inquiry content of customers who made inquiries to the Company.
  • Inferred Information: Information inferring the customer’s preferences and interests from personal information related to the customer.
  • In addition to the above information, the Company may acquire information voluntarily provided to the Company by the customer when using the Services.

(2) Personal Information Concerning Officers and Employees, etc., of the Group Companies’ Business Partners

  • Contact Information and Other Information Concerning Officers and Employees, etc.: Name, job title, date of birth, place of birth, address, zip code, phone number, mobile phone number, FAX number, email address, final academic background, hobbies, prefecture of residence, marital status, and family composition of the officers and employees, etc., themselves.
  • Information Concerning Affiliation: Name and location of the company, department, branch, or factory to which the officers and employees, etc., belong.
  • Business Negotiation History and Transaction Content Information: Content of products and services contracted, content of business negotiations, content of inquiries and estimates, etc.
  • Other Information: Other personal information necessary for the purposes described in Section 2 of this Global Privacy Policy.

(3) Personal Information Concerning Applicants for the Group Companies’ Recruitment Activities

  • Identity and Contact Information: Name, address, contact information such as phone number, email address, and FAX number, ID card number, passport number, date of birth, gender, age, nationality, signature, academic background, work history, facial photograph, reason for application, and other information stated in application documents for recruitment activities (including those by electromagnetic means) or submitted as annexed materials to such documents, information on electronic systems or online, information captured by cameras, and information on social media.
  • Cookies and Other Online Identifiers of Applicants Accessing the Group Companies’ Websites, Etc.: Access tokens and refresh tokens of applicants used for applying to the Company's recruitment activities; IP addresses, provider information, device information, and web browser information of applicants who accessed the Company’s website; and Attributes (age, gender, interest categories, affinity categories, in-market segments, etc.).
  • Other Information: Other personal information necessary for the purposes described in Section 2 of this Global Privacy Policy.

2. Purposes of Processing

The Group Companies process personal information for the following purposes and other purposes permitted under applicable laws and regulations. Furthermore, the Group Companies may de-identify or aggregate personal information and may disclose such de-identified or aggregated information.

(1) Personal Information Concerning Customers of Group Companies’ Services

  • Registration for Group Services and identity verification at the time of using Group Services.
  • Management of customers of Group Services.
  • Provision, operation, and maintenance of Group Services.
  • Billing of consideration if such consideration arises in Group Services.
  • Prevention of and response to fraudulent acts, etc., related to Group Services.
  • Provision and introduction of after-sales services related to Group Services.
  • Implementation of questionnaires and campaigns related to Group Services.
  • Guidance for information sessions and seminars by the Group Companies and sending of materials.
  • Sending of email newsletters (limited to those who have applied to receive email newsletters).
  • Sending of culture books (limited to those who have applied to receive culture books).
  • To judge the appropriateness of providing products and services (including investment advisory products for customers in Japan) in light of laws, regulations, and the Group's internal rules.
  • Investigation and analysis of marketing data and consideration and implementation of marketing measures.
  • Implementation of provision, solicitation, advertising, and other marketing of products and services of the Group Companies or partner companies according to interests and concerns based on analysis of attributes, browsing history, behavioral history, etc., of customers of Group Services.
  • Telephone calls from Group Companies for sales purposes.
  • To analyze the attributes of customers who accessed the Group Companies’ Websites, Etc., and utilize such analysis for personalization and improvement of the Group Companies’ websites.
  • Improvement of Group Services and planning and development of new services.
  • Posting of questionnaire results on the Group Companies’ homepages or sales pages.
  • Maintenance of the Group Companies’ Websites, Etc., investigation of server failures, and repair of defects.
  • Responding to inquiries and contacting the Data Subject.
  • Responding to disputes, litigation, etc., and other compliance with the Company's legal obligations.
  • To serve as a reference for new service development, new content development, and production.
  • For purposes to which the customer has consented and purposes separately disclosed to the customer at the time of collection.
  • For record-keeping by the Group Companies.
  • For employee training.
  • For detection, prevention, and response to unauthorized use of credit cards.
  • For ensuring the security of Group Services and the Group Companies’ Websites, Etc., including prevention of cyber-attacks.
  • For provision to third parties by the methods described in this Global Privacy Policy.
  • Other operations necessary for the provision of the Services and services incidental thereto.
  • Other purposes permitted under applicable laws and regulations.

(2) Personal Information Concerning Officers and Employees, etc., of the Group Companies’ Business Partners

  • For conclusion and performance of contracts and payment of remuneration.
  • For responding to inquiries and contacting the Data Subject.
  • Other purposes recognized under applicable laws and regulations.

(3) Personal Information Concerning Applicants for the Group Companies’ Recruitment Activities

  • For contacting recruitment applicants, screening for employment, and notification of recruitment.
  • Other purposes recognized under applicable laws and regulations.

3. Legal Basis for Processing, etc.

The Group Companies process the Data Subject's personal information in accordance with applicable personal information protection regulations. For the legal basis for processing in each country, please refer to the country-specific appendices.

The provision of the Data Subject's personal information may be mandatory for reasons such as being a statutory requirement, a contractual requirement, or a requirement necessary to conclude a contract. Specifically, cases where the provision of personal information is required are as follows:

(1) Personal Information Concerning Customers of Group Companies’ Services

  • The provision of Registration Information is a requirement necessary when concluding a contract with the Group Companies and is also mandated as a contractual requirement. If the Data Subject does not provide this information, the Group Companies may not be able to register the Data Subject as a member and may not be able to provide Group Services to the Data Subject.
  • The provision of Service Information and strictly necessary online identifiers is mandated as a contractual requirement. If the Data Subject does not provide such personal information, the Group Companies may not be able to provide Group Services to the Data Subject.
  • The provision of Inquiry Information and Purchase Information is mandated as a contractual requirement. If the Data Subject does not provide such personal information, the Group Companies may not be able to provide answers or appropriate product guidance to the Data Subject.
  • In other cases, if the Data Subject does not provide personal information despite it being a necessary requirement, the Group Companies may not be able to provide Group Services (including the Group Companies’ Websites, Etc.) to the Data Subject.

(2) Personal Information Concerning Officers and Employees, etc., of the Group Companies’ Business Partners

The provision of contact information and other information concerning officers and employees, etc., information concerning affiliation, business negotiation history, transaction content information, and other information may be a requirement necessary to conduct transactions with the Group Companies. If the Data Subject does not provide this information, the Group Companies may not be able to conduct transactions with the Data Subject.

(3) Personal Information Concerning Applicants for the Group Companies’ Recruitment Activities

The provision of identity and contact information, strictly necessary online identifiers, and other information may be a requirement necessary for recruitment application. If the Data Subject does not provide this information, they may not be able to participate in the Group Companies’ recruitment activities or the recruitment screening may not be possible.

4. Retention Period of Personal Information

To determine the appropriate retention period for personal information, the Group Companies consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which the Group Companies process the personal information and whether those purposes can be achieved through other means, and applicable legal requirements. When the personal information of the Data Subject collected by the Group Companies is no longer necessary, the Group Companies will delete or anonymize the personal information, or if that is not possible (for example, if the personal information is stored in backup archives), the Group Companies will store the Data Subject's personal information securely until deletion becomes possible and ensure that no further processing of the personal information is performed thereafter.

5. Sources of Personal Information

The Group Companies receive personal information of the Data Subject directly from the Data Subject or automatically acquire it via cookies and other online identifiers. However, in the following cases, the Company may collect the Data Subject's personal information indirectly from third parties:

(1) Personal Information Concerning Customers of Group Companies’ Services

  • Other Group Companies (Information described in “8. Joint Use of Personal Information under the Japanese Act on the Protection of Personal Information” below is provided).
  • Providers of website usage analysis services such as Google LLC (Cookies, IP addresses, provider information, device information, web browser information, user behavior, referrers, and attributes are provided).
  • Providers of product management systems such as Amazon Seller Central.
  • Advertising operators for affiliate advertisements, etc.

(*) Acquisition of Personally Referable Information under the Japanese Act on the Protection of Personal Information The Group Companies may use advertising operators for affiliate advertisements, etc. (hereinafter referred to as “Advertising Operators”). The Group Companies acquire personally referable information related to product purchases, such as advertisement click date and time, product purchase date and time, order number, ASP (Application Service Provider) name, and device ID, from Advertising Operators regarding individuals who purchased Group Company products via Group Company advertisements or affiliate advertisements, and may use this information for investigation of advertisements and affiliate advertisements and investigation of and response to fraudulent acts after linking it with personal information held by the Group Companies.

(2) Personal Information Concerning Applicants for the Group Companies’ Recruitment Activities

  • When receiving introductions of applicants from recruitment agencies or temporary staffing companies.
  • When acquiring from employment-related agents or job/career change sites, etc.
  • When acquiring from public information such as official gazettes, websites, and commercially available books.
  • When otherwise lawfully acquiring from third parties.

6. Sharing and Disclosure of Personal Information

The Group Companies will share and disclose the personal information described in “1. Categories of Personal Information Subject to Processing” above to third parties in the following cases to fulfill the purposes described in “2. Purposes of Processing” above. For cases of third-party provision based on joint use under the Japanese Act on the Protection of Personal Information, please refer to “8. Joint Use of Personal Information under the Japanese Act on the Protection of Personal Information” below. In addition to the following cases, information will be shared or disclosed to third parties when necessary for legal compliance, etc. (*1) or in other cases (*2).

**(1) Legal Compliance, etc.* The Group Companies may be required to disclose the Data Subject's personal information to public institutions and government authorities due to the laws within or outside the Data Subject's country of residence and/or requests from such institutions and authorities. The Group Companies may also disclose the Data Subject's personal information if disclosure is necessary or appropriate for law enforcement or other matters of public importance. The Group Companies may also disclose personal information if disclosure is reasonably necessary to protect the Group Companies' rights, pursue available remedies, enforce the Group Companies' terms of use, investigate fraud, or protect the Group Companies' operations or the Data Subject.

**(2) Others* In addition, the Group Companies may share the Data Subject's personal information with third parties in the following cases:

  • When personal information is shared in connection with an actual or potential sale of the company, merger, acquisition, reorganization, or other transfer of all or part of the assets (including as part of bankruptcy proceedings).
  • When it is necessary for the protection of the life, body, or property of the Group Companies or a third party, and it is difficult to obtain the Data Subject's consent.
  • When there is the Data Subject's consent.
  • When otherwise permitted under applicable laws and regulations.

(1) Personal Information Concerning Customers of Group Companies’ Services

〇 Sharing and Disclosure to Group Companies

The Group Companies may share or disclose personal information to other Group Companies. (Please refer to “8. Joint Use of Personal Information under the Japanese Act on the Protection of Personal Information” below.)

〇 Sharing and Disclosure to Online Service Providers and SNS Providers

To deliver information regarding the Group Companies’ products and services according to the Data Subject’s hobbies and preferences and to post advertisements on the web using various targeting advertisements, the Group Companies will, upon request from the recipient, provide personal information and personally referable information under Japanese law of customers held by the Group Companies—such as name, email address, phone number, zip code, address, IP address, browser information, cookie information, numbers assigned by the Group Companies to individual users, and purchase information—to online service providers and SNS providers such as Google, Yahoo, LINE, Facebook, X (formerly Twitter), Taboola, Instagram, YouTube, and Logicad. These recipients include providers located in the United States, the State of California, and the State of New York. For information on the personal information protection systems of each country and region for which information provision is required under the Japanese Act on the Protection of Personal Information, please see the links below. The recipients will handle the customer's personal information in compliance with applicable laws. In addition, Group Companies will provide personal information and personally referable information under Japanese law using the API (Application Programming Interface) or interface of each provider.

o United States (Federal), California, New York

〇 Sharing with Partner Companies

When the Data Subject registers a credit card within the Group Companies' web pages or apps or uses one for payment, the Group Companies will provide the Data Subject's personal information held by the Group Companies—such as attribute information (name, email address, phone number, zip code, address, numbers assigned by the Group Companies to individual users, etc.), information regarding transactions (type and content of transaction, date and time of transaction, number of transactions, transaction amount, etc.), and the customer's device information (IP address, browser information, cookie information, etc.)—to the issuer of the credit card (hereinafter referred to as the “Card Issuer”), GMO Payment Gateway, Inc., and its contractors for the purpose of detecting, preventing, and responding to unauthorized use. If the Card Issuer is located in a foreign country, the information provided above may be transferred to the country where the Card Issuer is located. Since the Group Companies cannot identify the Card Issuer being used or the country where such Card Issuer is located from the information collected from the Data Subject, the Group Companies cannot provide the Data Subject with the name of the foreign country where the recipient is located, information on the personal information protection system of said country, or information on the personal information protection measures of the Card Issuer. Information on the personal information protection systems in various countries is posted on the website of the Personal Information Protection Commission (https://www.ppc.go.jp/). If the Data Subject does not agree to this item, they cannot apply to purchase Group Company products using a credit card. Furthermore, as a result of screening, the Group Companies may refuse an application for purchase from the Data Subject or may cancel a contract even after it has been concluded.

〇 Sharing with Processors (Service Providers)

  • Providers of website usage analysis services such as Google LLC.
  • Cloud service providers employed by external contractors for customer support such as Google LLC.
  • Provision to external investigation agencies, etc., for the purpose of investigation, detection, prevention, and response to unauthorized use, etc., in the Services.
  • Delivery companies such as Funai Soken Supply Chain Consulting Co., Ltd.
  • Other contractors of the Company.

7. Transfer of Personal Information Overseas

As a result of the sharing and disclosure described above, the Data Subject's personal information may be transferred to the following countries:

  • United States
  • Japan

In such cases, the Group Companies will implement appropriate protection measures required by the personal information protection regulations of each country. For protection measures in each country, please refer to the country-specific appendices. For information to be provided to the Data Subject when providing personal information to a third party in a foreign country under the Japanese Act on the Protection of Personal Information, please see “6. Sharing and Disclosure of Personal Information” above.

8. Joint Use of Personal Information under the Japanese Act on the Protection of Personal Information

The Group Companies jointly use personal information regarding customers of the Group Companies’ services with specific parties as follows, based on joint use under the Japanese Act on the Protection of Personal Information. However, if it is necessary to obtain the Data Subject's consent under personal information protection laws other than the Japanese Act on the Protection of Personal Information, such consent shall be obtained.

(1) Personal Information Concerning Customers of Group Companies’ Services

  • Items of Personal Information to be Jointly Used: Name, email address, phone number, zip code, address, IP address, browser information, cookie information, numbers assigned by the Group Companies to individual users; information regarding contract details and product purchase history such as purchase date, purchase product name, purchase amount, and number of payments; product reviews, questionnaire response content; and other information for which the customer has consented to joint use.
  • Scope of Joint Users: Group Companies (For the Group, please refer here [https://www.d-publishing.jp/ourgroup/]).
  • Purpose of Use: Purposes of use described in 2.(1) above.
  • Party Responsible for Management: Direct Publishing, Inc. (For the address and name of the representative, please refer here [https://www.d-publishing.jp/company/]).

(2) Personal Information Concerning Officers and Employees, etc., of the Group Companies’ Business Partners

  • Items of Personal Information to be Jointly Used: Name, job title, date of birth, place of birth, address, zip code, phone number, mobile phone number, FAX number, email address, final academic background, hobbies, prefecture of residence, marital status, family composition; name and location of the company, department, branch, or factory to which the officers and employees, etc., belong; content of products and services contracted, content of business negotiations, content of inquiries and estimates, etc.; and other information for which the officers and employees, etc., of the Group Companies’ business partners have consented to joint use.
  • Scope of Joint Users: Group Companies (For the Group, please refer here).
  • Purpose of Use: Purposes of use described in 2.(2) above.
  • Party Responsible for Management: Direct Publishing, Inc. (For the address and name of the representative, please refer here).

(3) Personal Information Concerning Applicants for the Group Companies’ Recruitment Activities

  • Items of Personal Information to be Jointly Used: Name, address, contact information such as phone number, email address, and FAX number, ID card number, passport number, date of birth, gender, age, nationality, signature, academic background, work history, facial photograph, reason for application, and other information stated in application documents for recruitment activities (including those by electromagnetic means) or submitted as annexed materials to such documents, information on electronic systems or online, information captured by cameras, and information on social media; access tokens and refresh tokens of applicants used for applying to recruitment activities, IP addresses, provider information, device information, and web browser information of applicants who accessed the Company’s website, and Attributes (age, gender, interest categories, affinity categories, in-market segments, etc.); and other information for which the recruitment applicants have consented to joint use.
  • Scope of Joint Users: Group Companies (For the Group, please refer here).
  • Purpose of Use: Purposes of use described in 2.(3) above.
  • Party Responsible for Management: Direct Publishing, Inc. (For the address and name of the representative, please refer here).

9. Security Management Measures

The Group Companies will take necessary and appropriate measures for the management of the Data Subject's personal information, such as prevention of leakage, loss, or damage. In addition, when handling personal information in a foreign country, the Group Companies will take necessary and appropriate measures for the security management of personal information after understanding the external environment, such as the systems regarding the protection of personal information in said foreign country.

10. Cookies and Similar Technologies

When the Data Subject accesses the Group websites and has enabled cookies, etc. (including tracking technologies such as Flash cookies and web beacons, and other technologies; hereinafter referred to as “Cookies, Etc.”), the Group Companies may automatically acquire information regarding the PC, mobile phone terminal, tablet, or other information communication terminal used by the Data Subject. When the Group Companies acquire such information, the Group Companies will handle such information as personal information.

If you do not wish to use Cookies, Etc., it is also possible to set the use of cookies to be enabled or disabled from the browser settings of the terminal. For details, please check the help page, etc., of the browser you are using.

Please note that if the use of cookies is restricted, some obstacles may occur in the use of the Group websites.

〇 Regarding Analytical Cookies The Group Companies may cooperate with third parties that collect data regarding the Data Subject's use of the Group websites over a long period. For example, Google Analytics may be used for analysis and marketing purposes. If you use “DIRECT ACADEMY” or “DIRECT Reads” operated by Direct Publishing, Inc., please see the “External Transmission Policy.”

Google Analytics collects information about the Data Subject using Cookies, Etc. For information on how Google Analytics collects and uses information when the Data Subject uses the Company’s website, please see here (https://policies.google.com/technologies/partner-sites).

Data Subjects who wish to stop the use of Google Analytics should access here (https://tools.google.com/dlpage/gaoptout).

11. Links to Third-Party Websites, Etc.

The Group Companies’ Websites, Etc., may provide the Data Subject with links to third-party websites or apps other than the Group Companies. The Group Companies do not control how such websites or apps handle personal information, and such websites or apps are outside the scope of this Global Privacy Policy. The Data Subject needs to check the privacy policies of other websites and apps they use and know how such websites or apps handle personal information.

12. Data Subject's Rights

The Group Companies respect the rights held by the Data Subject under the personal information protection regulations applicable to the Data Subject. Under the Japanese Act on the Protection of Personal Information, the Data Subject may request disclosure, correction, addition, deletion of content, suspension of use, erasure, suspension of third-party provision of retained personal data under the same Act, and disclosure of records of third-party provision. If you exercise your rights based on the Japanese Act on the Protection of Personal Information, please see “Procedures for Requests for Disclosure, Etc.”

In addition to this, rights may be granted to the Data Subject by the personal information protection regulations of each applicable country. For rights granted in each country, please check the country-specific appendices. If the Data Subject exercises rights under the personal information protection laws of countries other than Japan, please contact the contact point described in “13. Contact Information” below.

13. Contact Information

Complaints, consultations, and other inquiries regarding the handling of personal information held by the Group Companies are accepted at the following contact points.

  • Direct Publishing, Inc. and Keiei Kagaku Shuppan, Inc. Customer Consultation Desk (Direct Publishing, Inc. is also in charge of the consultation desk for customers of Keiei Kagaku Shuppan, Inc.) 13F Osaka International Building, 2-3-13 Azuchimachi, Chuo-ku, Osaka-shi, 541-0052 TEL: 06-6268-0850 / FAX: 06-6268-0851 Personal Information Protection Manager: Management Department Manager (TEL: 06-6268-0850) Monday to Friday (excluding holidays and New Year's holidays) 10:00 to 17:00
  • Wealth On, Inc. Customer Consultation Desk 23F Osaka International Building, 2-3-13 Azuchimachi, Chuo-ku, Osaka-shi, 541-0052 TEL: 06-6271-1188 / FAX: 06-4708-7169 Personal Information Protection Manager: Management Department Manager (TEL: 06-6271-1188) Monday to Friday (excluding holidays and New Year's holidays) 10:00 to 17:00
  • APJ Media LLC Customer Consultation Desk 9F Sanko Osaka Honmachi Building, 2-3-8 Honmachi, Chuo-ku, Osaka-shi, 541-0053 TEL: 06-4705-7201 / FAX: 06-4705-7202 Personal Information Protection Manager: Management Department Manager (TEL: 06-4705-7201) Monday to Friday (excluding holidays and New Year's holidays) 10:00 to 16:00
  • Ivy Fitness, Inc. Customer Consultation Desk 13F Osaka International Building, 2-3-13 Azuchimachi, Chuo-ku, Osaka-shi, 541-0052 TEL: 06-6264-8689 Personal Information Protection Manager: Management Department Manager (TEL: 06-6264-8689) Monday to Friday (excluding holidays and New Year's holidays) 10:00 to 17:00

14. Name of the certified personal information protection organization to which Wealth On, Inc. and APJ Media LLC belong and its consultation desk:

Wealth On, Inc. and APJ Media LLC are member companies of the Investment Management Association of Japan (IMAJ), a certified personal information protection organization certified by the Financial Services Agency of Japan. The Association accepts complaints and consultations regarding the handling of personal information of member companies.

Investment Management Association of Japan, Member Audit Department, Investor Consultation Room
7th Floor, Tokyo Stock Exchange Building, 1-5-8 Nihonbashi Kayabacho, Chuo-ku, Tokyo 103-0025
TEL: 03-6821-8756
Monday to Friday (excluding national holidays and New Year's holidays) 9:00–11:30, 12:30–17:00

15. Changes to this Global Privacy Policy

When the Group Companies change this Global Privacy Policy (including country-specific appendices), they may change or add all or part of this Global Privacy Policy by notifying the Data Subject via posting on the Group Companies’ Websites, Etc., distribution of emails to the Data Subject, or other methods deemed appropriate by the Group Companies (if there is a method required by applicable laws and regulations, such method shall be followed). If there are other necessary procedures under applicable personal information protection regulations, such procedures shall be taken.

Data Subjects are encouraged to visit this page regularly to check for updates. You can find out when this Global Privacy Policy (including country-specific appendices) was last updated by checking the “Last Updated” date.

Effective Date: April 10, 2026