Privacy Policy

Sumitomo Mitsui DS Asset Management Company, Limited

Sumitomo Mitsui DS Asset Management Company, Limited (hereinafter, "we," "us," "our," or "our company") recognizes the protection of personal information held by our company as an important social responsibility that we should bear. When handling personal information, we will comply with the "Act on the Protection of Personal Information (hereinafter, "the Personal Information Protection Act")," and strive to appropriately protect and use personal information and manage it properly and safely based on the provisions set forth in this Policy.

The name of our representative is listed under "About Us" on our company website.

1. Declaration of policy

We will comply with the matters stipulated in each item below in addition to relevant laws and regulations, etc. for the proper protection and use of personal information and personal data, and we will strive to manage personal information and personal data properly and safely in order to respond appropriately to the development of information technology:

  1. We will never use your personal information other than for its purpose of use, except when have obtained your prior consent or as otherwise provided for in the Personal Information Protection Act, etc.;
  2. We will properly manage personal information, and strive to prevent its loss, destruction, falsification, leakage, etc.;
  3. We will handle complaints regarding the handling of personal information appropriately; and
  4. We will strive to continuously improve our personal information policy.

2. Purpose of use of personal information

We will use your personal information within the scope necessary to achieve the following business and purposes of use and not for any other purpose. These purposes of use will be posted on our company website. And if we will notify you of the purpose of use directly, such notice shall be issued in writing.

(1) Business content

Investment management business, investment advisory business, type II financial instruments business and related businesses, and other businesses that we can operate and related businesses (including any businesses that we will be permitted to operate in the future).

(2) Purpose of use

  1. To accept, propose, and solicit applications to conclude investment advisory agreements and discretionary investment agreements (hereinafter, “Investment Advisory Agreement, etc.”);
  2. To accept, propose, and solicit sales and offerings of securities, etc.;
  3. To accept, propose, and solicit applications to use our products and services, including opening a trading account;
  4. To verify your identity or the identity of your agent, and to confirm eligibility, etc. to use our products and services;
  5. For the administration and management of ongoing transactions, including contacting you regarding your Investment Advisory Agreement, etc. and investment trust products, etc.;
  6. To determine the validity of providing our products and services, including judgment in light of the principle of suitability, etc.;
  7. To exercise rights and fulfill obligations under contracts we have concluded with you and based on laws and regulations, such as reporting investment results and contract asset balance, etc.;
  8. In order to properly perform entrusted business when entrusted to manage all or part of personal information related to unitholders by an investment corporation as a general administrative agent;
  9. For research and development of our products and services through market research, data analysis, questionnaires, etc.;
  10. To send invitations to our seminars, to offer congratulations and condolences, to send greeting cards, and to provide various information, etc.;
  11. To analyze your browsing history, etc. that we have acquired through our services, and to provide information or distribute advertisements tailored to your preferences; and
  12. To otherwise facilitate the appropriate and smooth execution of transactions with you.

3. Appropriate acquisition of personal information

  1. We will acquire your personal information by proper and lawful means within the scope necessary to achieve the purpose of use specified in 2. above.
  2. We will acquire your personal information when you apply for and use our products and services, when you answer questionnaires, etc., when you submit documents, when you input information through our website, and verbally, etc. In addition, we may record phone calls in order to accurately understand the contents of your inquiries, etc. and improve our services going forward.

4. Provision of personal information to third parties

We will never provide your personal information to third parties without obtaining your prior consent, except as provided for in the Personal Information Protection Act.

5. Handling of sensitive information

We will not acquire or use your sensitive information (information about your race, creed, social status, etc. specified in Article 5, Paragraph 1 of the Guidelines for Protection of Personal Information in the Finance Sector (Personal Information Protection Commission and Financial Services Agency Notification No. 1 of 2017)) or provide such information to any third party, except as provided for in the aforementioned Guidelines.

6. Management of personal information

We strive to take reasonable steps to keep personal information in our possession accurate and up to date. In addition, we implement security control measures required by laws and regulations, etc., and take all possible measures to prevent unauthorized access to personal information and loss, destruction, falsification, leakage, etc. of personal information. In the unlikely event that an incident related to personal information occurs, we will respond promptly and appropriately.

The security control measures that we take include the following items:

  1. Development of internal discipline
    We have formulated handling methods and have established personnel in charge with defined duties, etc. at each stage of acquisition, use, provision, and disposal of personal data, and we conduct reviews, etc. as necessary to maintain internal discipline.
  2. Development of organizational structure
    We have established a personal data manager as the general manager for the handling of personal data at our company, and we have a system in place whereby an employee who has become aware of a leak, etc. will take measures such as promptly reporting or contacting the responsible department or the personal data manager.
  3. Regular inspection and audit
    We take measures such as conducting regular self-inspection of our handling of personal data, audits by other departments, and audits by external parties as necessary.
  4. Employee education
    In addition to providing employees with training on personal information protection and information security, we have incorporated matters related to employees’ duty of confidentiality into our employment regulations and are taking measures such as making these matters known within our company.
  5. Prevention of unauthorized access, etc.
    We have implemented measures in our offices to control the entry and exit of employees, prevent theft or loss of electronic media and documents, etc., and we have introduced a system to protect against unauthorized access, etc. from the outside.
  6. Understand the external environment
    When handling personal data in a foreign country, we implement security control measures after acquiring an understanding of the personal information protection system in that country.

7. Entrusting the handling of personal information

We may entrust the handling of personal information to a third party within the scope necessary to achieve the purpose of use specified in 2. above. In this case, we will select a contractor according to our prescribed standards, and will manage the subcontractor as necessary and appropriate by concluding a contract on the handling of personal information with the subcontractor, etc. in order to ensure security control measures are taken in accordance with our Privacy Policy and regulations, etc.

8. Request for disclosure, etc.

  1. If you have requested notification of the purpose of use, disclosure, correction, etc. (correction, addition, deletion) or cessation of use, etc. (cessation of use, erasure) of your retained personal data, or provision of records relating to our transfer of your retained personal data to third parties, then we will respond to such request based on the provisions of the Personal Information Protection Act after first verifying your identity. Please click the link below for more detail on how to make such a request.
    Procedure for Requesting Disclosure, etc. of Retained Personal Data

  2. If we provide your personal data to a third party in a foreign country, we will provide you with reference information based on the provisions of the Personal Information Protection Act when obtaining your consent; however, if we cannot identify the third party to whom we will provide your data at the time we obtain your consent, then we will subsequently provide you with such information at your request if we have been able to identify the third party after the fact. Please click the link below for further details on how to make such a request.
    Procedure for Requesting Disclosure, etc. of Retained Personal Data

  3. If we entrust the handling of your personal data to a third party in a foreign country, we will take necessary measures to ensure that the third party continues to implement appropriate security control measures. In addition, we will provide you with information about such measures we are taking at your request. Please click the link below for further details on how to make such a request.
    Procedure for Requesting Disclosure, etc. of Retained Personal Data

9. Continual improvement of handling of personal information and personal data

We will regularly review our handling of personal information and personal data, and will continue to make improvements to better protect personal information. In addition, if there is a change to the content of this Privacy Policy, we will promptly publicize it by posting it on our company website, etc.

10. Feedback, questions, and complaints

If you have any feedback or questions about our handling of personal information and personal data or our security control measures, please contact us at the details listed below. And please direct any complaints about our handling of personal information and personal data to the same contact.

Sumitomo Mitsui DS Asset Management Company, Limited

Risk Management Department

Contact for inquiries regarding personal information protection

Toranomon Hills Business Tower 26F, 1-17-1 Toranomon, Minato-ku, Tokyo 105-6426

TEL: +81-3-6205-0200

Business hours: 9:00 a.m.–5:00 p.m. (excluding Saturdays, Sundays, public holidays, and company holidays)

Organizations that we belong to

We are a member of the Japan Investment Advisers Association, the Investment Trusts Association, Japan, and the Type II Financial Instruments Firms Association. Each association accepts complaints and consultations regarding the handling of personal information by association members.

  • Japan Investment Advisers Association complaints desk: TEL +81-3-3663-0505
  • The Investment Trusts Association, Japan investor consultation service: TEL +81-3-5614-8440
  • Type II Financial Instruments Firms Association secretariat: TEL +81-3-6910-3980