When handling personal information and specific personal information (hereinafter collectively referred to as “Personal Information”), A.P. Asset Management Co., Ltd. (hereinafter referred to as “the Company”) shall endeavor to properly handle, manage, and protect Personal Information as it abides by with the relevant laws, guidelines, etc., and shall establish and comply with the following privacy policy (hereinafter referred to as “this Policy”).

1. Basic policy on the handling of Personal Information

The Company shall comply with the following basic policy based on the understanding that Personal Information is an important information asset and that the Company does not have only the legal obligation but also the social responsibility to properly acquire, manage, and use the Personal Information it has acquired to the extent necessary for its business.

1. (1)
   The Company shall acquire Personal Information by proper and legal means to the extent necessary to achieve the purpose of use specified by the Company. The Company will not acquire Personal Information by falsehood, by other illegal means, or in any manner that would unfairly infringe on the interests of the person concerned. Additionally, the Company will not acquire special care-required Personal Information without the consent of the person concerned, except as provided by laws.
2. (2)
   The Company shall always keep and manage the personal data it has acquired in an accurate and up-to-date state, and shall endeavor to delete the personal data concerned without delay when it is no longer necessary. Additionally, to prevent in advance unauthorized access to, leakage of, loss of, damage to, or falsification of personal data, the Company will provide thorough employee training and take necessary and proper measures to safely manage personal data.
3. (3)
   The Company will not handle Personal Information it has acquired beyond the extent necessary to achieve the purposes specified by the Company, except in cases when the Company has obtained prior consent from the person concerned or in exceptional cases permitted by laws and the like.
4. (4)
   If the Company receives a complaint or the like about the handling of Personal Information, the Company will endeavor to respond properly and promptly within a reasonable period. For inquiries regarding the handling of Personal Information, please contact the relevant parties using the details stated in section 8.

2. Purpose of use of Personal Information

The Company will handle Personal Information only to the extent necessary to achieve the purpose of use, except in cases where the Company has obtained prior consent from the person concerned or in exceptional cases permitted by laws and the like. Additionally, when acquiring directly from the person concerned Personal Information stated in a contract or other document, the Company will clearly state the purpose of use to the person concerned in advance. The Company may, however, omit the specification of the purpose of use if it is permitted by laws, and the purpose of the use is clear from the circumstances of acquisition, and the like.

3. Provision of personal data to a third party

The Company does not provide personal data it has acquired to third parties, except in the following cases:

1. ①
   Consent of the person concerned has been obtained
2. ②
   When required by laws
3. ③
   When it is needed in order to protect the life, body, or asset of a person and it is difficult to obtain consent from the person concerned.
4. ④
   When it is particularly necessary for the improvement of public health or to promote the sound growth of children, and it is difficult to obtain consent from the person concerned.
5. ⑤
   When it is necessary to cooperate with a government organization or a local government, or a person entrusted by such an organization in executing the affairs prescribed by laws, and obtaining the consent of the person concerned is likely to impede the execution of the said affairs.

4. Acquisition of Sensitive Information and the like

Except as provided in the Guidelines for Protection of Personal Information in the Finance Sector, the Company will not acquire, use, or provide to a third party in the finance sector any special care-required Personal Information or information related to (excluding information that is disclosed by the person concerned, a government organization, a local government, or a person listed in the Act on the Protection of Personal Information or the Ordinance for Enforcement of the Act on the Protection of Personal Information, or distinct exterior information that is obtained by observing or photographing the person concerned) labor union membership, birth, legal domicile, health and medical care, or sex life (excluding special care-required Personal Information).

5. Supervision of outsourcing and contractors

When the Company outsources all or part of the handling of personal data, the Company will take proper measures to protect personal data as per laws and the like, and supervise the outsourced party as necessary and appropriate to ensure the outsourced personal data is managed safely.

6. Procedures of the disclosure and the like of possessed personal data

If the Company receives, through a designated request form accompanied by a document that verifies the identity of the person concerned, a request for the disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to a third party (hereinafter referred to as “disclose and the like”), or a request for the notification of the purpose of use of possessed personal data as per the Act on the Protection of Personal Information, the Company will respond appropriately without delay as per laws and the like, as soon as the request is confirmed to have been made by the person concerned or the legitimate representative. Possessed personal data shall be disclosed in writing or by any other method to which the person concerned consents. However, in certain cases, such as when there is a risk of harming the life, body, assets, or other rights and interests of the person concerned or a third party, the Company may not be able to respond to the request for disclosure and the like or the request for notification of the purpose of use. In such cases, the Company will notify the person or the representative of the reason without delay. For more information on the procedures, please contact the relevant parties using the details stated in section 8. Additionally, customers may be asked to pay a fixed fee for the disclosure of personal data.

7. Continuous improvement

The contents of this Policy shall be applied from its date of publication on this website. The Company will continuously review the contents of this Policy, revise it appropriately as necessary, and endeavor to improve the management of Personal Information and the like. If the contents of this Policy are revised, it will also be immediately posted on the Company’s website.

8. Contacts for inquiries

For inquiries regarding the handling of Personal Information, requests for disclosure and the like of possessed personal data, requests for notification of the purpose of use, and complaints, please contact the relevant parties at the following details.

Revised: April 27, 2020

Our company's Basic Stance Regarding Solicitation to Customers

We endeavor to conduct appropriate solicitation and provide explanations with a comprehensive understanding of our customers' knowledge, investment experience, current assets, and investment purpose (purpose of executing agreements for the sale of the financial products in question).

Methods and Hours of Solicitation to Customers

Our company endeavors to take sufficient care regarding times, places, and methods of solicitation to customers to avoid inconveniencing them.
We endeavor to solicit to customers at times and places and with methods that are convenient to our customers.

Ensuring Reasonable Solicitation

We endeavor to provide accurate information to avoid causing misunderstanding on the part of the customer.
We work to ensure that customers correctly understand the important points of the "Law Regarding the Sale of Financial Products, Etc.".
In order for the customer to make investment decisions that are appropriate for them, we endeavor to provide sufficient and accurate explanations regarding the product details, risks, etc.
When soliciting and providing information, we always consider the benefit of the customer and comply with all related laws and regulations.
In order to conduct reasonable solicitation, we take serious measures toward creating in-house systems as well as education and training.

Display of Advertisements, etc. in Accordance with the Financial Instruments and Exchange Act

The products this company deals in or the services this company provides are extensive and diverse, and regarding related fees, remuneration, and various expenses (hereinafter referred to as "fees, etc.") we must individually determine the necessary types, amounts, etc. of fees, etc. after taking into consideration various circumstances such as the class of product or service provided by the company and the contract period, and therefore we are unable to display the amounts or calculation methods of these fees, etc. in advance. Regarding fees, etc. for individual products or services by this company, please check with the responsible staff at the company.

Financial products handled by this company such as "real estate trust beneficiary rights" and "silent investment interests" are subject to loss of assets due to fluctuations in real estate prices, rent, etc. as well as fluctuations in interest rates, etc. Furthermore, there is no guarantee of principal or profits. The risk of the value of marketable securities invested in cutting into the investment principal is borne by the customer. Regarding the risks associated with individual products, please examine and confirm the contract details which this company will send you in writing in advance.

A.P. Asset Management Co., Ltd.
Financial Instruments Business
Director-General of the Kanto Finance Bureau (Financial Instruments) No. 2785
Type 2 Financial Instruments Business, investment advice, agency
Member of the Japan Investment Advisers Association
Member of the Type 2 Financial Instruments Firms Association,

Cutoff date for the professional investors system

Regarding the "cutoff date" for the professional investors system under the Financial Instruments and Exchange Act, this Company makes the following proclamation in accordance with the provisions of Article 34-3 Clause 2 and Article 34-4 Clause 6 of the Financial Instruments and Exchange Act.

According to the Financial Instruments and Exchange Act, customers are classified as "professional investors" and "general investors", but there are cases where a customer can transition from a "professional investor" to a "general investor" or from a "general investor" to a "professional investor" via an application by the customer through designated procedures.
The "cutoff date" for transitioning from a general investor to a professional investor is as follows.

this Company's Measures for Processing Complaints

For complaints, etc. regarding this Company's business, please inquire with the following contact point.

Measures for Processing Complains and Resolving Disputes Relating to the Financial Instruments Business

In addition to resolving complaints through the aforementioned in-house contact point, we also work to process complaints and resolve disputes through the organizations listed below. To utilize these organizations, please contact them as shown below

The Company has adopted all seven principles of the Principles of Customer-Centric Business Operations, published by the Financial Services Agency on March 30, 2017, and has established the following policies on customer-centric business operations.

1. Formulation and publication of policies on customer-centric business operations

1. 1.
   The Company shall formulate and publish the policies that have been taken to achieve customer-centric business operations and shall regularly publish the policy status on its website and the like.
2. 2.
   The Company shall regularly review these policies in order to achieve better business operations.

2. The pursuit of the best interests of customers

1. 1.
   As a member of the A.P. Capital Group, based on the management philosophy of “driving the business forward with trust as the foundation”, the Company shall develop a business that is highly particular about the quality of services and products and continue its efforts to maximize the clients’ investment returns through high-quality asset management services.
2. ２.
   The Company shall conduct business with a strong sense of ethics, integrity, and fairness, as well as in compliance with laws. Furthermore, it shall endeavor to establish a corporate culture of customer-centric business operations.

3. Appropriate management of conflicts of interest

1. 1.
   The Company shall accurately grasp the possibility of conflicts of interest with customers and appropriately manage them as per laws, internal rules, etc.
2. ２.
   The Company shall establish decision-making procedures, standards, etc. to prevent customers’ interests from being harmed during transactions that may have a conflict of interest, as per internal rules.

4. Clarification of fees and the like

1. Taking into account relevant laws and the like, the Company shall set the amount of remuneration or the method of calculating the amount of remuneration after consulting with every customer, based on the type and attributes of the target of trade, trade practices in the market, etc.

5. Provision of important information in an easy-to-understand manner

1. 1.
   The Company shall provide information tailored to the customers and the characteristics of the products after it considers the customer’s trading experience and financial knowledge.
2. ２.
   For private investment corporations, the Company will make appropriate disclosures on the website and other platforms that are exclusive to the investor who is from the investment corporation, as per laws, internal rules, etc.

6. Provision of services suitable to customers

1. To strive for the best interests of customers, the Company shall understand the purposes, needs, etc. of the customers’ trade, and endeavor to provide the customers with suitable services.

7. Appropriate motivational framework and the like for employees

1. By conducting regular and ongoing compliance training and the like for all executives, as a trader in financial instruments, the Company shall strive to be thorough with the compliance, maintain and improve the governance system, and continue to promote the above policies 2 to 6.

The status related to this policy

Established: April 27, 2020