Mitsubishi Jisho Investment Advisors, Inc. (MJIA) recognizes the importance of personal information as well as its social responsibility to protect it. MJIA will work to properly handle personal information in line with the privacy policy set out below.

1. 1．Legal compliance

   MJIA is a "business operator handling personal information" as defined in the Act on the Protection of Personal Information. As such, the company shall abide by laws and regulations governing the protection of personal information, guidelines issued by the competent authorities, and this privacy policy. The company shall ensure that personal information is protected and properly handled.

2. 2．Clarification of purpose of use

   When it obtains personal information, MJIA will be as specific as possible about its purpose, and the information obtained shall be limited to what is needed to achieve that purpose. Also, where the purpose changes, the changed purpose shall, when viewed from the perspective of the original purpose, not exceed what the subject of the information would anticipate on the basis of generally accepted social norms.
   

3. 3．Proper obtaining of information

   MJIA shall use legal and fair means to obtain personal information.

4. 4．Restrictions on purpose of use

   Personal information obtained by MJIA shall be limited to what is necessary for the achievement of its purpose. The company shall handle information beyond the scope of its purpose only where it has obtained prior consent from the subject of the information. However, these restrictions shall not apply in cases where: (a) a law or regulation provides otherwise; (b) it is necessary in order to protect a person’s life, body, or property (including the property of a juristic person) and it is deemed to be difficult to obtain the consent of the subject of the information; or (c) the Act on the Protection of Personal Information otherwise allows that the information be handled.

5. 5．Ensuring accuracy

   MJIA shall make every reasonable effort to ensure that, within the scope of what is necessary for the achievement of its purposes, retained personal data is accurate and up to date. MJIA will strive to delete the personal data as soon as its use is no longer necessary.

6. 6．Security control measures

   1. (1) Internal security control measures

      In order to prevent the personal data (including personal information that MJIA has acquired or is about to acquire, including information that MJIA plans to treat as personal data; the same shall apply hereafter in this article) it handles from being leaked, lost, or damaged, or to achieve some other purpose related to security control for personal data, MJIA shall establish necessary and appropriate security control measures that take into account risks stemming from: (a) the extent to which the rights and interests of the subject of the information would be prejudiced in the event such personal data were leaked, lost, or damaged; (b) the nature of operations; (c) the way personal information is handled; and (d) the medium on which the personal data is recorded.

   2. (2) Supervision of employees

      To implement security control for personal data, MJIA shall establish appropriate internal controls. For employees who handle personal data, MJIA shall carry out necessary and appropriate monitoring, taking into account: (a) the extent to which the rights and interests of the subject of the information would be prejudiced in the event such personal data were leaked, lost, or damaged; (b) the nature of operations; and (c) the way personal data is handled.

   3. (3) Monitoring service providers

      There may be times when MJIA outsources the handling of personal data in order to achieve the purpose for which the data is used. In such a case, in order to implement security control for personal data, MJIA shall carry out necessary and appropriate monitoring, taking into account: (a) the extent to which the rights and interests of the subject of the information would be prejudiced in the event such personal data were leaked, lost, or damaged; (b) the nature of operations; and (c) the way personal data is handled.

   4. (4) Comprehending the external environment

      When it handles personal data in a foreign country, MJIA will regularly collect information on and acquire knowledge of the personal information protection systems of the country involved and take appropriate security control measures.

7. 7．Restrictions on provision of personal data to third parties

   Before providing personal data to a third party (including those in a foreign country), MJIA will obtain prior consent from the subject of the data. However, this restriction shall not apply in cases where: (a) a law or regulation provides otherwise; (b) it is necessary in order to protect a person’s life, body, or property (including the property of a juristic person) and it is deemed to be difficult to obtain the consent of the subject of the data; or (c) the Act on the Protection of Personal Information otherwise allows provision of the data to third parties.
   In addition, when it provides personal data to a third party in a foreign country, MJIA will provide the information stipulated in the Act on the Protection of Personal Information after the fact at the request of the individual in accordance with the Act on the Protection of Personal Information.

8. 8．Response to complaints, etc.

   MJIA respects the individual’s ownership of personal information. When a query or complaint is received regarding the handling of personal information, MJIA will investigate to determine the facts, and within a reasonable time period will provide an appropriate and timely response.

9. 9．How to submit a query or complaint

   1. (1) Information window

      To submit a query or complaint regarding the handling of personal information, contact MJIA by telephone, fax, or letter. The company’s contact information is as follows:

      Mitsubishi Jisho Investment Advisors, Inc.
      Officer for Personal Information Disclosure or Other Requests
      Human Resources and General Affairs Department
      6-5, Marunouchi 1-chome, Chiyoda-ku, Tokyo 100-0005
      Phone: +81-3-3218-0031 (Main number) Fax: +81-3-3218-0035

   2. (2) Certified organization for the protection of personal information

      MJIA is a member of the following authorized personal information protection organizations. Both of these organizations accept the submission of queries and complaints regarding the handling by their member firms of personal information.

      The Investment Trusts Association, Investor Consultation Section Phone: +81-3-5614-8440
      Open: Mon. – Fri. (except holidays)
      Japan Investment Advisers Association, Complaints & Consultation Section (officer for personal information) Tel: +81-3-3663-0505
      Open: Mon. – Fri. (except holidays)

10. 10.Further improvement of the personal information protection system

    MJIA will continue reviewing and striving to improve its system for the protection of personal information, including this privacy policy. Also, MJIA may revise this privacy policy in response to amendments to laws and regulations, or as the need otherwise arises.

11. 11.Other

    For more details of such matters as the purposes for use of personal information, procedures connected with the handling of personal information, and the contact window for questions and complaints about the handling of personal information, please refer to "Matters for which the Act on the Protection of Personal Information Requires Public Disclosure" on the MJIA website.

Amended: April 1, 2024.