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State Street Trust & Banking Co., Ltd.

Privacy Policy

State Street Trust & Banking Co., Ltd. (hereinafter referred to as "the Company"), in performing business operations, will establish the policy regarding appropriate protection and use of personal information and anonymously processed information (collectively as “Personal Information etc.”) and take every measure for such Personal Information Protection etc.

1. Compliance with the relevant laws and regulations
· In handling personal information, the Company will comply with the "Act on the Protection of Personal Information" and other relevant laws and regulations.

2. Acquisition / use of personal information
· The Company will obtain personal information by appropriate methods. In obtaining personal information, the Company will promptly notify the relevant individual or publicize the purpose of use unless otherwise publicized in advance.
· The Company will not obtain, use or provide third parties with any sensitive information except under certain exceptional circumstances, such as requirement by laws and regulations or protection of the person’s life, body or its property, etc. The Company shall not use any of such information that may constitute Special Care or Required Personal Information without consent from an individual as the laws require.
· The Company will not use personal information obtained beyond the extent necessary for achievement of the specified purpose of use, unless prior consent is obtained from the relevant person in advance or unless required otherwise under laws and regulations.

3. Provision of personal information to third parties
· The Company will not provide the acquired personal data to third parties except the following cases; when mandated by laws and ordinances, when necessary to protect life, body or property of a person and it is difficult to obtain the consent of the relevant individual, when entrusting all or part of the personal data within a scope of the purpose of use, and when necessary to cooperate with the execution of legally-defined duties by  central government institutions, local government agencies or their entrusted deputies and obtaining the consent of the relevant Individual would potentially impair execution of said duties.

· Such consent of provision to a third party shall include on a written form the name of a third party the personal data is provided, the purpose of use by the third party and the information to be disclosed.

· Upon provision of personal data to a third party in a foreign country, the Company will obtain consent from the relevant person unless the laws and regulations provide otherwise. Notwithstanding the foregoing, personal data may be used without obtaining consent upon any delegation or joint use between the Company and State Street Corporation (“SSC”), the Company’s parent company and/or its affiliates, if the Company deems the provision suffices Article 24 of the Act. 

4. Notification / publication of purpose of use of personal information
· Upon obtaining personal information, the Company will promptly notify the relevant individual or publicize the purpose of using the personal information unless otherwise clearly stated in advance.
· The details of the purpose of use is stated and publicized as per “Purpose of Use and Joint Use of Personal Information of Clients etc.”.

5. Disclosure, etc. of personal information
· Upon receiving a request from the relevant person for disclosure of his/her retained personal data, unless the disclosure would cause a serious problem with appropriate implementation of the business, the Company will disclose data to such person.
· Upon receiving a request from the relevant person for correction, addition, or deletion of the content of the retained personal data or suspension of use, elimination, etc. of the relevant personal data, the Company will respond to such request by taking appropriate measures in accordance with the Company’s defined procedure without any delay.
· Please refer to the notice posted in our office for the specific procedure for disclosure, etc.

6. Security management of personal data
· In handling personal data, the Company will implement the basic policy and the rules for handling, etc. for security management, establish an organization for implementation, and take necessary and appropriate security management measures in order to prevent leakage, loss, damage, etc., concerning personal data.
· Organizational security measures: The Company assigns a chief personal data security manager for personal data security, implements the rules for handling, and establishes a method to check the management and its status as audit system to prevent leakage.
· Human resources security measures: The Company executes the non-disclosure agreement with its employees, clarifies their roles and responsibilities, trains the management rules to raise awareness and checks all of the human resources management.
· Technical security measures: The Company identifies / authenticates users of the personal data, sets up the management type, controls access, manages access authority, and implements the preventive measures of leakage / damage of the personal data.

7. Outsource the personal data
· When the Company needs to outsource all or any part of handling of the personal data within the scope necessary to achieve the purpose of use, the Company shall conduct necessary and appropriate supervision over the outsource contractors for security management of the personal data.

8. Complaint handling concerning Personal Information etc.
· Upon receiving complaints concerning the handling of Personal Information etc., the Company will address them quickly and appropriately.

9. Contact point for inquiries and complaints
Compliance Department, State Street Trust & Banking Co., Ltd.
Toranomon Hills Mori Tower 25F, 1-23-1 Toranomon, Minato-Ku,  Tokyo 105-6325
Phone No.: 03-4530-7200
Service hours: Monday – Friday (except for national holidays and other bank holidays) 9:00 am – 5:00 pm
· The Company is a member of the Trust Companies Association of Japan, an authorized personal-information protection organization acknowledged under the Personal Information Protection Law. The contact point for complaints and consultation (Trust Consultation Center) of the Trust Companies Association of Japan responds to complaints and consultation regarding handling of personal information by its member companies.

Trust Companies Association of Japan (Contact Point for Trust Consultation)
http://www.shintaku-kyokai.or.jp/
Contact Point for Complaints / Consultation
:
Phone: (03) 6206-3988 or 0120-817335 (toll free number)

10. Efforts for continual improvement
· The Company will review this Privacy Policy periodically and revise as needed in accordance with amendment of the relevant laws and regulations and changes of the organization information security. The Privacy Policy is posted on the Company’s web site. The Company will strive for continual improvement.

Purpose of Use and Joint Use of Personal Information

Purpose of Use of Personal Information

State Street Trust and Banking (hereinafter “the Company”) shall use in the manner stated below personal information of clients or any other individual (“Clients etc.”), which are obtained through business within the following scope and the purposes of use as stipulated under the Personal Information Protection Law (May 30, 2003 Law No. 57).

Business Details
1. Trust business such as money trust, money trust other than money trust, pension trust, and securities trust, etc.
2. Concurrent Business to trust business such as agent services concerning the acquisition/ disposition or borrowing / lending of assets
3. Banking business such as deposit business, exchange business, foreign exchange business, foreign agency business and their accompanying business.
4. Other businesses which  the Company may conduct under the laws, and their accompanying business (including business that may be authorized in the future due to amendment, etc., of the laws and regulations).

Purpose of Use
1. For application and consultation on financial products, trust products and services.
2. For making various proposals regarding financial products, trust products and services.
3. For KYC on individuals pursuant to the Act on Prevention of Transfer of Criminal Proceeds (“Act”), or any other laws and regulations
4. For confirmation of qualifications, etc., for use of financial products, trust products, and services.
5. For administration of continuing business such as administration of expire date on deposit transactions, trust transactions, etc.
6. To conduct operations appropriately when outsourced by other parties, etc. 
7. For execution of rights and duties in accordance with the contracts with the customers or the laws, etc.
8. For research and development of financial products, trust products and services by market research, data analysis and surveys.
9. For judgment on appropriateness related to provision of financial products, trust products and services, in light with principle of suitability, etc.
10. For termination of various transactions and post-administration of termination of transactions.
11. Others, such as for appropriate and smooth execution of transactions/contracts with the customers in the Company’s business (including trust contract, outsourcing contract, etc.).

Notwithstanding the foregoing, pursuant to Personal Information Protection Act and its related laws and regulations along with Ordinance for Enforcement of the Banking Act and other related laws and regulations, the Company shall treat any special non-public information of Clients etc., including, but not limited to, race and ethnicity, faith (religion, ideology and beliefs), family origin and registered domicile, medical care and/ or criminal records with appropriate care including obtaining consents upon acquiring and/ or using of such information.  

Joint Use of Personal Data

The Company may jointly use Personal Data of Customers etc. when it is within the scope of its business, and/or necessary to accomplish the purposes of use as below. Any changes to the manner of the joint use will be notified or made public in advance.

Specific items of personal data of the Customer etc. for joint use
· Name, date of birth, address, or any other contact information including telephone numbers and/or email addresses, information regarding the individual’s place of work (including but not limited to, the name of the working place, department, position, title and contact information including telephone numbers and/or email addresses) 
· For the avoidance of doubt, any Individual Numbers and/or Personal Information that may include Individual Numbers of Employees’, their spouses and their dependent family members collected by the Company via the Employees in accordance to ‘Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure’ shall not be subject to joint use.

Scope of those engaging in Joint Use
Affiliates of State Street Corporation (“SSC”) which is the Company’s parent company through direct or indirect ownership, including but not limited to the following entities (Group Entities): 
· State Street Bank and Trust Company Ltd., Tokyo Branch
· State Street Global Advisors (Japan) Co., Ltd.
· State Street Global Markets (Japan)

Purpose of Joint Use
o For proposal/ guidance or R&D relating to various products and/ or services provided by respective Group Entity.
o To ensure information security management with respect to the Company or SSC and its Group Entities namely granting access to the systems provided by State Street Corporation and its Group Entities.
o For adequate execution of business management of SSC and/ or its Group Entities including management of various risks (including KYC pursuant to the Act, etc.)
o To  respond to legitimate requests from law enforcement agencies and/ or regulatory authorities in which SSC and its respective Global Entities are located
o To facilitate  the Company and/ or SSC and its Group Entities to execute transaction with Clients in an adequate and smooth manner

Name of the Responsible Administrator of the Personal Data
State Street Trust and Banking Co., Ltd.

Procedure regarding requests for disclosure etc. of the retained personal data
The Company shall disclose the retained personal data following the procedure below upon a request by the relevant individual or his/her agent in accordance with laws and regulations.
· Contact Point:Compliance Department, State Street Trust & Banking Co., Ltd.
Toranomon Hills Mori Tower, 1-23-1 Toranomon, Minato-Ku,  Tokyo
· Required Documents :a document having the name, address, phone number and the request details; a personal identity document such as a copy of driving license or passport; a document to confirm the agent’s identity and a power of attorney when a request for disclosure etc. is made by a statutory agent.
· Fees :Free
· Method of Response :The Company shall response by delivering of the relevant document or other methods within a reasonable period upon the request for disclosure etc.

Conflict of Interest Management Basic Policy

State Street Trust and Banking Co., Ltd, in consideration of our social responsibility as at trust bank, has adopted group values that require us to conduct our business with integrity to meet our customers’ expectations and social mandate, which all directors and employees always keep in mind as a standard of conduct.

We have established this Conflict of Interest Management Basic Policy in order to properly conduct our business without unjustly impairing the interests of our customers due to any behavior that constitutes a conflict of interest.

Compliance with Laws and Regulations
We will comply with laws and regulations, government guidelines, and our internal rules, etc., (hereinafter “Laws and Regulations“) regarding conflicts of interest.

Conflict of Interest Management
We will try to prevent our customers’ interests from being unjustly impaired by identifying any transactions that constitute a conflict of interest which may unjustly impair our customers’ interests in our daily operation, and will properly manage conflicts of interest by taking necessary actions to strengthen our customers’ trust.

Maintenance of Internal Rules
We will endeavor to prevent conflicts of interest by maintaining a Rule on Conflict of Interest Management and other internal rules pursuant to applicable laws and regulations regarding conflicts of interest, and by continuously providing training and guidance.

In addition, we will establish the Conflict of Interest Management Control Division and appoint a Chief of Conflict of Interest Management Control in order to control conflicts of interest in a consolidated manner by maintaining the internal system and promoting increased awareness of directors and employees, and collecting information concerning conflicts of interest and confirming and analyzing the status thereof.

Implementation of Internal Audit
We will conduct internal audits of our corporate system for managing conflicts of interest and regularly verify its appropriateness and effectiveness.

Should you have any comments or inquiries on our service in terms of conflicts of interest, please kindly contact a person in charge or call +81-3-4530-7200 (representative).

Opinions and Complaints

Contact Point
State Street Trust and Banking Co., Ltd.
Compliance Division
Phone No: +81-3-4530-7200

The below organizations also accept consultation about trust transactions/banking transactions.

Trust Consultation Center
Trust Consultation Center is operated by the Trust Companies Association of Japan as the contact point for inquiries and complaints regarding trust and accepts demands and complaints about trust business, etc., of a financial institution concurrently operating trust business or a trust company such as a trust bank. Trust Consultation Center is free for use.

For more details, please see the website of the Trust Companies Association of Japan (Trust Consultation Center).
Phone No.:0120-817335 or +81-3-6206-3988
Service days: Monday–Friday (except for national holidays and other bank holidays)
Service hours: 9:00 a.m. – 5:15 p.m.
*The Trust Companies Association of Japan is a designated dispute resolution organization under the Trust Business Act and the Act on Provision, etc. of Trust Business by Financial Institutions.

JBA Customer Relations Center
JBA Relations Center is operated by the Japanese Bankers Association as the contact point for various consultations and inquiries regarding a bank and opinions and complaints to a bank.  Consultation, inquiries, etc., is free.

For more details, please see the website of the Japan Bankers Association.
URL: http://www.zenginkyo.or.jp/adr/
Phone No.: 0570-017109 or +81-3-5252-3772
Service days: Monday – Friday (except for national holidays and other bank holidays)
Service hours: 9:00 a.m. – 5:00 p.m.
*The Japanese Bankers Association is a designated dispute resolution organization under the Banking Act.

Anti-Social Forces

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Important Note:

State Street's action in response to Anti-Money-Laundering (AML) initiatives.

For State Street Trust & Banking clients