Privacy Policy

Privacy Policy

April 2, 2018
In light of the importance of the protection of personal information and specific personal information including individual numbers (referred to collectively hereinafter as "Personal Information") in the financial sector, including the investment management and investment trust management businesses, and in recognition of its social responsibility as an asset management business to manage personal information securely, Bayview Asset Management Co., Ltd., ("BVAM") hereby establishes the following Privacy Policy. BVAM will ensure that all members of management and personnel understand and honor the Policy and will strive to protect Personal Information appropriately in accordance with this Policy.

Ken Yagi
President & Chief Executive Officer
Bayview Asset Management Co., Ltd.

1. Collection and use of Personal Information

BVAM conducts investment management work, investment advice and agency work, type-two financial instrument transaction work, and work that is incidental to such work. BVAM may ask you to provide the following personal information. (Examples of Personal Information for which provision will be requested) Postal code, address, name, telephone number, and e-mail address Birthdate, age, gender, and family composition Information about the workplace, work content, income, and status of possessed assets In addition, individual numbers and personally identifying information will be used only within the scope that has been stipulated in laws and regulations.

2. Safety and Management Measures for Personal Information

In order to maintain the accuracy of Personal Information and manage it securely, take suitable precautions to protect the information from improper access or theft and prevent incidents, such as loss of, damage to, manipulation of, or disclosure by error of such information, BVAM will implement the necessary and appropriate safety and management measures and appropriately manage personal data.Please note that in order to fulfill the purposes of use of Personal Information, Personal Information may be provided to a party that has been consigned work. In such a case, provision of data will be limited to the minimum amount of information that is necessary in accordance with the content of consignment, and an agreement related to handling of personal data will be concluded with the consigned party and appropriate management will be conducted so that Personal Information will not be used for matters other than the consigned work.

3. Compliance with laws, regulations, and standards concerning Personal Information

BVAM strives to comply with laws and regulations concerning personal information, guidelines about laws related to the protection of personal information, and industry standards on voluntary controls.

4. Organization and structure to protect Personal Information

BVAM appoints an officer in charge of the protection of personal information and an officer responsible for administration of handling of specific personal information, including individual numbers and administers Personal Information appropriately. BVAM implements a training program on its measures for the protection and appropriate management of Personal Information for its management and other personnel to enforce the proper handling of Personal Information in day-to-day business operations.

5. Adoption of the Personal Information Protection Compliance Program

In order to enforce this Privacy Policy, BVAM adopts the Personal Information Protection Compliance Program that includes this Privacy Policy, Personal Information Protection Rules, Personally Identifying Information Protection Rules, and related company bylaws and rules and strives to maintain and improve them continually.

6. Disclosure, correction, and suspension of use of Personal Information

In the event that a request has been made for something such as notification of purposes of use, disclosure, correction, etc. (correction, addition, deletion), or suspension of use, etc., (suspension of use, deletion) for personal data that is possessed, BVAM will confirm that the person who made the request is the person to whom the information belongs and then handle the matter based on the stipulations of the Act on the Protection of Personal Information. For specific procedures for such things, please make an inquiry to the Personal Information Inquiry Desk stated below.

7. Providing Personal Information etc. to third parties

BVAM will not disclose Personal Information to third parties without the prior consent of the individual concerned, except as required by laws or regulations. BVAM will not disclose specific personal information including individual numbers to third parties except as required by laws or regulations.

For any queries or complaints, please contact below.

Personal Information Inquiry Desk
Bayview Asset Management Co., Ltd.
Personal Information Inquiry Desk c/o the Compliance Office. (Office hours 9:00 to 17:00)
Bancho-House, 29-1 Ichibancho, Chiyoda-ku, Tokyo 102-0082 Japan
Tel +813-5210-3342

Please note that we are a member of the following two associations authorized by the government.

The name of the authorized association and its inquiry desk
Japan Investment Advisers Association (Inquiry and Claim Desk +813-3663-0505)
The Investment Trusts Association, Japan (Investors Inquiry Desk +813-5614-8440)

Purposes of use of Personal Information

  1. For promotion and sales activities related to BVAM's investment advising, discretionary investment, investment trust, and other products and services and to provide information on related services.
  2. For the promotion, sales, and services related to the financial instruments offered by BVAM or its affiliated companies and partners and to provide information on affiliated companies and partners.
  3. To judge the suitability of products and services to be offered in light of their conformity to client needs and other principles.
  4. To verify the identity of clients and/or their proxies.
  5. To report to clients their portfolio balances and the result of investment management.
  6. To carry out operational procedures related to transactions between clients and counterparties.
  7. To fulfill exercise rights and fulfill responsibilities imposed by contracts with clients and by laws and regulations.
  8. For research and development on financial instruments and services, through means including market research, data analysis, and surveys.
  9. In cases such as when entrusted by other businesses with all or part of the processing of personal information, to perform such entrusted duties appropriately.
  10. To maintain proper and smooth transactions between clients and counterparties.
  11. To conduct screening procedures and pre-employment procedures for people who have applied for employment
    * For information about the handling of the Personal Information of people who have applied for employment, please make an inquiry to the "Personal Information Inquiry Desk" stated above.
  12. For management of the personnel, work, and welfare matters of board members, employees, and people who used to be board members or employees (hereinafter referred to as the "Board Members and Employees, et al.")
    * For information about the handling of the Personal Information of the Board Members and Employees, et al., please make an inquiry to the Personal Information Inquiry Desk stated above.

Purposes of use of specific personal information including individual number

  1. Administrative procedures for preparation of payment statements related to transactions with clients
  2. Administrative procedures related to preparation of income tax withholding statements, dependent deduction (change) applications, and other documents
  3. Administrative procedures related to individual residents' tax
  4. Administrative procedures for notices, applications, and invoices related to employment insurance
  5. Administrative procedures for notices, applications, and invoices related to health insurance and employees' pension insurance
  6. Administrative procedures for notices, applications, and invoices related to Type III insured persons under the National Pension system
  7. Other administrative procedures related to individual numbers as established by laws and regulations.