Privacy Policies

Show content of Deutsche Securities Inc.

Deutsche Securities Inc. (hereinafter referred to as the “Company”) puts top priority on client trust and complies with all applicable laws and regulations of Japan and other countries for protection of personal information and strives for appropriate handling and protection of personal information of clients entrusted to the Company in accordance with the following Policy.

The terms used in the Privacy Policy shall be in accordance with the following definitions.
  • “Personal Information” means information related to living individuals, which can identify a specific individual by name, date of birth or any other description, etc., contained in such information (including information as will allow easy reference to other information and will thereby enable identification of the specific individual) and information that contains individual identification codes which are defined by the article 2-1 of Personal Information Protection Act (hereinafter referred to as the “PIPA”) .
     
  • “Personal Information Database etc.” means a set of information which includes personal information as set of information structurally organized to enable a computer to be used to retrieve certain personal information from it, or in addition to what is listed in the preceding item by alphabetical order, index code, organized table of contents and etc., a set of information which are structurally organized to be easily retrieved certain personal information even without using computer.
     
  • “Personal Data” means personal information compiled in a Personal Information Database etc. “Individual Number” means the number obtained by converting a resident record code under the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures (hereinafter referred to as the “Numbers Act”), which is designated to identify the person to whom the resident record where said resident record code is stated pertains (including the number, symbol and any other code other than the resident record code, corresponding to the Individual Number and is used in place of the Individual Number) and includes the number of a deceased person who does not fall under “Personal Information.”
     
  • “Specific Personal Information” means Personal Information containing an Individual Number.
     
  • “Specific Personal Information, etc.” means an Individual Number and Specific Personal Information.


1. Procurement of Personal Information

The Company shall obtain Personal Information by lawful and fair manner.
In this regard, for information sources of Personal Information, the Company shall mainly obtain Personal Information, through the application form for opening an account and any other documents and materials submitted by customers. The Company may obtain Personal Information, in relation to transactions with clients and the products and services provided. Further, regarding Personal Information, the Company may obtain additional Personal Information related to clients by obtaining credit records from consumer credit information organizations, etc., depending on the goods and services requested by clients. The Company may also obtain Personal Information through application forms for employment to recruit personnel, placement agencies, our employees, our group companies and any other third parties. In this regard, the Company shall properly obtain Specific Personal Information in accordance with laws and regulations and in compliance with the Numbers Act and shall not share Specific Personal Information among our DB group companies.

In providing financial services to our clients, the Company may obtain Personal Information related to clients through monitoring and any other means (recording of telephone conversations and monitoring of e-mails, etc.) in compliance with applicable laws and regulations. The Company does not routinely or regularly access such information, but the Company may use the information for the purpose of compliance and security.


2. Use of Personal Information

The Company shall use Personal Information within the purpose of use published in advance or notified and/or specified when it is obtained and to the extent necessary to perform the following business authorized by laws and regulations and shall not use for any other purposes.

  • Financial Instruments Business (to sell/buy securities, agency execution of securities, underwriting of securities transactions, etc.) and other businesses incidental to Financial Instruments Business.
     
  • Businesses to be carried out by financial instruments business operators under the Financial Instruments and Exchange Act (hereinafter referred to as the “Financial Instruments Act”) and any other laws and businesses incidental thereto.
     
  • Those businesses other than the above to be carried out by financial instruments business operators and businesses incidental thereto (including businesses authorized to handle in the future).
     
  • Affairs which are authorized to use an Individual Number in connection with the above businesses under the Numbers Act.


3. Purposes of Usage of Client's Personal Information, and its Announcement

In order to promote transactions with clients safely and securely and provide better financial instruments and services, the Company obtains the Personal Information related to clients to the extent required.

The most common information shall be the address, name, date of birth, workplace, telephone number, other contact, roles, position, title, and business in charge, etc., of clients. In addition, in commencement of transactions, information related to financial condition, investment experience, investment purpose, risk tolerance, credit records, Individual Number and information to verify the identity of the person, etc., may be required.

The above Personal Information shall be used for the following purposes within the scope determined by all applicable laws and regulations. In this regard, the Company shall not use or provide to third parties sensitive information and special care required personal information which are special non-disclosure information and defined by the PIPA and FSA Guideline for personal information protections including race, belief, family origin, domicile and information related to health and medical care or criminal records, etc., other than the purposes for proper business operation and any other purposes which are deemed to be necessary in compliance with all relevant regulations. The Company shall not use or provide to third parties an Individual Number for any purpose other than the following purpose of use of Specific Personal Information, etc., in compliance with the Numbers Act.

1. Purposes of Use of Personal Information (except for Specific Personal Information, etc.)

  • For providing information related to solicitation, sales and service of securities and various financial instruments of the Company under the Financial Instruments Act;
  • For accepting application for financial instruments and services, including for opening an account of various financial instruments;
  • For performing the obligation of client identification, etc., under the Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act and any other laws and regulations;
  • For making judgment on credit extension /investment, and management of risk associated with credit extensions or investments by the Company;
  • For making decisions on applications for financing or on continuation of existing transactions;
  • For making decisions for adequacy of services regarding financial instruments in the light of the principle of suitability;
  • For providing Personal Information to third parties to the extent required for conducting necessary operations for financing businesses;
  • For properly performing where all or part of Personal Information maintenance and processing is outsourced from other parties;
  • For exercising rights and fulfil obligations under agreement with a client and the law, etc.;
  • For research and development of financial instruments and services by market research, data analysis, conducting questionnaires and other sources;
  • For proposals of various financial instruments and services, including sending direct mail;
  • For soliciting and selling various financial instruments and introducing services related to Deutsche Bank Group companies, affiliates and alliance partners of the Companies;
  • For necessary administration for cancellation of various transactions and clerical management after cancellation;
  • For market research in the Company and research and development of financial instruments and services and sending various research reports, etc.;
  • For compliance with laws and regulations of Japan and other countries, risk management, enhancement of services, promotion of internal business and internal control;
  • For the purpose of various investigations, analysis and production of documents upon requests by a central or municipal government, an autonomous government, a relevant regulator, tax authority, any other administrative authority, judicial body, stock exchange or self-regulatory body of Japan and other countries.
  • For verifying the identity of the Subject Individual person or the agent of the person;
  • For reporting transaction results, account balances, etc. to the client;
  • For handling necessary operations for transactions with the client;
  • For obtaining information necessary to respond inquiries from clients ;
  • For sending seasonal greetings, etc., and information related to various seminars and receptions, etc.;
  • For any other reasons for the purpose of conducting proper and smooth transactions with the client; and
  • For employment of personnel.

2. Purpose of Use of Specific Personal Information, etc.

  • Affairs of application for and filing of opening an account for financial instruments transactions by clients (including affairs of application for and filing of use of small amount investment tax exemption scheme, etc.);
  • Affairs of preparing and providing statutory documents for financial instruments transactions of clients;
  • Affairs of providing to depository institutions, etc., related to financial instruments transactions by clients;
  • Affairs of preparing and providing the payment records of remunerations and fees, etc., related to clients;
  • Affairs of preparing and providing the payment records of distribution of dividends and retained earnings and fund interest of clients;
  • Affairs of preparing and providing the payment records of use fees, etc., of real estate of clients related to the business of the Company;
  • Affairs of preparing and providing the payment records of consideration for receipt of real estate, etc., related to clients; and
  • Otherwise, affairs of preparing and providing statutory documents required to enter a Individual Number by laws and regulations, etc.


4. Joint use of Personal Data among group companies

Within the scope of purpose of use above, the Company and the group companies set forth below may jointly use Personal Data of clients (excluding Specific Personal Information, etc., the same applies hereinafter in this article). You may access the Privacy Policy (purpose of use and the contact for inquiries, etc.) of each group company in Japan from the following links. In this regard, this shall not apply to the cases where the consent of clients is required for joint use by laws and regulations.

Our Group Companies:
  • Deutsche Bank AG
  • DWS Investments Japan Limited
  • Deutsche Holdings (Luxembourg) S.ar.l.
  • Deutsche Bank Trust Company Americas
  • DB Services (New York), Inc.
  • Deutsche Bank Securities Inc.
  • Deutsche Securities Asia Limited
  • Deutsche Securities Australia Limited
  • DB Services New Jersey, Inc.
  • DBOI Global Services Private Limited
  • Deutsche Knowledge Services Pte. Ltd.
  • Deutsche CIB Centre Private Limited
  • DB Service Centre Limited
  • DB Global Technology, Inc.
  • Other subsidiaries and affiliates of Deutsche Bank AG stated in the “Description of related companies” of the Annual Securities Report (Yukashoken Hokokusho) submitted by Deutsche Bank AG (Yukashoken Hokokusho is available through EDINET web-site).

Link to Privacy Policies of Group Companies in Japan:

Items of Personal data to be jointly used (except for Specific Personal Information, etc.):
  • Such information related to a client as the name, home address, date of birth, position description, employer, job title, work address, telephone/fax number, e-mail address, CV/resume, etc.;
  • Information related to trading of client, balance amount, client transaction information; and
  • Information on client needs, such as those for client’s asset management, etc.

In this regard, where a client provides Personal Information, if it becomes necessary to use Personal Information of the client beyond the scope of specified initial purpose, the Company shall give prior notice or announce to the client of the purpose, except for certain cases which are provided for in laws and regulations.


5. Outsourcing

The Company outsources a part of its operations/activities to external vendors. The Company obtained the consent to management of Personal Data by the outsourcing company and chain sourcing company (which is a re-outsourcing company from the outsourcing company of the Company) that the outsourcing is conducted within the purpose of use of the Personal Data of clients is properly managed under all applicable laws and regulations of Japan and other countries and this Policy, and supervises them.
Major operations outsourced are as follows:
  • Operations of printing or dispatching documents sent to clients.
  • Operations to provide professional legal and accounting advice, etc.
  • Operations for operation and maintenance of information systems.
  • Operations for preparation and retention of books and documents related to business.
  • Operations for involving production or analysis etc. of data, records, communications or other documents etc. relating to internal investigations etc.


6. Provision・receive of Personal Data to・from Third Parties

The Company shall not provide to any third party Personal Data (excluding Specific Personal Information, etc., the same applies hereinafter in this article) related to a client without the prior consent of the client, except as provided for in laws and regulations, rules or this Policy. If the Company provide Personal Data to a third party and its chain-sourcing company, the Company shall conduct appropriate investigation of the third party and appropriate supervision to cause the third party to keep confidential. In such an event, method of notification to the third party shall be by distributing and sending written documents (including electronic and magnetic method) or orally.

In the Personal Data provided to the third party, the name, address, date of birth, place of employment, phone number, other contact details, roles, position, title, jobs and Personal Information, necessary to perform the purpose of use stated in the Policy are included.
If it is requested by a client, the Company shall suspend providing to third parties Personal Data of the client.

Specific Personal Information and etc. related to a client shall not be provided to the parties other than the parties which were confirmed that provision of Information was necessary for the cases which are provided for in the Numbers Act and any other related laws and regulations and with reference to the purpose of use provided for above (the third party which conducts the affairs and such administrative organization, etc., requesting submission of an Individual Number as tax offices).

The Company does not provide any Personal Data of the client on to fee services.

In case of the Company receive Personal Data from the third party, measurements will be taken following regulations in Japan.


7. Management of Personal Information

  • The Company implements appropriate safety measures to assure the accuracy of its clients' Personal Information and to maintain the information up to date.
  • The Company implements appropriate measures to prevent unauthorized access to its clients' Personal Information.
  • The Company implements appropriate security measures including countermeasure for unauthorized access and for computer viruses in order to prevent loss, destruction, falsification and leakage, etc..
  • The Company requires the proper management of its clients’ Personal Information by its outsourcing vendors that handle Personal Information.


8. Disclosure/Rectification/Suspension of Usage/Deletion based on the Request from the Client

Where an individual client makes a request for disclosure, rectification, suspension of use, deletion and suspension of provision to third parties or deletion of Personal Information etc. of the client held by the Company, or the client requests disclosure of whether the Company holds the Individual Number of the client, the Company shall respond in accordance with the procedures prescribed by the Company upon verification of the identity of the requester, unless there are special reasons. Please understand in advance that fees may be charged on the disclosure.

Please Contact the following address for further information.


9. Contact Information

For requests for disclosure, rectification, suspension of use, deletion and suspension of provision to third parties, deletion of Personal Information and any questions, please contact the following.

Compliance Department
Deutsche Securities Inc.

Post Code, 100-6171
Sanno Park Tower,
2-11-1 Nagata-cho Chiyoda-ku Tokyo

TEL: +81-3-5156-6000
E-Mail: tokyodsi.personal-info@list.db.com

Business Hours: 9:00 ~ 17:30
(Closed on Saturday, Sunday, National Holidays, and Year-end/New Year holidays)


10. Authorized Personal Information Protection Institution

The Company is a member of the Japan Securities Dealers Association ("JSDA") and the Financial Futures Association of Japan (“FFAJ”) both of which are Authorized Personal Information Protection Institutions. The Personal Information Consultation Offices of JSDA and FFAJ handle complaints and/or consultation in relation to the handling of Personal Information by JSDA and FFAJ members.

[Contact for complaints and/or consultation]

Personal Information Consultation Office, Japan Securities Dealers Association
Tel: 03-3667-8427  (http://www.jsda.or.jp/)

Personal Information Consultation Office, The Financial Futures Association of Japan
Tel: 03-5280-0881  (http://www.ffaj.or.jp/hogodantai/index.html)


11. Amendments

This Policy is subject to change in accordance with the amendments of laws and/or regulations or for any other reasons. In such an event, any amendments will be posted on the homepage of the Company and will become effective at the time of posting.


12. Compliance with Laws and/or Regulations, Improvements and Enhancements

In order to implement this Policy, the Company will comply with laws and/or regulations concerning Personal Information and will continuously endeavor to improve and enhance the handling of Personal Information.


Established:
January 1, 2006
Last revised:
August 31 2021

Show content of Deutsche Bank AG, Tokyo Branch

Deutsche Bank AG, Tokyo Branch (hereinafter referred to as the "Bank") puts top priority on client trust and complies with all applicable laws and regulations of Japan and other countries for protection of personal information and strives for appropriate handling and protection of personal information of clients entrusted to the Bank in accordance with the following Policy.

The terms used in the Privacy Policy shall be in accordance with the following definitions.
  • “Personal Information” means information related to living individuals, which can identify a specific individual by name, date of birth or any other description, etc., contained in such information (including information as will allow easy reference to other information and will thereby enable identification of the specific individual) and information that contains individual identification codes which are defined by the article 2-1 of Personal Information Protection Act (hereinafter referred to as the “PIPA”) .
     
  • “Personal Information Database etc.” means a set of information which includes personal information as set of information structurally organized to enable a computer to be used to retrieve certain personal information from it, or in addition to what is listed in the preceding item by alphabetical order, index code, organized table of contents and etc., a set of information which are structurally organized to be easily retrieved certain personal information even without using computer.
     
  • “Personal Data” means personal information compiled in a Personal Information Database etc.
     
  • “Individual Number” means the number obtained by converting a resident record code under the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures (hereinafter referred to as the “Numbers Act”), which is designated to identify the person to whom the resident record where said resident record code is stated pertains (including the number, symbol and any other code other than the resident record code, corresponding to the Individual Number and is used in place of the Individual Number) and includes the number of a deceased person who does not fall under “Personal Information.”
     
  • “Specific Personal Information” means Personal Information containing an Individual Number.
     
  • “Specific Personal Information, etc.,” means an Individual Number and Specific Personal Information.


1. Procurement of Personal Information

The Bank shall obtain Personal Information by lawful and fair manner.
In this regard, for information sources of Personal Information, the Bank shall mainly obtain Personal Information, through the application form for opening an account and any other documents and materials submitted by customers. The Bank may obtain Personal Information in relation to transactions with clients and the products and services provided. Further, regarding Personal Information, the Bank may obtain additional Personal Information related to clients by obtaining credit records from consumer credit information organizations, etc., depending on the goods and services requested by clients. The Bank may also obtain Personal Information through application forms for employment to recruit personnel, placement agencies, our employees, our group companies and any other third parties. In this regard, the Bank shall properly obtain Specific Personal Information in accordance with laws and regulations and in compliance with the Numbers Act and shall not share Specific Personal Information among our DB group companies.

In providing financial services to our clients, the Bank may obtain Personal Information related to clients through monitoring and any other means (recording of telephone conversations and monitoring of e-mails, etc.) in compliance with applicable laws and regulations. The Bank does not routinely or regularly access such information, but the Bank may use the information for the purpose of compliance and security.


2. Use of Personal Information

The Bank shall use Personal Information within the purposes of use published in advance or notified and/or specified when it is obtained and to the extent necessary to perform the following businesses authorized by laws and/or regulations and shall not use for any other purposes.

  • Deposit business, exchange business, currency exchange business, loan business, foreign exchange business, and other businesses incidental to these businesses;
  • Businesses to be carried out by registered financial institution under Financial Instruments and Exchange Act (hereinafter referred to as the “Financial Instruments Act”) ;
  • Those businesses other than the above in which banks are permitted to engage and businesses incidental to these businesses (including businesses which will be permitted in the future).
  • Affairs which are authorized to use an Individual Number in connection with the above businesses under the Numbers Act.


3. Purposes of Usage of Client's Personal Information, and its Announcement

In order to promote transactions with clients safely and securely and provide better financial products and services, the Bank obtains the Personal Information related to clients to the extent required.

The most common information shall be the address, name, date of birth, place, telephone number, other contact, roles, position, title, and business in charge, etc., of clients. In addition, in commencement of transactions, information related to financial condition, investment experience, investment purpose, risk tolerance, credit records, Individual Number and information to verify the identity of the person, etc., may be required.

The above Personal Information shall be used for the following purposes within the scope determined by all applicable laws and regulations including Personal Information Protection Act, Bank Law. In this regard, the Bank shall not use or provide to third parties regarding the repayment capacity of debt only for the purpose of conducting investigation of repayment capacity according to the Enforcement Ordinance of the Banking Law. Also the Bank shall not use or provide to third parties sensitive information and special care required personal information which are special non-disclosure information, and defined by the PIPA and FSA Guideline for personal information protections, including race, belief, family origin, domicile and information related to health and medical care or criminal records, etc., other than the purposes for proper business operation and any other purposes which are deemed to be necessary in compliance with all relevant regulations. The Bank shall not use or provide to third parties an Individual Number for any purpose other than the following purpose of use of Specific Personal Information, etc., in compliance with the Numbers Act.

Purposes of Usage

1. Purposes of Use of Personal Information (except for Specific Personal Information, etc.)

  • For providing information related to solicitation, sales and service of various financial instruments;
  • For accepting applications for financial instruments and services, including for opening an account of various financial instruments;
  • For performing the obligations of client identification, etc., under the Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act and any other laws and regulations;
  • For management of continuing transactions such as by due date control for deposit transactions or loan transactions, etc.;
  • For making judgment on applications for financing or on continuation of existing transactions;
  • For making judgment on credit extension or investment of the Bank, and management of risk associated with credit extensions or investment afterwards;
  • For making decisions for adequacy of services regarding financial instruments in the light of the principle of suitability;
  • For providing Personal Information to third parties to the extent required for conducting necessary operations for financing businesses;
  • For properly performing where all or part of Personal Information maintenance and processing is outsourced from other parties, etc.;
  • For exercising rights and fulfill obligations under agreement with the client or and the law, etc.;
  • For research and development of financial instruments and services by market research, data analysis, conducting questionnaires, and other sources;
  • For proposals of various financial instruments and services, including sending direct mail;
  • For soliciting and selling various financial instruments and introducing services related to Deutsche Bank Group companies, affiliates and alliance partners of the Companies;
  • For necessary administration for cancellation of various transactions and clerical management after cancellation operations for cancelled transactions;
  • For market research in the Bank and research and development of financial instruments and services and sending various research reports, etc.;
  • For compliance with laws and regulations of Japan and other countries, risk management, enhancement of services, promotion of internal business and internal control;
  • For the purpose of various investigation, analysis and production of documents upon requests by a central or municipal government, an autonomous government, a relevant regulator, tax authority, any other administrative authority, judicial body, stock exchange or self-regulatory body of Japan and other countries.
  • For verifying the identity of the Subject Individual person or the agent of the person;
  • For reporting transaction results, account balances, etc. to the client;
  • For handling necessary operations for transactions with the client;
  • For obtaining information necessary to respond to inquiries from clients;
  • For sending season's greetings, etc., and information related to various seminars and receptions, etc.;
  • For any other reasons for the purpose of conducting proper and smooth transactions with the client; and
  • For employment of personal.

2. Purpose of Use of Specific Personal Information, etc.

  • Affairs of application for and filing of opening an account for banking transactions and financial instruments transactions by clients (including affairs of application for and filing of use of small amount investment tax exemption scheme, etc.);
  • Affairs of preparing and providing statutory documents for banking transaction and financial instruments transactions of clients;
  • Affairs of preparing and providing to statutory documents related to remittance, etc., by clients;
  • Affairs of preparing and providing the payment records of remunerations and fees, etc., related to clients;
  • Affairs of preparing and providing the payment records of distribution of dividends and retained earnings and fund interest of clients;
  • Affairs of preparing and providing the payment records of use fees, etc., of real estate of clients related to the business of the Bank;
  • Affairs of preparing and providing the payment records of consideration for receipt of real estate, etc., related to clients; and
  • Otherwise, affairs of preparing and providing statutory documents required to enter a Individual Number by laws and regulations, etc.


4. Joint use of Personal data among group companies

Within the scope of purposes of use above, the Bank and the group companies set forth below may jointly use Personal Data of clients (excluding Specific Personal Information, etc., the same applies hereinafter in this article). You may access the Privacy Policy (purpose of use and the contact for inquiries, etc.) of each group company in Japan from the required for joint use by laws and regulations.

Group Companies:

  • Deutsche Securities Inc.
  • DWS Investments Japan Limited
  • Deutsche Bank Trust Company Americas
  • DB Services New Jersey, Inc,
  • DBOI Global Services Private Limited
  • Deutsche Knowledge services Pte. Ltd.
  • Deutsche CIB Centre Private Limited
  • DB Service Centre Limited
  • Other subsidiaries and affiliates of Deutsche Bank AG stated in the “Description of related companies” of the Annual Security Report (Yukashoken Hokokusho) submitted by Deutsche Bank AG (Yukashoken Hokokusho is available through EDINET web-site).

Link to Privacy Policies:


Items of Personal data to be jointly used (except for Specific Personal Information, etc.):

  • Such information related to a client as the name, home address, birth date, position description, employer, job title, work address, telephone/fax number, e-mail address, CV/resume, etc.;
  • Information related to trading of client, balance amount, client transaction information; and,
  • Information on client needs, such as those for client’s asset management, etc..

The Person responsible for sharing Personal Information among the group entities:

  • Personal Information Protection Manager, Deutsche Bank AG, Tokyo Branch

In this regard, where a client provides Personal Information, if it becomes necessary to use Personal Information of the client beyond the scope of specified initial purpose, the Bank shall give prior notice or announce to the client of the purpose, except for certain cases which are provided for in laws and regulations.


5. Outsourcing

The Bank outsources a part of its operations/activities to external vendors. The Bank obtained the consent to management of Personal Data, by the outsourcing company and chain sourcing company (which is a re-outsourcing company of the outsourcing company of the Bank) that the outsourcing is conducted within the purpose of usage of the Bank and Personal Information and Personal Data of clients is managed appropriately in accordance with the all relevant laws and regulations of Japan and other countries and this Policy, and supervises them.
Major operations outsourced are as follows:
  • Operations of printing or dispatching documents sent to clients
  • Operations to provide professional legal and accounting advice, etc.
  • Operations for operation and maintenance of information systems.
  • Operations for preparation and retention of books and documents related to business.
  • Operations for involving production or analysis etc. of data, records, communications or other documents etc. relating to internal investigations etc.


6. Provision・receive of Personal Data to Third Parties

The Bank shall not provide to any third party Personal Data (excluding Specific Personal Information, etc., the same applies hereinafter in this article) related to a client without the prior consent of the client, except as provided for in laws and regulations, rules or this Statement. If the Bank provides Personal Data to a third party and its chain-sourcing Bank, the Bank shall conduct appropriate investigation of the third party and appropriate supervision to cause the third party to keep confidential. In such an event, method of notification to the third party shall be by distributing and sending written documents (including electronic and magnetic method) or orally. In the Personal Data provided to the third party, the name, address, date of birth, place of employment, phone number, other contact details, roles, position, title, jobs and Personal Information, necessary to perform the purpose of use stated in the Statement are included.
If it is requested by a client, the Bank shall suspend providing to third parties Personal Data of the client.

Specific Personal Information and etc. related to a client shall not be provided to the parties other than the parties which were confirmed that provision of Information was necessary for the cases which are provided for in the Numbers Act and any other related laws and regulations and with reference to the purpose of use provided for above (the third party which conducts the affairs and such administrative organization, etc., requesting submission of a Individual Number as tax offices).

The Bank does not provide any Personal Data of the client on to fee services.

In case of the Bank receive Personal Data from the third party, measurements will be taken following regulations in Japan.


7. Management of Personal Information

  • The Bank implements appropriate safety measures to assure the accuracy of its clients' Personal Information, and to maintain the information up to date.
  • The Bank implements appropriate measures to prevent inappropriate access to its clients' Personal Information.
  • The Bank implements appropriate security measures such as protection from unauthorized access, or computer viruses, in order to protect Personal Information from loss, damage, falsification or leakage, etc.
  • The Bank causes the companies which are outsourced by the Bank to handle Personal Information of clients and its re-consignee to conduct appropriate management.


8. Disclosure/Rectification/Suspension of Usage/Deletion based on the Request from the Client

Where an individual client makes a request for disclosure, rectification, suspension of use, suspension of provision to third parties or deletion of Personal Information of the client held by the Bank, or the client requests disclosure of whether the Bank holds the Individual Number of the client, the Bank shall respond in accordance with the procedures prescribed by the Bank upon verification of the identity of the requester, unless there are special reasons. Please understand in advance that fees may be charged on the disclosure.

Please contact the following address for further information.


9. Contact Information

For requests for disclosure, rectification, suspension of use, deletion and suspension of provision to third parties, deletion of Personal Information and any questions, please contact the following.

Compliance Department
Deutsche Bank AG, Tokyo Branch
Sanno Park Tower,
2-11-1 Nagata-cho Chiyoda-ku Tokyo

TEL: +81-3-5156-4000
E-Mail: dbagtokyo.personal-info@list.db.com
Business Hours: 9:00 ~ 17:30
(Closed on Saturday, Sunday, National Holidays, and Year-end/New-year holidays)


10. Authorized Personal Information Protection Institution

The Bank is a member of the All Banks Personal Data Protection Council (the "Council") which is an Authorized Personal Information Protection Institution for the financial sector. The complaints/inquiries center of the Council (Customer Relations Center, Japanese Bankers Association and Ginko Torihiki Sodanjo) handles complaints/consultation in relation to the handling of Personal Information by members of the Council.

All Banks Personal Data Protection Council
(homepage: http://www.abpdpc.gr.jp/)

[Contact for complaints/consultation]
Tel: 03-5222-1700

or contact the closest Ginko Torihiki Sodanjo

DB is a member of the Japan Securities Dealers Association ("JSDA") which is an Authorized Personal Information Protection Institution. The Personal Information Consultation Office of JSDA handles complaints/consultation in relation to the handling of Personal Information by JSDA members.

Personal Information Consultation Office, Japan Securities Dealers Association
(homepage: http://www.jsda.or.jp/)

[Contact for complaints/consultation]
Tel: 03-3667-8427


11. Amendments

This policy is subject to change in accordance with the amendments of laws and/or regulations or other reasons. Such amendments will be posted on DB's homepage, and will become effective once posted.


12. Compliance with Laws and/or Regulations, Improvements and Enhancements

In order to implement this policy, the Bank will comply with laws and/or regulations concerning Personal Information and will continuously endeavor to improve and enhance the handling of Personal Information.


Established on March 25, 2005
Last amendment on August 31, 2021

Show content of DWS Investments Japan Limited

DWS Investments Japan Limited (hereinafter referred to as the “Company”) puts top priority on client trust and complies with all applicable laws and regulations of Japan and other countries for protection of personal information and strives for appropriate handling and protection of personal information of clients entrusted to the Company in accordance with the following Policy.

The terms used in the Privacy Policy shall be in accordance with the following definitions.
  • “Personal Information” means information related to living individuals, which can identify a specific individual by name, date of birth or any other description, etc., contained in such information (including information as will allow easy reference to other information and will thereby enable identification of the specific individual) and information that contains individual identification codes which are defined by the article 2-1 of Personal Information Protection Act (hereinafter referred to as the “PIPA”).
     
  • “Personal Information Database etc.” means a set of information which includes personal information as set of information structurally organized to enable a computer to be used to retrieve certain personal information from it, or in addition to what is listed in the preceding item by alphabetical order, index code, organized table of contents and etc., a set of information which are structurally organized to be easily retrieved certain personal information even without using computer.
     
  • “Personal Data” means personal information compiled in a Personal Information Database etc.
     
  • “Individual Number” means the number obtained by converting a resident record code under the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures (hereinafter referred to as the “Numbers Act”), which is designated to identify the person to whom the resident record where said resident record code is stated pertains (including the number, symbol and any other code other than the resident record code, corresponding to the Individual Number and is used in place of the Individual Number) and includes the number of a deceased person who does not fall under “Personal Information.”
     
  • “Specific Personal Information” means Personal Information containing an Individual Number.
     
  • “Specific Personal Information, etc.,” means an Individual Number and Specific Personal Information.


1. Procurement of Personal Information

The Company shall obtain Personal Information, by lawful and fair manner. In this regard, for information sources of Personal Information the Company shall mainly obtain Personal Information through the questionnaires the Company conducts, the commercially available books such as “Shiki-ho” or Internet, and/or in the course of the products and services the Company provides. The Company also may obtain the Personal Information from employment agencies, our employees, DB group companies and/or third parties for our hiring. In this regard, the Company shall properly obtain Specific Personal Information in accordance with laws and regulations and in compliance with the Numbers Act and shall not share Specific Personal Information among our DB group companies.

In providing financial services to our clients, the Company may obtain Personal Information related to clients through monitoring and any other means (recording of telephone conversations and monitoring of e-mails, etc.) in compliance with applicable laws and regulations. The Company does not routinely or regularly access such information, but the Company may use the information for the purpose of compliance and security.


2. Use of Personal Information

The Company shall use Personal Information within the purposes of use published in advance or notified and/or specified when it is obtained and to the extent necessary to perform or the following business authorized by laws and regulations and shall not use for any other purposes.;
  • investment management business concerning investment trust, investment management business based on investment discretionary agreement, investment advisory/agency business, type-two financial instruments business and its auxiliary business;
  • other business that the Company is, based on relevant laws and regulations, able to engage in, and its auxiliary business (including business which will be permitted in the future).
  • affairs which are authorized to use an Individual Number in connection with the above businesses under the Numbers Act.


3. Purpose of Usage of Clients’ Personal Information and its Announcement

In order to promote transactions with clients safely and securely and provide better financial instruments and services, the Company obtains the Personal Information related to clients to the extent required.
The most common information shall be the address, name, date of birth, workplace, phone number, other contact, roles, position, title, and business in charge, etc. of clients. In addition, in commencement of transactions, information related to financial condition, investment experience, investment of purpose, risk tolerance, credit records, Individual Number and information to verify the identity of person, etc. may be required.

The above Personal Information shall be used for the following purposes within the scope determined by laws and regulations. In this regard, the Company shall not use or provide to third parties sensitive information and special care required personal information which are special non-disclosure information and defined by the PIPA and FSA Guideline for personal information protections including race, belief, family origin, domicile and information related to health and medical care or criminal records, etc., other than the purposes for proper business operation and any other purposes which are deemed to be necessary in compliance with all relevant regulations. The Company shall not use or provide to third parties an Individual Number for any purpose other than the following purpose of use of Specific Personal Information, etc., in compliance with the Numbers Act.

1. Purposes of Use of Personal Information (except for Specific Personal Information, etc.)
  • For providing information related to solicit, sales and service of various financial instruments;
  • For operations regarding investment advisory agreements, discretionary investment management agreements or investment trust management agreements with clients;
  • To report results of investment management and amount of assets under investment management agreements to clients;
  • For opening accounts, etc. for receiving application for securities, financial products and services;
  • For making decisions for adequacy of services regarding financial instruments in the light of the principle of suitability;
  • For exercising rights and fulfill obligations under agreement with a client or by rule of law or regulation;
  • For research and development of financial instruments and services by market research, data analysis, conducting questionnaires and other sources;
  • For proposals of various financial instruments and services, including sending direct mail;
  • For soliciting and selling various financial instruments and introducing services related to Deutsche Bank Group companies, affiliates and alliance partners of the Companies;
  • For necessary administration for cancellation of various transactions and clerical management after cancellation for cancelled transactions;
  • For market research in the Company and research and development of financial instruments and services and sending various research reports, etc.;
  • For compliance with laws and regulations of Japan and other countries, risk management, enhancement of services, promotion of internal business and internal control;
  • For the purpose of various investigations, analysis and production of documents upon requests by a central or municipal government, an autonomous government, a relevant regulator, tax authority, any other administrative authority, judicial body, stock exchange or self-regulatory body of Japan and other countries.
  • For verifying the identity of the Subject Individual person or the agent of the person
  • For obtaining information necessary to respond to inquiries from clients;
  • For sending season’s greetings, etc., and information related to various seminars and receptions, etc.;
  • For any other reasons for the purpose of conducting smooth transactions with the client; and
  • For employment of personnel.

2. Purpose of Use of Specific Personal Information, etc.
  • Affairs of preparing and providing statutory documents for financial instruments transactions of clients;
  • Affairs of preparing and providing the payment records of remunerations and fees, etc., related to clients;
  • Affairs of preparing and providing the payment records of distribution of dividends and retained earnings and fund interest of clients;
  • Affairs of preparing and providing the payment records of use fees, etc., of real estate of clients related to the business of the Company;
  • Affairs of preparing and providing the payment records of consideration for receipt of real estate, etc., related to clients; and
  • Otherwise, affairs of preparing and providing statutory documents required to enter an Individual Number by laws and regulations, etc.


4. Joint use of Personal Information among group companies

Within the scope of purpose of use above, the Company and the group companies set forth below may jointly use Personal Information and Personal Data of clients (excluding Specific Personal Information, etc., the same applies hereinafter in this article). You may access the Privacy Policy (purpose of use and the contact for inquiries, etc.) of each group company in Japan from the following links. In this regard, this shall not apply to the cases where the consent of clients is required for joint use by laws and regulations.

Group Companies:
  • Deutsche Bank AG, Tokyo Branch, Other Branches
  • Deutsche Securities Inc.
  • DWS Group GmbH & Co. KGaA
  • DWS International GmbH
  • DWS Investment GmbH
  • RREEF America L.L.C.
  • DWS Investment Management Americas Inc.
  • DWS Investments Australia Limited
  • DB Services New Jersey, Inc.
  • DBOI Global Services Private Limited
  • Deutsche Knowledge Services Pte. Ltd.
  • Deutsche CIB Centre Private Limited
  • DB Service Centre Limited
  • DB Global Technology, Inc.
  • Other subsidiaries and affiliates of Deutsche Bank AG stated in “Description of related companies” of the Annual Securities Report (Yukashoken Hokokusyo) submitted by Deutsche Bank AG (Yukashoken Hokokusyo is available through EDINET web- site).

Link to Privacy Policies of Group Companies in Japan:

Deutsche Securities Inc. - Privacy Policy
Deutsche Bank AG, Tokyo Branch - Privacy Policy

Items of Personal data to be jointly used (except for Specific Personal Information, etc.):
name, home address, birth date, position description, employer, job title, work address, telephone/fax number, e-mail address, CV/resume, etc.;

The Person responsible for sharing Personal Information among the group entities:
Personal Information Protection Manager, DWS Investments Japan Limited

In this regard, where a client provides Personal Information, if it becomes necessary to use Personal Information of the client beyond the scope of specified initial purpose, the Company shall give prior notice or announce to the client of the purpose, except for certain cases which are provided for in laws and regulations.


5. Outsourcing

The Company outsources a part of its operations/activities to external vendors. The Company obtained the consent to management of Personal Data by the outsourcing company and chain sourcing company (which is a re-outsourcing company of the outsourcing company of the Company) that the outsourcing is conducted within the purpose of use of the Personal Information and Personal Data of clients is properly managed under all applicable laws and regulations, rules of Japan and other countries and this Policy, and supervises them.
Major operations outsourced are as follows:
  • Operations of printing or dispatching documents sent to clients
  • Operations to provide professional legal and accounting advice, etc.
  • Operations for operation and maintenance of information systems
  • Operations for preparation and retention of books and documents related to business.
  • Operations for involving production or analysis etc. of data, records, communications or other documents etc. relating to internal investigations etc.


6. Provision・receive of Personal Data to Third Parties

The Company shall not provide to any third party Personal Data (excluding Specific Personal Information, etc., the same applies hereinafter in this article) related to a client without the prior consent of the client, except as provided for in laws and regulations, rules or this Policy. If the Company provides Personal Data to a third party and its chain-sourcing company, the Company shall conduct appropriate investigation of the third party and appropriate supervision to cause the third party to keep confidential. In such an event, method of notification to the third party shall be by distributing and sending written documents (including electronic and magnetic method) or orally.
In the Personal Data provided to the third party, the name, address, date of birth, place of employment, phone number, other contact details, roles, position, title, jobs and Personal Information, necessary to perform the purpose of use stated in the Policy are included.
If it is requested by a client, the Company shall suspend providing to third parties Personal Information identifying the client.

Specific Personal Information and etc. related to a client shall not be provided to the parties other than the parties which were confirmed that provision of Information was necessary for the cases which are provided for in the Numbers Act and any other related laws and regulations and with reference to the purpose of use provided for above (the third party which conducts the affairs and such administrative organization, etc., requesting submission of an Individual Number as tax offices).

The Company does not provide any Personal Data of the client on to fee services.

In case of the Company receive Personal Data from the third party, measurements will be taken following regulations in Japan.


7. Management of Personal Information

  • The Company implements appropriate safety measures to assure the accuracy of its clients’ Personal Information and maintain the information up to date.
  • The Company implements appropriate measures to prevent unauthorized access to its clients’ Personal Information.
  • The Company implements appropriate security measures including countermeasure for unauthorized access for computer viruses in order to prevent loss, destruction, falsification and leakage, etc.
  • The Company causes the companies which are outsourced by the Company to handle Personal Information of clients and its re-consignee to conduct appropriate management.


8. Disclosure/ Rectification / Suspension of Usage/ Deletion based on the Request from the Client

Where an individual client makes a request for disclosure, rectification, suspension of use, deletion and suspension of provision to third parties or deletion of Personal Information etc. of the client held by the Company, or the client requests disclosure of whether the Company holds the Individual Number of the client, the Company shall respond in accordance with the procedures prescribed by the Company upon verification of the identity of the requester, unless there are special reasons. Please understand in advance that fees may be charged on the disclosure. Please contact the following address for further information.


9. Contact Information

For requests for disclosure, rectification/suspension, suspension of use, deletion and suspension of provision to third parties, deletion of Personal Information and any questions, please contact the following.

Compliance Department
DWS Investments Japan Limited

Sanno Park Tower,
2-11-1 Nagata-cho Chiyoda-ku Tokyo
Tel: +81-3-5156-5000
E- Mail: deamj.personal-info@list.db.com
Business Hours: 9:00 ~ 17:30
(Closed on Saturday/Sunday/National Holiday, and Year-end/New-year holidays)


10. Authorized Personal Information Protection Institutions

The Company is a member of the below associations, which handle Complaints/Inquiries on members regarding the handling of Personal Information.

Business related to Non-discretionary and Discretionary Investment Advisory Services
 Japan Investment Advisers Association
 [Contact for Complaints/Inquiries] Tel:03-3663-0505, FAX: 03-3663-0510

Investment Trust Management Business
 The Investment Trusts Association, Japan
 [Contact for Complaints/Inquiries] Tel: 03-5614-8440

 Type I Financial Instruments Business
 Japan Securities Dealers Association
 [Contact for Complaints/Inquiries] Tel:03-3667-8427


11. Amendments

This Policy is subject to change in accordance with the amendments of laws and/or regulations or for any other reasons. In such an event, any amendments will be posted on the homepage of the Company and will become effective upon the time of posting.


12. Compliance with Laws and/or Regulations, Improvements and Enhancements

In order to implement this Policy, the Company will comply with laws and/or regulations concerning Personal Information and will continuously endeavor to improve and enhance the handling of Personal Information.



Enacted on 25 March 2005
Last revised on 31 August 2021