Privacy Statement

Morgan Stanley Japan Holdings Co., Ltd.

Morgan Stanley Japan Business Group (“we”, “our” or “us”) is committed to safeguarding the privacy of information entrusted to us. Protecting the confidentiality and security of personal information has always been an integral part of how we conduct our business.

We pledge to ensure our business practices protect your personal information.

This Privacy Statement applies to all personal information that we obtain or handle in Japan.

As a business operator handling personal information (as defined in the Act on the Protection of Personal Information (the “Personal Information Protection Act”), we make this Privacy Statement in respect of our basic policies concerning the protection of personal information of (1) Morgan Stanley Group’s clients and (2) other persons involved in our business (collectively “you” or “your” depending on the context).

1. We will comply with the Personal Information Protection Act and the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures as well as other applicable laws and regulations, guidelines issued by our government agencies, this Privacy Statement and any other documentation which may govern your relationship with us.
2. Where it is necessary for us to obtain personal information, we will only do so by lawful and fair means.
3. Unless otherwise agreed to between you and us or in exceptional circumstances (but always in compliance with paragraph 1 above), we will only use your personal information within the scope of achieving the following purposes:
   
   
   1. Morgan Stanley Group to provide solicitation, sales and related services concerning financial instruments business (as prescribed in the Financial Instruments and Exchange Law (*);
   2. Morgan Stanley Group suitability in connection with any of our financial products or services (*);
   3. Morgan Stanley Group to check you or your agent’s eligibility (through for example, identification) when we offer our financial products to you or enter into credit transactions with you;
   4. Morgan Stanley Group to check you or your agent’s eligibility (through for example, identification) when we provide our services to you in connection with a transaction;
   5. Morgan Stanley Group to develop our internal business practice, for example, in respect of evaluating credit risk and other types of risk and in respect of our management of new or existing transactions with customers (including extending credit, service providing and similar transactions)(*);
   6. Morgan Stanley Group to inform or advise you of performance results and account balances concerning financial products or services offered to you (*);
   7. Morgan Stanley Group to provide market reports to customers;
   8. Morgan Stanley Group to perform operational and marketing activities including customer development (*);
   9. Morgan Stanley Group to research or develop financial products and services provided by or to be provided by us by conducting market research, data analysis or customer surveys (*);
   10. Morgan Stanley Group to properly carry out any services under contract, including where we are requested by a third party to handle part or all of such third party’s personal information; 
   11. to exercise our rights or perform our obligations under the contracts with you or the applicable laws and regulations. This includes but is not limited to regulatory requests anywhere in the world; reporting to and being audited by national and international regulatory, enforcement or exchange bodies and complying with court orders (*); and
   12. for any other purposes in connection with the above purposes to enable the Morgan Stanley Group to adequately and smoothly provide our services to you (*);
4. Notwithstanding the preceding paragraph, with regard to your individual number and specified personal information (“specified personal information, etc.”), we will only use such information within the scope of achieving the following purposes:
   
   
   1. for processing the affairs of preparation and submission of payment records regarding the payment of remuneration, fees, contract money, awards or other considerations for services or rights, the payment of rent, etc. or consideration for transfer of real estates, etc.; and
   2. for preparation and submission of other statutory records or documents on which an individual number is required to be written under provisions of laws and regulations.
5. We will not obtain from you, use, or provide to a third party, except as necessary for our proper business management or any other purposes deemed necessary by law, information regarding race, creed, social status, damage suffered as a result of a crime, physical disability, medical history, physical conditions and/or criminal record (collectively "special care-required personal information"), as well as information regarding your affiliation with any labor union, domicile of origin, health care and/or sexual orientation.
6. We may, in whole or in part, share your personal information (excluding specified personal information, etc.) for the following purposes:
   
   
   1. Personal data that may be shared
      
      Name, address, date of birth, telephone number, e-mail address, occupation or information relating to you on business cards, type of products or services, transaction records, account number, and/or account balance
   2. Scope of persons who may share your personal data
      
      Affiliated companies within the Morgan Stanley Group including foreign corporations (*)
      
      * Our affiliated companies include: Morgan Stanley (a U.S. corporation), the consolidated subsidiaries of Morgan Stanley and the Affiliated Companies of Morgan Stanley or its consolidated subsidiaries. “Affiliated Companies” means the affiliated companies as defined in the Ordinance on the Terminology, Forms, and Preparation Methods of Financial Statements, etc. (Ordinance of the Ministry of Finance No.59 of November 27, 1963) and other laws and regulations.
   3. Purpose of use
      
      Indicated in paragraph 3 above
   4. Responsibility for management of personal data to be shared
      
      Morgan Stanley Japan Holdings Co., Ltd.
      Otemachi Financial City South Tower 1-9-7 Otemachi, Chiyoda-ku, Tokyo
      President & CEO: Alberto Tamura
7. We may transfer all or part of the handling of your personal data or specified personal information, etc. to third parties approved by us including overseas third parties in order to accomplish the purposes set out in paragraphs 3 and 4 above. We will supervise any such outsourcing service provider as necessary to ensure that personal data or specified personal information, etc. is secure in accordance with applicable laws and guidelines.
8. Subject to paragraphs 6 and 7 above, we may provide your personal data only to a third party in a foreign country with processes equivalent to of Japanese business operator handling personal information.
   
   We will implement necessary security measures required under the system protecting personal information in the foreign country that is retaining your personal data.
   
   If you wish to request the disclosure of information related to such necessary measures, please contact the Information Helpdesk for personal Information indicated in paragraph 11 below.
9. We will take any necessary and adequate security measures and exercise adequate supervision over all officers and employees and any outsourcing service providers to protect your personal data and specified personal information, etc. against leaks, loss or damage.
10. You may request disclosure of the personal information we hold on you, or request the amendment, addition, suspension of use, deletion or suspension of sharing with third parties (collectively referred to as the “Privacy Rights Requests”) of such personal information by writing to the information desk at the address set out in paragraph 11 below. After we obtain satisfactory evidence of your identity, we will address your request in accordance with the applicable laws and guidelines.
11. If you have any questions or comments regarding Privacy Rights Requests of your personal information and information related to a foreign country where the data is located, or this Privacy Statement, you can contact the Information Helpdesk for Personal Information in the following ways:
    
    Information Helpdesk for Personal Information
    Legal and Compliance Division,
    Morgan Stanley Japan Holdings Co., Ltd.
    Otemachi Financial City South Tower
    1-9-7 Otemachi, Chiyoda-ku, Tokyo 100-8109
    Phone: 03-6836-5000
    E-mail: data-protectionjp@morganstanley.com
    Office hours: 9:00 a.m. – 5:00 p.m.
    (excluding Saturday, Sunday, national holidays and year-end through new year holidays)
12. This Privacy Statement may be amended from time to time. At the time of any amendment, we will publish a revised Privacy Statement in substitution for this webpage.
13. In order to constantly monitor and, where necessary, improve our handling of your personal information we will periodically review this statement and security measures or any other associated activities related to personal data.