Personal Information Policy (Privacy Policy)

Personal Information Protection Policy (Privacy Policy)

LAETOLI Co., Ltd. (hereinafter referred to as “the Company”) sheds light on “value to be entrusted to the next generation” beyond economic rationality, and as a company that not only creates “free finance” in which anyone can be involved fairly but also creates a prosperously economy era, we recognize the importance of personal information, including customer’s confidential information, and establish the following personal information protection policy.

We will establish compliance including laws and regulations regarding the handling of personal information, guidelines set by the government and other norms, and we will comply with it as a social responsibility.
We will formulate and comply with internal rules that stipulate proper and appropriate handling regarding the acquisition, use and provision of personal information. In addition, we will use the acquired personal information within the scope of the purpose of use and take measures to prevent it from being used for other purposes.
We will take appropriate security management measures and corrective measures against leakage, loss or damage of personal information.
In case there is any complaint or consultation from the identical person regarding the handling of personal information and the personal information protection management system, we will respond in good faith.
We will formulate and implement a personal information protection management system and continuously improve it.

First Edition (Enactment) January 1, 2022
LAETOLI Co., Ltd.
Representative Director Ya Muto

［Complaint / consultation and inquiry counter］（Limited to personal information）
〒107-0062
2-26-1, Minami Aoyama, Minato-ku , Tokyo
D-LIFE PLACE Minami Aoyama 2F
LAETOLI Co., Ltd.　PMS Office
Phone : 03-6721-1401
Email：info@laetoli.jp

About the handling of personal information

We announce the handling of the acquired personal information as follows.

【Ⅰ】The purpose of using personal information

Type of personal information	Purpose of use	Disclosure classification
Personal information entrusted by the fund management company (first operator) in the course of entrusted business	Execution of contract work	Not object
Personal information of those who wish to register as a member	Account Authorization Related Contacts.	Object
Personal information of registered members	Guide to Investor Registration Learn about our funds Subscribe to our e-newsletter Related communications For research and development of financial products and services handled by the Company and its business partners through market research, data analysis, implementation of questionnaires, etc. To propose financial products and services handled by the Company and its business partners by sending e-mails, direct mails, etc., and to send various mailings, etc.	Object
Personal information of those who have requested to register as investors	identification Verification of identity (including sensitive personal information) Examination Related communications For research and development of financial products and services handled by the Company and its business partners through market research, data analysis, implementation of questionnaires, etc. To propose financial products and services handled by the Company and its business partners by sending e-mails, direct mails, etc., and to send various mailings, etc	Object
Personal information of funds participants	Acceptance of applications for funds Tax processing Provision of information to the desired fund management company (first operator) Payment of redemptions and dividends Preparation of list of project participants (legal compliance) Related communications	Object
Identification information obtained from partners	Matching with our member information. Identification of our partners	Object

【Ⅱ】Matters related to retained personal data

Our company name: Address and Representative name It is described in “Privacy Policy”. (The address is the same as the “Complaints, Consultations and Inquiries Desk”)
Job title of personal information protection manager：　Business management department manager
（Contact email: info@laetoli.jp）
Purpose of use of each personal information
This applies to items for which the “Disclosure classification” in [I] is “Object”.
Authorized Personal Information Protection Organization
The authorized personal information protection organizations that our company is a member of are listed in [III].
Procedures for requesting disclosure, etc. of retained personal data or disclosure of records provided to third parties
Please contact the personal information protection manager at item (2) for any complaints and requests for disclosure regarding the handling of retained personal data (notification of purpose of use, disclosure, correction / addition or deletion, suspension / deletion of use or provision to third parties) or disclosure of records provided to third parties. We will explain the procedure for requesting complaints and disclosure.
Measures taken for the secure management of retained personal data
We have taken the following measures for the secure management of personal data in our possession.
- Establishment of Rules for Handling Personal Data
  The Company has established internal rules and procedures for the handling of personal data when acquiring, using, and storing personal data.
- Organizational security control measures
  In addition to appointing a person responsible for the handling of personal data in each department, the Company has in place a system whereby the responsible person confirms, through self-inspection and internal audits, that employees are handling personal data in accordance with the established handling procedures.
- Personnel Safety Control Measures
  All employees are required to submit a written pledge to comply with company regulations, and training is conducted each term on personal data handling procedures and information security considerations.
- Physical Safety Control Measures
  The Company locks its offices and confidential areas, and takes measures to prevent the theft or loss of equipment, electronic media, and documents that handle personal data.
- Technical Safety Control Measures
  The Company clarifies the equipment that can handle personal data and the employees who handle such equipment to prevent unnecessary or unauthorized access to personal data.
- Supervision of entrusted contractors
  We evaluate our contractors to whom we entrust personal data on a periodic or timely basis to ensure that they have implemented security control measures that exceed our level of security control measures.
- Understanding the External Environment
  We do not provide personal data to third parties located in foreign countries.
Please contact the personal information protection manager (2) for any complaints and requests for disclosure, etc. (notification of purpose of use, disclosure, correction / addition or deletion, suspension / deletion of use or provision to third parties) regarding the handling of personal information subject to disclosure. We will explain the procedure for requesting complaints and disclosure.

【Ⅲ】Matters related to complaints and inquiry

We accept complaints and inquiries regarding personal information. Please contact the inquiry counter listed in the “Privacy Policy”.
The authorized personal information protection organizations that our company is a member of are as follows.

Name of the authorized personal information protection organization: Japan Users Association of Information Systems (JUAS)
Contact for resolution of complaints: Secretariat of Authorized Personal Information Protection Organizations　Complaint Consultation Office
Contact address
Address　　　7th Floor, Nihonbashi Horidomecho 2-chome Building, 2-4-3 Nihonbashi Horidomecho, Chuo-ku, Tokyo
Telephone number　03-3249-4104 *This is not a contact for inquiries regarding our products or services.

The Japanese version shall always prevail in case of any discrepancy or inconsistency between Japanese version and its English translation.