Effective Date: April 1, 2005

Date of Last Revision: March 13, 2023

Junko Saito

Representative Director

Soken Inc.

Personal Data Protection Policy

Soken Inc. (Soken), an integrated advertising agency specializing in finance, recognizes the importance of protecting personal data. Soken collects, manages, and protects personal data in accordance with JIS Q 15001 Personal Information Protection Management System-Requirements. Soken will review and adjust its practices as necessary to maintain its compliance with these standards, applicable law, and the following basic policies.

Soken collects personal data from clients and employees. We will inform individuals contributing data about how their personal data may be used and with which third parties it may be shared. Soken may share personal data with third parties only within the scope of our business, or to fulfill a specific request from clients or employees, or in compliance with the law or a binding court order. Soken will not otherwise share or use personal data without prior notification and permission.

Soken will share personal data only with service providers that, in Soken’s sole judgment, meet our criteria for managing and protecting personal data.

Soken Inc. will protect personal data with logical safety controls, and pre-emptive and corrective measures against its loss, destruction, and leakage so that clients and employees feel secure providing their data.
Soken will comply with all applicable laws, regulations, and government-promulgated guidelines regarding the protection of personal data.

Soken will regularly review and update our personal data management practices to maintain compliance.

Questions or concerns about personal data at Soken should be addressed to:

Service Representative for Matters Concerning Personal Data

Soken Inc.

San-ai Kayabacho Bldg. 2F, 2-13-11 Nihonbashi Kayabacho, Chuo-ku, Tokyo 103-0025

Tel.: 03-5641-5170

Handling Personal Data

Soken will manage personal data with the utmost caution, as outlined below.

1．Personal Data Protection Manager

The Manager is charged with overseeing the handling and safeguarding of personal data under Soken’s control. Every effort will be made to prevent unauthorized access to; loss, leakage or destruction of; or tampering with personal data.

Questions or concerns may be directed to:

Head of Administration

Soken Inc.

Tel.: 03-5641-5170

2. Using Personal Data

Soken Inc. will use the personal data it collects to:

Manage subscribers’ information on websites Soken operates;

Complete mailings and other subscriber-related services for Soken publications;

Conduct surveys, questionnaires, and the like;

Publicize seminars and events sponsored by or otherwise involving Soken;

Provide credits or citations to accompany names and photos of persons appearing in Soken publications;

Facilitate administrative and accounting functions;

Manage personal data of seminar participants;

Communicate with clients, subscribers, and seminars/events applicants;

Manage HR issues concerning employees;

Communicate with job applicants;

Mediate career changes, and;

Connect IFAs (Independent Financial Advisors) and potential investors;

Improve the quality of the service;

Optimize the content and advertising on the service.

3. Sharing Personal Data

Soken will not share personal data we collect with third parties, except:

When consent has been obtained in advance from the provider of the personal data;

When required by law or binding court order; or

When providing personal data to a subcontractor under paragraph 4 below.

4. Subcontracting Personal Data

Soken may outsource some of our operations to provide better service. Accordingly, Soken may provide personal data to its subcontractors. Soken will select and contract only with subcontractors that demonstrate active data management systems capable of adequately protecting personal data.

5. Disclosing Personal Data

Soken has the right to disclose, amend, append, delete, or cease providing personal data under our control to third parties, excluding information which poses a threat to public safety or the interests of others, or which is subject to deletion under law. (We define “disclose” etc. in paragraphs 5-8 here and below to mean “disclose, amend, append, delete, or cease providing personal data.”)

6. Disclosing Personal Information Upon a Request for Disclosure

Soken will disclose relevant personal data following an individual’s written request to disclose and upon confirmation of that individual’s identity. Despite a written request and confirmation of the requester’s identity, however, personal data will not be disclosed when such disclosure may harm the life, body, property, or other rights and interests of any individual; when disclosure may significantly hinder Soken’s business operations; or when disclosure may contravene other laws and regulations.

7. Confirming Identity

Soken will use its best efforts to confirm the identify of an individual whose personal data we seek to collect, using any or all of the following methods:

Calling a phone number provided by an individual;

E-mailing an address provided by an individual and receiving a reply to Soken, Inc.; and

Confirming the name, address, phone number, and birthday of an individual through publicly available means.

In the case of a proxy, Soken requests the proxy physically visit Soken’s offices and provide either a driver’s license or passport confirming identity.

8. Procedures for Disclosing Personal Data

After confirming an individual’s identity, Soken will mail a “Disclosure Request” form to the individual. Upon receipt of the completed form, Soken will acknowledge receipt and disclosure via telephone or by mailing a document to the responding individual.

Please direct all correspondence regarding personal data to:

Service Representative for Matters Concerning Personal Data

Soken Inc.

San-ai Kayabacho Bldg. 2F, 2-13-11 Nihonbashi Kayabacho, Chuo-ku, Tokyo 103-0025

Tel.: 03-5641-5170