Privacy Principles – Pathology Associates Co. Ltd (“Pathology Associates”) and its affiliates are fully committed to protecting the privacy interests of individuals who provide us with information about themselves and to complying with the requirements of each jurisdiction’s Personal Data Privacy Laws. In doing so, we comply with strict internal standards of security and confidentiality.
Your privacy is important to us. This Online Privacy Policy explains what and how we collect, share, use, and protect your personal information when you visit or use this and other online services offered by Pathology Associates that link to or reference this Privacy Policy (collectively, our “Online Services”). Contact details are provided below.
We take our responsibility to protect the privacy that link and confidentiality of your information, including personal information, very seriously. We maintain physical, electronic and procedural safeguards that comply with applicable legal standards to secure such information from unauthorized access and use, accidental or unlawful alteration and destruction, and other unlawful or unauthorized forms of Processing.
Type of information we collect and how we use it
Pathology Associates obtains your personal information (PI) as may be necessary in the course of undertaking its business.
The types of personal information we collect from you when you visit or use our Online Services include your name, email address, mailing address, telephone number(s), account numbers, limited location information (for example, a zip code), username and password. We may also collect payment card information, Social Security numbers, driver’s license numbers (or comparable), gender and nationality when you provide it directly to us while using our Online Services and where we believe it is reasonably required for ordinary business purposes. In some instances, we create personal information about you, such as records of your interactions with us, and details of your accounts. We do not seek to collect or process sensitive personal information unless it is required or permitted by law; necessary for the detection or prevention of crime; necessary to establish, exercise or defend legal rights; or we have your prior explicit consent.
In addition to the personal information described above, we collect certain information about your use of our online services. The personally identifiable information which we collect at the web site may comprise any or all of the following: i. the IP address of the visitor’s personal computer; the country from which the inquiry is made; the pages visited; the time at which a visit is made and the browser type; and ii. certain personal details of the visitor (these may for instance include his/her name;); contact details; whether the visitor holds any professional licenses, e-mail address and wishes to receive information and if so, what kind of information. This PI information, when collected, is not electronically encrypted. As explained in more detail in our COOKIES POLICY, we and our third-party partners use cookies (as well as web beacons or other technologies) to collect and store this and other information about your visit to, or use of, our online services. We may later associate the usage and other information we collect online with personal information about you, as permitted or required by law.
We sometimes collect information about you from additional online and offline sources including social media (to the extent you choose to make your personal information public) and commercially available third-party sources, such as credit reporting agencies. We may combine this information with the personal and other information we have collected about you under this Online Privacy Policy.
We use and otherwise process the information we collect from you to help us deliver our Online Services; to administer, evaluate and improve our business (including developing new products and services, improving existing products and services, performing data analytics and other research tasks, communicating with you via any means, and performing accounting, auditing and other internal functions); manage our risks; to market our services and products; and to comply with and enforce applicable laws and regulations, relevant industry standards, contractual obligations and our policies. We also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individuals or clients) for various business purposes, where permissible under applicable laws and regulations.
What do we do with the data
We take reasonable steps to ensure that the personal information we process is limited to what we require in connection with the purposes set out in this Policy; it is accurate and, where necessary, kept up to date; and it is erased or rectified without delay if it is inaccurate. From time to time, we may ask you to confirm the accuracy of your personal information.
For some of our Online Services, you can review or update certain account information by logging in and accessing the “My Account” section. If you cannot change the incorrect information online, or you prefer to request changes offline, you can reach us though “Contact Us” form.
We will retain copies in a form that permits identification for as long as we deem necessary in connection with the purposes set out in this PRIVACY POLICY, unless applicable law requires a longer retention period. In particular, we will retain personal information for as long as it is needed to establish, exercise or defend any legal rights.
For your convenience, Pathology Associates offers you the ability to access some of our products and services through mobile applications and mobile-optimized websites. When you interact with us through your mobile device, we collect information such as unique device identifiers, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device. We typically ask your permission before collecting certain information such as precise geolocation information.
Purpose of Use – By providing us personal data (including sensitive data), you accept that your personal data be processed by us for the purposes described in this PRIVACY POLICY.
Personally identifiable information may be used for; (i) Providing advisory and other activities for our clients, to enter into asset management contracts and all other types of contracts with our clients, and to manage those contracts in relation to asset management, asset maintenance, real estate investment and the like; (ii) Administering relationships and related services; (iii) Operational purposes, and statistical analysis (including behaviour analysis); (iv) Conducting market or customer satisfaction research; (v) Providing individuals with information concerning products and services which we believe will be of interest; (vi) Compliance with any requirement of law, regulation, associations, voluntary codes we decide to adopt, or good practice, anywhere in the world; (vii) Confirming and verifying an individual’s identity (this may involve the use of a credit reference agency or other third parties acting as our agents) and to conduct due diligence; and (viii) To actual or potential purchasers of parts of our business, and their respective advisers and insurers, and in relation to the transfer of our contractual rights and/or obligations.
We may also screen against publicly available government and/or law enforcement agency sanctions lists. The detection, investigation and prevention of fraud and other crimes or malpractice. For the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights, Pathology Associates may use your personal information.
If we or any person to whom we disclose personal data otherwise have a right or duty to disclose the personal data or are allowed or compelled by law to do so. For example, financial institutions and payments and messaging service providers may from time to time be required, under subpoena or otherwise, to provide certain transaction information to authorities or other official bodies, whether located in your local jurisdiction or overseas, to assist in the prevention of terrorism, money laundering and other crimes.
Provision to Third Parties – Except where required by law or provided in this Privacy Policy, we will not disclose any individual’s personal information to a third party without the consent of that individual.
Pathology Associates does not allow unaffiliated third parties to collect personal information about your online activities when you visit our online services. Nor do we use personal information collected across non-affiliated websites for the purpose of serving you advertising related to your browsing behavior. If we engage in this practice in the future, we will provide appropriate notice and choice so that you can opt-out of the practice.
For Purpose of Use, we disclose or share personal information among subsidiaries or affiliates of Pathology Associates, their agents, auditors, service providers, regulators, governmental or law enforcement agencies or any person we reasonably think necessary when we believe it will enhance the services we can provide and that your personal data be therefore transferred and processed in countries where the level of protection of personal data is not always equivalent to the level of protection that may be provided in your own country but only in circumstances where such sharing conforms to law, any applicable confidentiality agreements, and our policies and practices. Additionally, we reserve the right to share your personal information in connection with a corporate change including a merger, acquisition or sale of all or any relevant portion of our business or assets.
We disclose information we have about you as required or permitted by law. For example, we share information with regulatory authorities and law enforcement officials when we believe in good faith that such disclosure is necessary to comply with legal requirements.
We share information with third parties where appropriate to protect against fraud or verify or enforce our terms of use, our other rights, or other applicable policies.
From time to time, we enter into agreements with other companies to provide services to us, or to make services and products available to you. If these companies receive your personal information, they are required to safeguard it and only use it for those purposes we specify.
We can share your personal information with any person or entity if we have your consent to do so.
Amendments, Additions and Deletions – In the event that any individual whose personal information we hold wishes us to amend, supplement or delete that information, we will, without delay, after first confirming the identity of the individual making such request, make the relevant change so that the corresponding personal information is in accordance with the facts.
Suspension and Cessation of Use – In the event that any individual whose personal information we hold wishes us to suspend, or cease our use or limit the purpose of the use (for example, to stop sending direct mails, etc.) of that information or to delete the information, or cease providing that information to a third party, we will, without delay, after first confirming the identity of the individual making such request and ascertaining that there is a reason for the request, implement the relevant suspension, limitation , deletion or cessation.
Contact
Procedure
All requests in relation to an individual’s personal information, and any inquiries or complaints regarding the Pathology Associates’ handling of personal information should be made to the following address. Requests, inquiries and complaints shall be made in accordance with the procedures separately stipulated by Pathology Associates. Please note that we may not be able to respond to requests for disclosure and the like unless such procedures are followed.
Level 20, Marunouchi Trust Tower- Main, 1-8-3 Marunouchi, Chiyoda-ku, Tokyo, 100-0005″
E: [email protected]
T: +81-3-6269-3175
Fee
Requests for notification of the purpose of the use of personal information or for the disclosure of personal information held will incur a handling fee of JPY 10,000 per request (inclusive of consumption tax and local consumption tax), which may be paid by bank transfer or other methods.
Authorized Personal Information Protection Organization
We are an association member of the Japan Securities Investment Advisers Association as follows. The Association handles complaints and inquiries in relation to the handling of Personal Information by its members.
Japan Investment Advisers Association
Customer Inquiries for complaints/consultation (for Personal Information)
Tel: +81-3-3663-0505
Office Hours: Monday through Friday from 9:00 am to 5:00 pm (excluding national holidays)