September 2019

Global X Japan Co., Ltd.

In accordance with the Act on the Protection of Personal Information in Japan, we set forth the privacy policy as follows, observe it, and appropriately handle personal information and anonymized processing information.

  1. We consider personal information to be an important asset of individuals and recognize that proper protection of personal information is an important responsibility. To fulfill this responsibility, we will comply with laws, regulations, guidelines, internal rules, and other norms relating to the protection of personal information.
  2. We will not use personal information beyond the scope necessary for the achievement of the purpose of use of personal information unless the purpose of use is specified and the prior consent of the person in question is obtained or permitted by law or ordinance.
  3. We will acquire personal information through appropriate and legal means to the extent necessary to achieve the purpose of use.
  4. We will implement the necessary safety management measures and appropriately manage personal information to prevent leakage and loss.We will also educate and supervise employees regarding the handling of personal information.
  5. When handling personal data is consigned, we shall supervise the consignee as necessary and appropriate.
  6. In accordance with changes in laws and regulations, we will review this Privacy Policy as necessary and strive for continuous improvement.
  7. We will endeavor to respond appropriately and promptly to requests for disclosure, corrections, or suspension of the use of personal data held by the Company.
  8. We strive to respond sincerely and promptly to questions, opinions, and complaints regarding the handling of personal information.
  9. We will appropriately manage anonymized processing information by taking necessary measures according to the handling of personal information.

Handling of Personal Information

Intended use of personal information

We use personal information to the extent necessary to achieve the following purposes.

  1. For the purpose of conducting market research to provide better products and services for the purpose of providing information and services based on inquiries and requests from customers, and for the purpose of meeting the requirements stipulated in laws and industry rules as necessary, we acquire individual addresses, names, telephone numbers, email addresses, etc., and hold them as personal data.
  2. In order to ascertain the contact information of government agencies, relevant industry associations, business partners, and other parties that need to be contacted in the course of daily operations, the Company properly obtains the name of the person in charge, his or her department, telephone number, email address, and personal history of the representative in accordance with business practices and retains such information as personal data.
  3. For the purpose of security measures, we acquire images of visitors using surveillance cameras and hold them as personal data.
  4. For the purpose of employment management, the Company obtains personal information of officers and employees, etc. and holds it as personal data. In addition, for the purpose of personnel recruitment activities, the Company obtains personal information of applicants and holds it as personal data.

The personal information described above may be acquired and retained as personal data, if necessary, by specifying the purpose of use individually and by taking measures such as obtaining the consent of the person in question.In addition to the above, personal information may be acquired and held as personal data as incidental information through various media and other channels, as well as conducting surveys on the eligibility of sales companies, outsourcing partners, business partners, and other business partners required for business operations, as well as collecting information on the times, business environment, economic conditions, and other matters.

Proper Acquisition of Personal Information

We acquire personal information to the extent necessary for our business operations.

Furthermore, we shall not acquire, use, or provide to a third party information concerning sensitive information (excluding information that is disclosed by the person in question, a national institution, a local government, or any other person listed in laws and regulations, or it is obvious from the appearance of the information obtained by viewing or shooting the person), except as permitted by laws and regulations, concerning personal information that should be considered for personal information, family origin, legal domicile, health and medical care, and sexual life (excluding any information that falls under the category of personal information requiring consideration).

Proper Management of Personal Information

We will endeavor to prevent leakage, loss, falsification, unauthorized access, etc., of personal information, take necessary safety management measures, and appropriately manage such information.

Disclosure and Provision of Personal Data to Third Parties

We will not disclose or provide personal data to any third party without prior consent of the customer, except in the following cases or where permitted by law or ordinance.

  1. Cases in which the consent of the person in question has been obtained
  2. Cases based on laws and regulations
  3. Cases in which the provision of personal information is necessary to protect the life, body, or property of an individual and in which it is difficult to obtain the consent of the person
  4. When it is particularly necessary for the improvement of public health or the promotion of sound growth of children and it is difficult to obtain the consent of the Identical Person
  5. Cases in which it is necessary to cooperate with a state organ, local government, or a person entrusted by either of them in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned
  6. Where the provision of personal data (excluding sensitive information) that is provided to a third party is to be discontinued at the request of the Person and where the provision of such personal data (excluding sensitive information) as may lead to the identification of the Person is to be discontinued and where the Person notifies the Person of the necessary matters in advance or put the matters in a readily accessible condition for the Person and notifies the Personal Information Protection Committee thereof

Disclosure and Provision of Personal Data to Third Parties in Foreign Countries

We will not disclose or provide personal data to a third party (excluding those who have a system in place that complies with the standards provided by laws and regulations as necessary for the continuous implementation of measures equivalent to those required by laws and regulations with regard to the handling of personal data) in a foreign country (excluding those who have a system that protects personal information that is recognized to be at the same level as Japan in protecting the rights and interests of individuals) without obtaining the prior consent of the person, in the following cases and other cases, unless permitted by laws and regulations.

  1. Cases in which the consent of the person in question has been obtained
  2. Cases based on laws and regulations
  3. Cases in which the provision of personal information is necessary to protect the life, body, or property of an individual and in which it is difficult to obtain the consent of the person
  4. When it is particularly necessary for the improvement of public health or the promotion of sound growth of children and it is difficult to obtain the consent of the Identical Person
  5. Cases in which it is necessary to cooperate with a state organ, local government, or a person entrusted by either of them in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned

Delegation of personal data

We may subcontract all or part of the operations and provide the necessary personal data to the subcontractor in order to smoothly carry out the operations required to achieve the Purpose of Utilization.In the event of consignment, the Company shall supervise the consignee in a necessary and appropriate manner, including supervising the sub-consignee.

Shared use of private information

We may share the personal data of investors as follows..

  1. Information about investors such as the names, addresses, dates of birth, telephone numbers, email addresses, etc., occupations, and transaction needs of the personal data to be used jointly
  2. Scope of co-users Global X Management Company, Inc., Daiwa Asset Management Co. Ltd., Daiwa Securities Group Inc., our related companies, and Global X Management Company LLC, a subsidiary of Global X Management Company, Inc.
  3. Purpose for shared use For management and internal control

Person responsible for the management of the personal data concerned Global X Japan Co. Ltd.

Disclosure, Correction, Suspension of Use, etc. of Personal Data

In the event that a request for disclosure is made by the person in question or his or her agent for disclosure, correction, non-use, etc. (hereinafter referred to as ""disclosure, etc.""), we will respond in writing within a reasonable period of time and within a reasonable scope after confirming that the request is made by the person in question and after confirming that disclosure is not required under laws, regulations, etc.

Acquisition of Personal Information, etc. by a Method Not Easily Identifiable by the Person

When you visit our website, certain pieces of personalized data may be automatically collected using techniques and methods such as Cookie.

Handling of anonymous processing information

Preparation, etc. of Anonymized Processing Information

We do not create anonymous processing information.

Provision of anonymized processing information to a third party

When providing anonymized processing information to a third party, we shall publicize the items of information to be provided and the method of provision in advance, and shall clearly indicate to the recipient that the information is anonymized processing information.

Act to identify the anonymized processing information

When using the anonymized processing information, we shall not acquire information such as processing methods or collate it with other information for the purpose of identifying the principal pertaining to the original personal information.

Questions, opinions, and complaints regarding the handling of personal information and anonymized processing information

Our reception desk

We strive to respond sincerely and promptly to questions, opinions, and complaints regarding the handling of personal information and anonymized processing information.For questions on the handling of personal information and anonymous processing information, please contact the following reception desk.

[Contact for inquiries]

info@globalxetfs.co.jp

Authorized personal information protection group

We are a member of the Investment Trusts Association of Japan and the Japan Investment Advisers Association, both of which are approved by the Personal Information Protection Committee.The Investor Counseling Office of the Investment Trust Association and the Complaint Counseling Office of the Japan Investment Advisory Association receive complaints and consultations on the handling of personal information and anonymous processing information of members.

[Complaints and Consultation Desk]

Investor Consultation Office, The Investment Trust Association

Telephone Number 03-5614-8440

Complaint Consultation Office, Japan Investment Advisers Association

Telephone Number 03-3663-0505