Morgan Stanley MUFG Securities Co., Ltd.

Morgan Stanley’s long-standing commitment to safeguard the privacy of information our clients entrust to us is essential to our goal to be the world’s first choice for financial services. Protecting the confidentiality and security of client information has always been an integral part of how we conduct our business worldwide.

We pledge to ensure our global business practices protect your privacy.

Where applicable, more specific privacy policies are posted on the home pages of our individual businesses. This Privacy Policy applies to individuals whose personal information is processed in Japan.

As a Business Handling Personal Information (as defined in the Protection of Personal Information Law (the “Law”)), Morgan Stanley MUFG Securities Co., Ltd. makes this statement in respect of its basic policies concerning the protection of personal information of (1) its clients and (2) other persons involved in securities and other financial products handled by us.

  1. In order to protect your personal information, we will comply with the Law as well as all other applicable laws and regulations guidelines issued by our regulators, this Privacy Policy statement and any other documentation which may govern your relationship with Morgan Stanley.
  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. for performing or soliciting transactions and related services concerning securities or any other financial products handled by us (including buy/sell transactions, intermediating buy/sell transactions, introduction or brokerage services, private and public offerings, underwritings as well as securitizations, leases and other types of structured finance transactions);
    2. for reviewing your suitability for solicitation by us in connection with any of our financial products or services;
    3. 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. 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. for the development of 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. for informing or advising you of performance results and account balances concerning financial products or services offered to you;
    7. for providing market reports to Customers;
    8. for performing operational and marketing activities including customer development;
    9. for researching or developing financial products and services provided by or to be provided by us by using market research, data analysis or customer surveys;
    10. to properly carry out any outsourcing services, if we are requested by a third party to handle part or all of such third party’s personal information; and
    11. for any other purposes in connection with the above purposes to enable us to adequately and smoothly provide our services to you.
  4. We will not obtain from you, use, or provide to a third party, information regarding your political opinions, beliefs (including religious, faith-based and other profound beliefs), trade union membership, race, ethnicity, lineage, domicile of origin, physical or mental health, any information about alleged or committed criminal offences or any other sensitive information except for our proper business management or any other purposes deemed necessary by law.
  5. We may, in whole or in part, share your personal information with our affiliated companies(*) for the purposes set out in Paragraph 3 of this statement. However, we will be responsible for (i) receiving and handling all primary complaints, (ii) decisions on disclosing, correcting and stopping the use of personal information; and (iii) security measures.

    *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 Regulations for the Terms, Formats and Preparation Method for Financial Statements (Ordinance of the Ministry of Finance No.59 of November 27, 1963) and other laws and regulations.
  6. We may outsource all or part of the handling of your personal data to third parties approved by us in order to accomplish the purposes set out in Paragraph 3 above. We will supervise any such outsourcing service provider as necessary to ensure the personal data is secure in accordance with applicable laws and guidelines.
  7. 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 against leaks, loss or damage, etc.
  8. You may request disclosure of the personal information we hold on you, or request the amendment, removal or updating of such personal information by writing to the information desk at the address set out in Paragraph 9 below. After we obtain satisfactory evidence of your identity, we will seek to address your request in accordance with the applicable laws and guidelines.
  9. If you have any questions or comments regarding our security measures in respect of your personal data or regarding this statement, you can contact the Information Helpdesk for Personal Information in the following ways:

  10. Information Helpdesk for Personal Information
    Legal and Compliance Division,
    Morgan Stanley MUFG Securities Co., Ltd.
    Yebisu Garden Place Tower
    4-20-3 Ebisu, Shibuya-ku, Tokyo 150-6008
    Phone: 03-5424-5000
    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)

  11. This statement may be amended from time to time. At the time of any amendment, we will publish a revised statement in substitution for this webpage. In addition, up-to-date hardcopies of this statement are available at the front desk of the eleventh floor of our offices at the address set out in section 9 above.
  12. 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.
  13. We are a member of the Japan Securities Dealers Association (the “JSDA”) which is a Personal Information Protection Authority certified by the Financial Services Agency. The Personal Information Helpdesk of the JSDA accepts complaints and provides counselling services concerning the handling of personal information by JSDA's members.

    Japan Securities Dealers Association, Personal Information Helpdesk
    Tel: 03-3667-8427
    (http://www.jsda.or.jp/)