Privacy Policy

Daiwa SB Investments (USA) Ltd. (the “Company”) sets forth its privacy policy as follows.

  1. The Company considers personal information as individual property, recognizes its appropriate protection as an important responsibility, and complies with applicable U.S. laws and regulations and the Company’s internal rules, with respect to the handling, use and disclosure of personal information.
  2. The Company will specify the purpose of use of personal information, and will not use personal information by exceeding the extent necessary to accomplish the purpose of such use unless when there is prior written consent of the individual or where such use is permitted by applicable laws and regulations.
  3. The Company will obtain personal information to the extent necessary for the Company’s business use in an appropriate and lawful manner.
  4. The Company will seek to prevent disclosure of personal information. The Company will conduct, from time to time, training to educate employees as to the handling of personal information.
  5. The Company will implement appropriate supervision and oversight with respect to third parties who are entrusted with the handling of personal data.
  6. The Company will review this privacy policy from time to time, including with respect to a change in laws and regulations applicable to such policy.
  7. The Company will seek to respond promptly to a request for disclosure, correction, deletion, and discontinuation of use regarding retained personal data.
  8. The Company will seek to respond promptly respond to inquiries, requests, and complaints, regarding the handling of personal information.

Handling of Personal Information

  1. Purpose of Use of Personal Information
    The Company does not expect to be using personal information in the normal course of operation, but may do so for any one or more possible business reasons.

  2. Acquisition of Personal Information
    The Company may acquire personal information from the following sources to the extent necessary for its business.

    1. Documents prepared by an individual, such as a questionnaire.
    2. The data directly entered by the person, such as online inquiries on the website.
  3. Management of Personal Information

    The Company will not disclose or provide to third parties any personal data of an individual without their prior consent, except for when it is based on laws and regulations and when we may entrust personal data to third parties to the extent necessary for business purposes, and when it is permitted by laws and regulations.
  4. Provision of Personal Data to Third Parties

    The Company will maintain appropriate security to seek to prevent loss, alteration, improper access or the like regarding personal information.
  5. Entrustment of Handling of Personal Data

    The Company may entrust all or a part of the personal data in its possession to third parties to the extent necessary for business purposes. In the case of such entrustment, the Company will supervise the entity entrusted with such data.
  6. Joint Use of Personal Data

    The Company may share personal data jointly with its affiliates for internal administration subject to the terms of this policy.
  7. Disclosure, Correction, Deletion, Discontinuation of Use, Etc. of Personal Data

    When the disclosure, correction, deletion, discontinuation of use or the like regarding retained personal data of an individual are sought in a disclosure requested in writing by such person himself/herself or his/her agent, the Company will respond in writing within a reasonable period and to a reasonable extent except for the case where, based on laws and regulations such disclosure etc. is not required.
  8. Inquiry, Request, Complaint, Etc. About Handling of Personal Information

    The Company will endeavor to sincerely and promptly respond to inquiries, requests, complaints, regarding handling of personal information.

Disclaimer

Daiwa SB Investments (USA) Ltd. is an investment adviser registered with the U.S. Securities and Exchange Commission. For institutional or professional investors only.