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Winton Capital Japan Co. Ltd. (the “Company”) will comply with laws and/or regulations concerning the protection of personal information, and will use its best endeavors to handle and protect personal information in accordance with the guidelines set out below.

Procurement of Personal Information

The Company will procure personal information in a lawful and fair manner and to the extent required for its business. 

Purpose of Use of Clients’ Personal Information

The Company will use personal information to the extent required to achieve the following purposes:

  • to aid in the Company’s provision of services concerning investment management business for qualified investors, investment advisory/agency business and ancillary businesses thereto to its clients;
  • to determine the suitability of securities and services for clients;
  • to administer and manage transactions with clients;
  • to perform the Company’s identification duties under the Law for Prevention of Transfer of Criminal Proceeds, Foreign Exchange and Foreign Trade Control Law, or any other related laws and/or regulations and to otherwise confirm the identity of the individual;
  • to introduce products or services provided by group companies;
  • to conduct market research;
  • to provide proposals (by sending direct mails, etc.) for services, etc.;
  • to comply with foreign or domestic laws and/or regulations and comply with requests from foreign and domestic government agencies and courts;
  • to send greetings, information on presentations and seminars, newsletters, or other notifications relating to the Company;
  • to properly implement outsourced services which are outsourced by other business operators in connection with all or a part of the handling of personal information;
  • to enforce rights or perform duties based on contracts with clients; and
  • to otherwise enable the Company to perform its business in a smooth and proper manner.

Sharing Personal Information among Group Companies

To the extent necessary for the purposes mentioned above, the Company and its related Group Companies (including Winton Group Limited, Winton Capital Management Limited, Winton Fund Management Limited, Winton Capital US LLC, Winton Capital Asia Limited and Winton Capital (Cayman) Limited) may share a client’s personal information such as the name or contact point of the person in charge.  In such cases, the Investment Operations Department shall have the responsibility of administering the sharing of personal information.

Management of Personal Information

  • The Company will take commercially reasonable measures to keep the personal information of its clients accurate and updated.
  • The Company will not provide personal information of the Company’s clients to third parties (excluding related Group Companies) without the clients’ consent unless there is a valid reason such as required disclosure under relevant laws, or to engage external service providers to address the Company’s business needs within the scope of the “Purpose of Use of Clients’ Personal Information” as set forth above.
  • The Company will take commercially reasonable measures to prevent unauthorized access to personal information of the Company’s clients.
  • The Company will keep its executives and employees informed on the necessity to protect personal information of the Company’s clients.
  • The Company will take commercially reasonable measures to ensure that its external service providers handle any personal information of the Company’s clients with materially the same level of care as the Company. 

Purposes for collection personal information

Winton may use the information held about you to:

  • Provide you with information about Winton’s products, services, research or events;
  • Assess your suitability for products or services;
  • Process your subscription documents;
  • Fulfil any contract between you and Winton;
  • Fulfil any legal, regulatory or self-regulatory requirement that applies to Winton and/or any member of the Winton group of companies;
  • Process your job application and assess your suitability for a vacancy with Winton;
  • Ensure that the Site is effectively presented for you and for your computer or device;
  • Administer the Site; and
  • Respond to any enquiry or complaint raised by you.
  • Winton may also combine any information that you provide with the information received from other sources. This combined information may be used for the purposes set out above.

Requests from Clients

If the Company receives a request for the disclosure, correction, suspension of use, deletion, etc. with respect to personal information from a client, the Company will, unless there is a valid reason otherwise, respond as soon as reasonably practicable to such request once the Company has confirmed that the request is actually being made by the client himself/herself.

Publication of Privacy Policy and Amendments

Hard copies of this Privacy Policy are available to the public at the Company’s Office.
This Privacy Policy may be amended by the Company in its sole discretion to comply with amendments to relevant laws and regulations, etc.

Contact for Handling Personal Information

Winton Capital Japan Co. Ltd.
Investment Operations Department
Telephone: 03-6250-8830 (Main)
Hours: 9:00 to 17:00 (except for Saturday, Sunday, national holidays and year-end and New Year holidays)