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• Japannext Co., Ltd. assumes no responsibility for trouble that may occur from information originating from the website, from the actions of contracted users, from the operations and services contracted between users, or from other contracted content.

We hereby establish and announce this Declaration of Personal Information Protection (“Declaration”), which sets forth our policies for our clients’ personal information and Individual Number (hereinafter collectively referred to as “Personal Information etc.”).

1. Compliance with Applicable Laws and Regulations

In addition to the matters set out in this Declaration, we will comply with all applicable laws and regulations, government guidelines, and guidelines by the recognized personal information protection organizations, with respect to the proper handling of Personal Information etc.

2. Purposes of Use of Personal Information

Unless otherwise agreed to between us and our clients or in exceptional circumstances required by applicable laws and regulations, we will only use our clients’ personal information in accordance with the purposes set out below. Individual Number will only be used for specific purposes prescribed by law.

As a PTS business (including any incidental businesses) operator (as provided under Article 2-8-10 of the Financial Instruments and Exchange Act), there are situations where it is necessary for us to collect Personal Information etc. for the purpose of ensuring the effectiveness of our operations.

• sales/solicitation of, and the carrying out of service guidelines regarding securities and financial products, pursuant to the Financial Instruments and Exchange Act;
• to process the client’s application for financial products and services such as opening of an account;
• to confirm the client or its agent’s eligibility;
• to inform the client of the transaction results etc.;
• to carry out transactions related administrative procedures;
• to carry out any other actions necessary for the adequate and smooth performance of our services; and
• notwithstanding the above, Individual Numbers will only be used for the purposes of creating or submitting legal documents concerning financial products transactions

The principal sources of personal information are as described below:

• information from an account application form, questionnaires etc. completed by our clients
• information provided by our clients in the course of the provision of services

3. Secure Management of Personal Information

We will endeavor to ensure that our clients’ Personal Information etc. is always kept accurate and up to date. Further, in order to prevent any leakage of our clients’ Personal Information etc., we will take all necessary and appropriate security measures as described below, as well as exercising appropriate supervision over all officers, employees and any external outsourcing service providers.

(Development of Disciplines on the Handling of Personal Data)

• Establish the handling rules of personal data including the roles and responsibilities of the person handling personal data, the limitation on the number of the persons handling personal data, and procedures etc. necessary for security control of personal data, at each stage of acquisition and input, use and processing, storage and retention, transfer and sending, and deletion and disposal of data

(Institutional Security Control Measures)

• Appoint a person responsible for handling of personal data, clarifying employees handling personal data and the range of personal data handled by such employees, and developing a system for reporting to a person responsible in the event that information leakage etc. is found
• Implement regular self-inspections and internal audits of the handling status of personal data

(Personnel Security Control Measures)

• Implement regular training for employees about consideration when personal data is handled
• Describe the matters about confidentiality of personal data in rules of employment

(Physical Security Control Measures)

• Prevent unauthorized persons from viewing personal data in areas handling personal data and implement entry and exit control for employees in areas installing a computer system etc. to store personal data
• Take measures to prevent theft or loss of equipment, electronic media, and documents that handle personal data

(Technological Security Control Measures)

• Limit persons handling personal data and the range of personal information database etc. handled by such persons through implementing access control
• Introduce a mechanism to protect information systems that handle personal data from unauthorized access from outside sources or malicious software

(Understanding of External Environment)

• When handling personal data in a foreign country, understand the system regarding protection of personal information in such country and take necessary and appropriate measures for the safety management of personal data

4. Continuous Improvement

We will endeavor to review this Declaration on a regular basis and to make continuous improvements with the purpose of ensuring the appropriate handling of our clients’ Personal Information etc.

5. Disclosure of Information

We will endeavor to address adequately and promptly, after obtaining satisfactory evidence of an individual’s identity, our clients’ request for disclosure of the personal data we hold on them, correction, suspension of use of such personal data, or disclosure of a record of provision of such personal data to a third party.

Further, we will answer on whether we possess Individual Numbers if requested to disclose it.

6. Sharing of Personal Information

We may share our clients’ personal information with our associated company, SBI Holdings, Inc., as well as the subsidiary companies listed in the annual securities report of the associated company, for the purposes of exercising appropriate management and internal control such as compliance and risk management. Personal information that may be shared includes information concerning an individual’s name, address, telephone number and occupation.

The person who is responsible for managing such personal data is below:

Japannext Co., Ltd.
3-1-1 Roppongi, Minato-ku, Tokyo
Representative: Masakatsu Yamada

7. Inquiries and Complaints Handling

We will endeavor to address our clients’ inquiries, comments or complaints regarding our handling of Personal Information etc. promptly and appropriately. Please contact our Compliance Department on 03-4577-4040 for any queries, comments or concerns that you may have.

8. Recognized Personal Information Protection Organization

We are a member of the JSDA, which is recognized by the Personal Information Protection Commission as a personal information protection organization. The enquiries and complaints desk of the JSDA accepts complaints and provides consultation services concerning the handling of personal information, pseudonymized personal information, and anonymized personal information by JSDA’s members.

Complaints and Consultation Helpdesk

Japan Securities Dealers Association
Personal Information Consultation Office
TEL: 03-6665-6764
URL: https://www.jsda.or.jp/

Revised on 1 April 2023

This best execution policy stipulates the policy and method for executing orders from our trading participants (Type I Financial Services Providers) (“trading participants”) on the best possible terms in accordance with Article 40-2, Paragraph 1 of the Financial Instruments and Exchange Act (“FIEA”).

When Japannext (“we”) receives orders from the trading participants involving securities listed on the financial instruments exchanges (“FIEs”) in Japan, we will endeavor to execute the orders in accordance with this policy to the greatest extent possible.

1. Applicable Securities

“Listed share certificates, etc.” as defined in Article 16-6 of the Enforcement Ordinance of the FIEA, which includes shares listed on FIEs, exchange-traded funds (ETFs: beneficiary certificates of investment trust linked to equity indexes), real estate investment trusts (REITs), etc.

We do not perform transactions for Phoenix stocks, Convertible bonds, etc. which are defined in Article 67-18, Item (iv) as tradable securities.

2. Method for Executing Orders on the Best Terms

It is our fundamental policy to execute all orders from the trading participants on a private proprietary trading system (“Japannext PTS”) operated by us in accordance with our internal trading rules, i.e. the order we received from the trading participant will be matched with the other order we received from said participant or with the order received from a different trading participant and executed on the Japannext PTS. We will not conduct agency brokerage of the orders from the trading participants to a FIE in Japan or the PTS operated by other financial services providers. Accordingly, any unexecuted orders will be automatically cancelled.

3. Reason for Selecting the Method Stated in 2.

We mainly operate the PTS and we never conduct agency brokerage of purchase and sale of securities to FIEs in Japan or PTS operated by other financial services providers. We endeavor to assist our trading participants in understanding this as well as our PTS Trading Instructions and PTS Terms of Business. We anticipate that the order we receive from the trading participants will be matched and executed on our PTS and we believe that the trading participants would consider this as the most reasonable method of matching and execution that meets their needs.

4. Others

We will not process transactions involving fractional shares or transactions with an amount less than one trading unit (i.e. an odd lot).
There may be instances in which it is unavoidable that we select an order execution method other than the method selected in accordance with this best execution policy due to system failures or other circumstances. In such cases, we will nevertheless endeavor to execute orders on the best terms possible at that given time.

The obligation of best execution not only relates to price but involves the consideration of various factors including cost, speed and probability of execution. Accordingly, the mere fact that an execution appears not to have resulted in the best possible price afterwards will not necessarily constitute a contravention or violation of said obligation.