Privacy Policies

Privacy Policy

Deutsche Securities Inc. (the “Company”) aims to be a trusted financial institution for customers, and shall comply with the Act on the Protection of Personal Information (the “APPI”), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures (the “Numbering Act”), Guidelines for Protection of Personal Information in the Finance Sector, and any other relevant laws, regulations and guidelines (the APPI, the Numbering Act and all other laws, regulations and guidelines stated above shall hereinafter collectively be referred to as, the “Laws etc.”) and strive for maintaining accuracy and confidentiality of customers’ personal information by appropriate handling, and management and protection, of such information in accordance with the following policy as well as the Company’s internal rules etc. concerning protection of personal information.

For those who apply or wish to apply for employment (including internships etc.) with the Company, who participate or wish to participate in explanatory recruiting sessions etc., and so on (collectively, the “Employment Applicants etc.”): The Company shall strive for maintaining accuracy and confidentiality of the Employment Applicants etc.’s personal information by appropriate management of such information in accordance with Clause 2 and subsequent Clauses of this Privacy Policy (this “Policy”). In this Policy, when it applies to the Employment Applicants etc., the term “customers” shall be read as the “Employment Applicants etc.,” unless clearly provided, or the context requires, otherwise.

1. Acquisition and Usage of Personal Information

The Company shall acquire customers’ personal information for the purpose of smooth and secure execution of transactions with customers and to offer better products and services in connection with the Company’s following businesses. More specifically, the Company shall utilize personal information within the purposes listed below.

• Financial Instruments Business (to sell/buy securities, agency execution of securities, underwriting of securities transactions, etc.) and other businesses incidental to Financial Instruments Business.
• Businesses which can be carried out by financial instruments business operators under the Financial Instruments and Exchange Act (the “Financial Instruments Act”) and any other laws (other than the businesses listed in the preceding item) and businesses incidental thereto.
• Those businesses other than the above which can be carried out by financial instruments business operators and businesses incidental thereto (including businesses which will be authorized to handle in the future).
• Affairs where use of an individual number (kojin bangou) is permitted under the Numbering Act in connection with the above businesses.
  Purposes of Use

（1）Purposes of use of personal information (except for specific personal information, etc. (tokutei kojin jouhoutou))

• For providing information related to solicitation, sales and service of securities and various financial instruments of the Company under the Financial Instruments Act;
• For accepting application for financial instruments and services, including for opening an account of various financial instruments;
• For performing the obligation of customer identification, etc., under the Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act and any other laws and regulations;
• For making judgment on credit extension /investment, and management of risk associated with credit extensions or investments by the Company;
• For making decisions on applications for financing or on continuation of existing transactions;
• For making decisions for adequacy of provision of financial instruments and services in the light of the principle of suitability etc.;
• For providing personal information to third parties to the extent required for conducting necessary operations for financing businesses;
• For properly performing where all or part of personal information maintenance and processing is outsourced from other parties;
• For exercising rights and fulfilling obligations under agreements and laws, etc.;
• For research and development of financial instruments and services by market research, data analysis, conducting questionnaires and other sources;
• For proposals of various financial instruments and services, including sending direct mails (including analysing information etc. acquired from customers’ transaction records, browsing history of website or by any other way and delivering advertisements concerning financial instruments and services relevant to customers’ interests);
• For soliciting and selling various financial instruments and introducing services related to Deutsche Bank Group companies (the “Group Companies”), affiliates and/or alliance partners of the Company (including analysing information etc. acquired from customers’ transaction records, browsing history of website or by any other way and delivering advertisements concerning financial instruments and services relevant to customers’ interests);
• For necessary administration for cancellation of various transactions and clerical management after cancellation;
• For market research in the Company and research and development of financial instruments and services and sending various research reports, etc.;
• For compliance with laws and regulations of Japan and other countries, risk management, enhancement of services, promotion of internal business and internal control;
• For the purpose of various investigations, analysis and production of documents upon requests by a central or municipal government, an autonomous government, a relevant regulator, tax authority, any other administrative authority, judicial body, stock exchange or self-regulatory body of Japan and other countries.
• For verifying the identity of customers or the agent of customers;
• For reporting transaction results, account balances, etc. to customers;
• For handling necessary operations for transactions with customers;
• For obtaining information necessary to respond inquiries from customers;
• For sending seasonal greetings, etc., and information related to various seminars and receptions, etc.; and
• For any other reasons for the purpose of conducting proper and smooth transactions with customers.

（2）Purpose of use of specific personal information, etc.

• Affairs of application for and filing of opening an account for financial instruments transactions by customers (including affairs of application for and filing of use of small amount investment tax exemption scheme, etc.);
• Affairs of preparing and providing statutory documents for financial instruments transactions of customers;
• Affairs of providing to depository institutions, etc., related to financial instruments transactions by customers;
• Affairs of preparing and providing the payment records of remunerations and fees, etc., related to customers;
• Affairs of preparing and providing the payment records of distribution of dividends and retained earnings and fund interest of customers;
• Affairs of preparing and providing the payment records of use fees, etc., of real estate of customers related to the businesses of the Company;
• Affairs of preparing and providing the payment records of consideration for receipt of real estate, etc., related to customers;
• Affairs of preparation and providing the payment records of fees for trading or mediation of lending of real estate, etc., related to customers; and
• Otherwise, affairs of preparing and providing statutory documents required to enter an individual number by Laws etc.

2. Types of Personal Information to be Acquired

The Company shall acquire customers’ personal information by those methods provided in Clause 3 below. The Company shall not acquire “sensitive information” as provided in the Guidelines for Protection of Personal Information in the Finance Sector except in those cases set forth in the Laws etc. or cases where the Company has obtained customers’ consent to the extent necessary for performing the businesses.

3. Methods of Acquiring Personal Information

The Company shall acquire customers’ personal information to the extent necessary for meeting the purposes of use, and for example, shall acquire from the following sources orally, by electronic mails, in writing or by any other way and in lawful and fair manner.

• Cases where customers directly provide their personal information through the documents etc. to be filled in and submitted by customers (e.g., submission of applications etc. or data input on website etc. by customers themselves), and cases where personal information is acquired from customers and/or their agents etc. orally, by mail, by email, via internet, via telephone, via facsimile etc. (including recording of telephone conversations and monitoring of emails for compliance and security purposes), in connection with offering of products and services.
• Cases where personal information is provided by third parties such as parties of joint use, consumer credit information organizations etc.
• Cases where personal information is acquired in relation to transactions with customers or products and services offered or to be offered.
• Cases where personal information is acquired through the Company’s employees, the Group Companies or other third parties (e.g., placement agencies for recruiting).
• Cases where personal information is acquired from the information contained in publications such as Japan Company Handbook (Kaisha Shikihou), Japan Directors and Officers Handbook (Yakuin Shikihou), from the information contained in copies of commercial registrations, government gazette etc., and from the information publicly available in newspapers or internet etc.

4. Provision of Personal Data*

1. The Company shall not provide customers’ personal data to third parties, except in those cases set forth in the Laws etc.
2. The Company may utilize customers’ personal data jointly with others to the extent provided in Clause 5 below.
3. The Company may outsource handling of personal data to the extent provided in Clause 6 below.
4. The Company may provide customers’ personal data to third parties located in foreign countries. In this case, the Company shall provide necessary information in accordance with the Laws etc. and obtain prior consent from principal, except in those cases set forth in the Laws etc. At the time of obtaining consent from the customer, it might be difficult to specify the name of the foreign countries, or obtain and provide information on their regimes of protecting personal information in an appropriate and reasonable manner, or information on the measures to be taken by the third parties to protect personal information. If the foreign countries where such third parties are located are identified later, the customer may request the Company to provide the aforementioned information. The Company may also provide customers’ personal data to the third parties located in foreign countries who have established a system conforming to standards prescribed by rules of the Personal Information Protection Commission as necessary for continuously taking action equivalent to the one that a personal information handling business operator shall take pursuant to the provisions of the APPI (the “Equivalent Action”). In this case, the Company shall take necessary actions to secure the third parties’ continuous implementation of the Equivalent Action, and customers may request information concerning such necessary actions. However, with respect to any requests for information, the Company may refrain from providing part or all of the requested information if provision of such information may materially interfere with proper operation of the Company’s businesses.
5. When the Company provides personally referable information (kojin kanren jouhou) concerning customers to third parties and expects that such third parties will acquire such Personally Referrable Information as personal data, the Company shall make confirmation and provide information as required by the Laws etc., except in those cases set forth in the Laws etc.

* Personal data includes personal information already acquired and personal information to be acquired with an intention to be treated as personal data.

5. Joint Use of Personal Data

Within the scope of purposes of use above, the Company and the Group Companies listed below may jointly use personal data of customers (excluding specific personal information, etc., the same applies hereinafter in this Clause 5). Privacy Policy of the respective Group Companies in Japan are accessible through the link shown below.

Items of personal data to be jointly used (except for specific personal information, etc.):

• Information related to customers such as name, home address, date of birth, occupation/position description, employer/organizational affiliation, job title, work address, telephone/fax number, e-mail address, information contained in CV/resume, etc.;
• Information related to transactions of customers such as transaction details, balance amount etc.; and
• Information related to customers’ needs, such as those for customers’ asset management, etc.

Scope of the parties of joint use（the Group Companies）：

• Deutsche Bank AG (including Head Office, and Tokyo Branch and other branches)
• DWS Investments Japan Limited
• Deutsche Holdings (Luxembourg) S. ar.l.
• Deutsche Bank Trust Company Americas
• DB Services (New York), Inc.
• Deutsche Bank Securities Inc.
• Deutsche Securities Asia Limited
• Deutsche Securities Australia Limited
• DB Services New Jersey, Inc.
• Deutsche India Private Limited
• Deutsche Knowledge Services Pte. Ltd.
• Deutsche CIB Centre Private Limited
• DB Service Centre Limited
• DB Global Technology, Inc.
• Other subsidiaries and affiliates of Deutsche Bank AG stated in the Annual Securities Report (Yukashoken Hokokusho) submitted by Deutsche Bank AG (Deutsche Bank AG’s Annual Securities Report is available through EDINET website).

Name, address and name of representative of the entity responsible for management of personal data：

• Name: Deutsche Securities Inc.
• Address: Post Code, 100-6171 Sanno Park Tower, 2-11-1 Nagata-cho Chiyoda-ku Tokyo
• Name of Representative: Representative Director  Tamio Honma

Link to Privacy Policies of Group Companies in Japan：

Deutsche Bank AG Tokyo Branch Privacy Policy
DWS Investments Japan Limited Privacy Policy

6. Outsourcing

The Company outsources a part of its operations/activities to external parties/vendors, and within the scope of purposes of use, outsources handling of personal data, for example, in the following cases. The Company shall exercise necessary and proper control over the external parties/vendors to whom it outsources handling of personal data. More specifically, in order to ensure the safety management of customers' personal data, the Company shall perform checks on outsources and conclude necessary agreements with them, and shall take necessary actions as required by the Laws etc. such as monitoring over external parties/vendors’ handling of personal data.
Examples of outsourcing cases:

• Operations concerning preparation, printing, dispatching etc. of various documents
• Transaction-related operations
• Operations which require professional legal, accounting and other advice, etc.
• Operations concerning development, operation and maintenance of information systems and applications etc.
• Operations of preparation and retention of books and documents related to businesses
• Operations of analysis and retention etc. of internal records and data
• Operations of preparation and analysis etc. of data, records, communications, documents etc. relating to internal investigations etc.
• Administrative works supporting operation of the Company’s businesses and administrations concerning dealing with foreign laws and regulations etc.

7. Security Control/Management of Personal Data

The Company takes appropriate security control action to assure that customers’ personal data remains accurate and up to date. The Company shall implement organizational, personnel, physical and technical security management measures to prevent leakage, loss or damages etc. (the “Leakage etc.”) of customers’ personal data and specific personal information. When customers’ personal data is handled in a foreign country, the Company shall take appropriate action by acquiring information on personal information protection system of such foreign country.

8. Disclosure/Correction/Suspension of Use/Elimination etc. Requests from Customers

If customers wish, with respect to their own personal data or specific personal information, to make request for notification of purposes of use, disclosure, correction/addition/deletion, suspension of use/elimination, suspension of provision to a third party or disclosure of records of provision to a third party, please reach to the contact provided below. The Company shall respond in accordance with the Laws etc. upon verification of the identity of the requester. Please understand in advance that fees may be charged on the notification and/or disclosure.
For more details, please contact the Contact provided in Clause 9 below.

9. Contact for Consultation and Complaints from Customers

Contact：

Customers’ request for notification of purposes of use, disclosure, correction/addition/deletion, suspension of use/elimination, suspension of provision to a third party or disclosure of records of provision to a third party of their personal data or specific personal information, contents of the security management measures taken by the Company, and any other inquiries on the Company’s handling of personal information, are accepted at the following contact.

Compliance Department, Deutsche Securities Inc.

Post Code, 100-6171
Sanno Park Tower,
2-11-1 Nagata-cho Chiyoda-ku Tokyo
TEL: +81-3-5156-6000
E-Mail: tokyodsi.personal-info@db.com

Business Hours: 9:00 ~ 17:30
(Closed on Saturday, Sunday, National Holidays, and Year-end/New-year holidays)

10. Authorized Personal Information Protection Institutions

The Company is a member of the following Authorized Personal Information Protection Institutions. Complaints and consultations regarding the Company’s handling of personal information may be directed to these institutions as well.

[Contact for consultation and complaints]

Personal Information Consultation Office, Japan Securities Dealers Association
Tel: 03-6665-6784 (http://www.jsda.or.jp/)

Personal Information Consultation Office, The Financial Futures Association of Japan
Tel: 03-5280-0881 (http://www.ffaj.or.jp/hogodantai/index.html)

11. Amendments

This Policy is subject to change, without prior or individual notice to the extent provided by laws and regulations, due to amendment of laws or regulations or for any other reasons. In such an event, any amendments will be posted on the Company’s website, etc. and will become effective at the time of posting.

12. Compliance with Laws and/or Regulations, Improvements and Enhancements

In order to implement this Policy, the Company will comply with the Laws etc., and will continuously endeavour to improve and enhance the handling of customers’ personal information.

13. Company’s Address and Representative

Address and representative of the Company are as follows.

Sanno Park Tower, 2-11-1 Nagata-cho Chiyoda-ku Tokyo
Representative Director  Tamio Honma

Established: January 1, 2006
Last revised: March 1, 2024