Terms of Use


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Privacy POLICY

This statement sets out our policy concerning the protection of personal information (including “Individual Number” provided under the Social Security and Tax Numbers Act (the “My Number Act”)) of our clients as webelieve it is our social responsibility to handle such information with due care.

1. Compliance with Applicable Laws and Regulations

The Company will suspend or limit all or part of a transaction whenever any of the following events arise:
In addition to the matters set out in this statement, 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.

2. Purposes of Use of Personal Information

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 for the purpose of ensuring the effectiveness of our operations.

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.

  • 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 and account balances;
  • 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 (i) setting up an account for financial products transactions; and (ii) creating or submitting legal documents concerning financial products transactions.
3. Secure Management of Personal Information

In addition to the above provisions, the Company may suspend or limit all or the part of a transaction if any of the following events arises, irrespective We will endeavor to ensure that our clients’ personal information is always kept accurate and up to date. Further, in order to prevent any leakage, loss and damage to our clients’ personal information, we will take all necessary and appropriate security measures, as well as exercising appropriate supervision over all officers, employees and any external outsourcing service providers.

4. Continuous Improvement

We will endeavor to review this statement on a regular basis and to make continuous improvements with the purpose of ensuring the appropriate handling of our clients’ personal information.

NOTE: *Personal Information* means personal information with the exclusion of Individual Number.

5. Disclosure of Information

Our clients may request disclosure of the personal information we hold on them, or request the amendment,
removal or updating of such personal information. After obtaining satisfactory evidence of an individual’s
identity, we will endeavor to address our client’s request adequately and promptly.

We will comply with our obligation to address any inquiries regarding our possession of Individual Numbers.

6. Sharing of *Personal Information*

We may share our clients’ personal information with our parent company, SBI Holdings, Inc., as well as the subsidiary companies listed in the annual securities report of our parent 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. For the avoidance of doubt, we still bear the responsibility of managing such personal information.

7. Inquiries and Complaints Handling

We will endeavor to address our clients’ inquiries, comments or complaints regarding our handling of personal information promptly and appropriately. Please contact our Compliance Department on 03-4577-4048 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 FSA as a personal information protection organization.
The Personal Information Helpdesk of the JSDA accepts complaints and provides consultation services
concerning the handling of *personal information* by JSDA’s members.

Complaints and Consultation Helpdesk

Japan Securities Dealers Association
Personal Information Liaison Office
TEL: 03-3667-8427
URL: www.jsda.or.jp

Revised on 5 October 2015


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.