Japan Privacy Policy

BLOOMBERG TRADEBOOK ® Japan Ltd. (“Bloomberg Tradebook Japan”) respects the privacy rights of our users and is strongly committed to protecting your privacy online. This Privacy Policy applies to information collected through this web site (“this Site”) and other Bloomberg web sites and products or services as expressly indicated by Bloomberg Tradebook Japan, including by providing a link to this Privacy Policy or otherwise displaying these terms. You represent, warrant and covenant that you are at least eighteen (18) years or the age of majority in your jurisdiction, whichever is older.

Information We Collect

Bloomberg Tradebook Japan or a designated service provider collects information through this Site, such as during registration, when you request certain services or products, or submit information to enter a sweepstakes, contest, or other promotion, or complete a survey or poll. This information includes personal information such as name, phone number, and e-mail address.

Do not provide information about others unless you are authorized to do so and consent to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting the information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

Bloomberg Tradebook Japan or a designated service provider may use “cookies”, web server logs, web beacons, or other electronic tools to collect information about you, such as your IP address, browser type, language, operating system, computer platform, and the state or country from which you accessed this Site. Bloomberg Tradebook Japan or a designated service provider may also use cookies, web server logs, web beacons, or other electronic tools to collect and compile statistical and other information about your use of this Site and other websites and the services provided on this Site, such as the web pages visited, the date and the time of your visit, the web sites you visited immediately before and after visiting this Site, the number of links you click within this Site, the functions you use on this Site, the databases you view and the searches you request on this Site, the data you save on or download from this Site, etc.

A cookie is a small text file placed on your computer. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The help function on most browsers contains instructions on how to set your browser to notify you before accepting cookies or to disable cookies entirely. However, note that this Site will not function properly if you disable cookies.

How We Use and Disclose Your Information

Bloomberg Tradebook Japan uses the information collected through this Site, including personal information and information about your use of this Site, to enhance your experience with this Site, analyze web site usage, analyze use of the Site, communicate with you, enforce any terms of service or other agreement related to the Site, and provide you with services or products that you request. Bloomberg Tradebook Japan and its affiliates may also use the information collected through this Site to provide special offers and promotions. You may instruct Bloomberg Tradebook Japan at any time not to use your personal information collected in connection with the product you requested to provide you with special offers and promotions by sending us an e-mail message at: privacy@bloomberg.com and include Bloomberg Tradebook Japan in the subject line. Your choice does not apply to any other Bloomberg products or services to which you may subscribe or purchase. Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Please also note that these processes make take some time to complete, consistent with applicable law.

To assist us with the uses described in this privacy policy, information we or our designated service providers have collected about you through this Site, including your use of this Site, may be enhanced with other information about you that we have from other sources.

Bloomberg Tradebook Japan may disclose your personal information to affiliates (including affiliated websites and other products under common ownership or control) and our service providers. Bloomberg Tradebook Japan may disclose to other third parties, information about your use of this Site and the services provided on this Site or other websites, but only in an aggregated and unattributed manner. Bloomberg Tradebook Japan may also share your personal information collected in connection with the product you requested collected through this Site with a sponsor or other third party (“Third-Party Providers”) that provides you with special offers or promotions that may be of interest to you. You may instruct Bloomberg Tradebook Japan at any time not to share your personal information collected in connection with the product you requested with such Third Party Providers by contacting privacy@bloomberg.com and include Bloomberg Tradebook Japan in the subject line. Please note that (i) this process may take some time to complete, consistent with applicable law; and (ii) even after such process is completed, your personal and other information may continue to be shared with our affiliates (including affiliated websites and other products under common ownership or control) and designated service providers.

Bloomberg Tradebook Japan may also disclose your information to unaffiliated third parties if we believe in good faith that such disclosure is necessary: (a) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (b) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (c) to protect the interests, rights, safety, or property of Bloomberg Tradebook Japan or others; (d) to enforce any terms of service on this Site; (e) to provide you and the other users of this Site with the services or products requested by you and/or the other users (including allowing a purchaser of Bloomberg Tradebook Japan to continue to serve you), and to perform other activities related to such services and products, including billing and collection; (f) to provide you with special offers or promotions from Bloomberg Tradebook Japan that may be of interest to you; or (g) to operate Bloomberg Tradebook Japan’s systems properly.

The collection, further use, and/or disclosure of your information by Third Party Providers or by other third parties is not the responsibility of Bloomberg Tradebook Japan. Rather, such collection, use, and/or disclosure is governed by the third parties’ privacy policies.

Accuracy and Security of Personal Information

Any of your personal information collected by Bloomberg Tradebook Japan through this Site is kept on secure servers. Bloomberg Tradebook Japan uses reasonable administrative, technical, personnel, and physical measures to protect your personal information on such servers.

Accessing and Updating Your Personal Information

To access, review, rectify, or delete personal information collected about you through this Site, please send us an e-mail message at: privacy@bloomberg.com and include Bloomberg Tradebook Japan in the subject line. All requests must include the following information: first name, last name, e-mail address, and “Privacy” in the Subject line. While Bloomberg Tradebook Japan will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws.

Transfer of Personal Information To Other Countries

Some of the uses and disclosures mentioned in this privacy policy may involve the transfer and processing of your personal information to various countries around the world that may have different levels of privacy protection than your own country. By submitting your personal information, you consent to such transfers and processing, including to and in the United States.

Links To Third-Party Web Sites

Bloomberg Tradebook Japan may provide links to third-party web sites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those web sites before providing any of your information on such sites.

Questions Regarding This Privacy Policy

If you have questions regarding this privacy policy, please contact us at privacy@bloomberg.com and include Bloomberg Tradebook Japan in the Subject line of your inquiry.

Modifications To This Privacy Policy

Bloomberg Tradebook Japan reserves the right to change this privacy policy at any time by posting revisions on this web page. Such changes will be effective upon posting.

Last Updated: April 29, 2024

Personal Information Protection Declaration

Bloomberg Tradebook Japan Limited

BLOOMBERG TRADEBOOK has developed and announces this Personal Information Protection Declaration as its policy for handling of the personal information of customers.

Compliance with Relevant Laws, Regulations and Guidelines

Our company shall comply with all applicable laws and regulations concerning the protection of personal information including the “Act on the Protection of Personal Information (“APP”) (Act No.57 of 2003, as amended)”, the guidelines of those state ministers with competency thereover, the guidelines of the Personal Information Protection Commission and the guidelines of the Accredited Personal Information Protection Organization, as well as this Personal Information Protection Declaration.

Purposes of Use

Our company, unless the customer agrees or except as applicable laws, regulations and guidelines permit it as an exception, shall handle the personal information of customers solely to the extent of the achievement of the purposes of use of personal information within our company as described in the annex hereto (the “Purposes of Use”).

Furthermore, the Purposes of Use shall be displayed in our headquarters, in addition to being published on the website and the like of our company. In the event that the Purposes of Use are modified, such modification shall also be published in the same manner. Please click here for the online privacy policy.

Safe Management Measures

Our company shall strive so that the content of the personal information of customers is accurate and current. Furthermore, in order to prevent the disclosure, loss or damage of the personal information of customers and to manage the safety of such personal information, the necessary and appropriate safe management measures shall be implemented and, in addition, the appropriate supervision of executives, staff and delegatees shall be carried out.

Continuous Improvement

Our company, in order to strive for the appropriate handling of the personal information of customers, shall carry out the appropriate review of this Declaration and strive for continuous improvement.

Provision of Personal Information to Third Parties

Personal information may be made available to Bloomberg L.P. and its affiliates in order to enhance the services it provides as far as applicable laws, regulations and guidelines allow.

The personal information provided to the third parties may include such persons’ names, addresses, telephone/facsimile numbers, email addresses, employers’ names, titles, career history and information about the use of its service, such as generic types of information accessed, times and volume of use of the service and traffic information as far as applicable laws, regulations and guidelines allow.

Our company may disclose personal information or other information to Bloomberg L.P. and its affiliates, its service providers and others, including the subscriber of relevant account or other party, including Bloomberg product users and the party who authorized your use of the Service, such as your employer (or its parent company or authorized affiliates(s)). Our company makes available some of the personal information above it collects to such parties and Bloomberg L.P. and its affiliates via its proprietary electronic network over which the BLOOMBERG PROFESSIONAL service is provided as far as applicable laws, regulations and guidelines allow.

We may share your personal information with Bloomberg L.P., its affiliates and service providers, including those performing administrative and operational functions on our behalf.

Matters concerning Personal Information held and handled by Our Company

Purposes of Use of All Personal Data Held

Same as the Purposes of Use described in Section 2.

Procedure for Requesting Disclosure, Etc.

Relevant law may permit customers to request to be informed of the purpose of use of the personal information, to request disclosure of personal information, to request amendments, additions or deletions of personal information, or to request suspension of use of personal information. If customers would like to exercise any of these rights with respect to personal information held by our company about them, they may contact the person as set forth below with sufficient particulars to identify the information involved. We will inform customers of the procedures that may be required, including the payment of any necessary fees.

Questions, Opinions, Etc.

Our company shall strive to make prompt and good faith responses to questions, opinions and the like concerning personal information received from customers. Customers may contact in writing our company via the contact information provided below with your questions, opinions and the like:

Address:

Marunouchi Bldg. 21F
2-4-1 Marunochi, Chiyoda
Tokyo, Japan, 100-6321

Telephone:

03-4565-8358

Office hours:

9:00 am to 5:00 pm

E-mail:

privacy@bloomberg.com and include Bloomberg Tradebook Japan in the subject line

Accredited Personal Information Protection Organization

Our company is a member of the Japan Securities Dealers Association, an Accredited Personal Information Protection Organization that has received the authorization of the Financial Services Agency. Complaints and consultation concerning the association member’s handling of personal information are accepted at the Personal Information Consultation Office of the Association.

http://www.jsda.or.jp/en/personal-information/index.html

(Complaints and Consultation Counter):
Japan Securities Dealers Association
Personal Information Consultation Office
Telephone (03-6665-6764)

Handling of Sensitive Information

Our company shall not handle information concerning political thought, race and nationality, religious beliefs (including religion, thought and creed), entry into labor union, family status and original domicile, healthcare and medical care, sexual life or criminal record and other special nondisclosed information, in accordance with Cabinet Office Ordinances concerning regulation of the acts and the like of securities companies and the like and applicable guidelines.

Transfer of Personal Information To Other Countries

End

(Annex)

Purposes of Use of the Personal Information of Customers

April 29. 2024

Bloomberg Tradebook Japan Limited

Our company shall handle the personal information of customers solely to the extent necessary to achieve the purpose of implementing the business content and achieving the purposes of use below:

Business Content:

Purchase and sale of negotiable securities, futures transactions such as a negotiable securities index, negotiable securities options trading or foreign market securities futures trading

Mediation, agency or proxy for the purchase and sale of negotiable securities, futures transactions such as a negotiable securities index, negotiable securities options trading or foreign market securities futures trading

Mediation, agency or proxy for the delegation of the purchase and sale of negotiable securities, futures transactions such as a negotiable securities index, negotiable securities options trading in the market for negotiable securities, as well as mediation, agency or proxy for the delegation of the purchase and sale of negotiable securities or foreign market securities futures trading

Other services relating to securities business

Intermediation of OTC derivatives transactions

Purposes of Use:

In order to provide solicitation, sale and service for the electronic Bloomberg trading platforms pursuant to the Financial Instruments and Exchange Act (including those related to PTS and OTC derivatives trading)

In order to carry out solicitation, sale and service guidance for the electronic Bloomberg trading platforms pursuant to the Financial Instruments and Exchange Act (including those related to PTS and OTC derivatives trading)

In order to carry out solicitation, sale and service guidance for the electronic Bloomberg trading platforms of our company, affiliates or associated companies

In order to judge the appropriateness of the providing of the electronic Bloomberg trading platforms and services to the customer

In order to confirm whether a customer is the actual party concerned or the agent of the party concerned

In order to carry out notice of transaction results and the like to the customer

In order to carry out administrative matters related to transactions with the customer

For the purpose of the research and development of financial products and services by means of the implementation of market surveys as well as data analysis and questionnaires and the like

In order to properly perform delegated work, when all or part of the processing of the personal information has been delegated from another business entity or the like

Such other matters in order to appropriately and smoothly perform other transactions with the customer (including PTS and OTC derivatives trading work based on the Financial Instruments and Exchange Act)

In order to make personal information available to Bloomberg L.P. and its affiliates to support our company’s provision of the electronic Bloomberg trading platforms and to enhance and promote the services Bloomberg L.P. and its affiliates provides as far as applicable laws, regulations and guidelines allow

In order to enhance and promote the services Bloomberg Tradebook Japan provides as far as applicable laws, regulations and guidelines allow

Bloomberg Tradebook Japan may also disclose your information to unaffiliated third parties if we believe in good faith that such disclosure is necessary: (a) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (b) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (c) to protect the interests, rights, safety, or property of Bloomberg Tradebook Japan or others; (d) to enforce any terms of service on this Site; or (e) to provide you and other customers with the services or products requested by you and/or the other customers (including allowing a purchaser of Bloomberg Tradebook Japan to continue to serve you) and to perform other activities related to such services and products, including billing and collection.

Please click here for the online privacy policy.