Privacy Policy

Morgan Stanley and its affiliates in Japan (“we”, “our” or “us”) are committed to safeguarding the privacy of information entrusted to us. Protecting the confidentiality and security of client information and candidate and employee information has always been an integral part of how we conduct our business.

Morgan Stanley and its affiliates in Japan mean Morgan Stanley Japan Holdings Co., Ltd., Morgan Stanley Japan Group Co., Ltd., Morgan Stanley MUFG Securities Co., Ltd., Morgan Stanley Investment Management (Japan) Co., Ltd., Morgan Stanley Capital K.K., Morgan Stanley Japan Business Group Co., Ltd. *, Shareworks Japan K.K. The same applies below:

* Our candidates and employees who will be seconded to Mitsubishi UFJ Morgan Stanley Securities Co., Ltd are included.

We pledge to ensure our business practices protect your personal information.

This Addendum of International Privacy Policy for Japan (this “Addendum”) applies to all personal information that we obtain or handle in Japan and forms part of Morgan Stanley’s International Privacy Policy, and is incorporated into it by reference. In the event that there is a conflict between the contents of this Addendum and Morgan Stanley’s International Privacy Policy, the contents of this Addendum shall prevail.

As a business operator handling personal information (as defined in the Act on the Protection of Personal Information (the “Personal Information Protection Act”), we make this Addendum in respect of our basic policies concerning the protection of personal information of (1) each company’s clients (for Morgan Stanley Japan Holdings Co., Ltd. and Morgan Stanley Japan Business Group Co., Ltd., clients of Morgan Stanley Group including itself; hereinafter the same), (2) other persons involved in our business ((1) and (2) above are referred to collectively as “client, etc.”), (3) our candidates, and (4) our employees ((3) and (4) above are referred to collectively as “candidate, etc.”).

Compliance with Applicable Laws and Regulations, Etc.
We will comply with the Personal Information Protection Act and the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures as well as other applicable laws and regulations, guidelines issued by governmental agencies, the International Privacy Policy, this Addendum and any other documentation which may govern the client, etc.’s/ candidate, etc.’s relationship with us.
Purpose of Use of the Client, Etc.’s Personal Information and Specified Personal Information, Etc.
(1) Purpose of Use of Personal Information
Unless otherwise agreed to between the client, etc., and Morgan Stanley and its affiliates in Japan or in exceptional circumstances, Morgan Stanley and its affiliates in Japan will only use the client, etc.’s personal information within the scope of achieving the following purposes:
1. Purposes of Use of Morgan Stanley Japan Holdings Co., Ltd., Morgan Stanley MUFG Securities Co., Ltd., Morgan Stanley Investment Management (Japan) Co., Ltd., and Morgan Stanley Capital K.K.:
  1. to provide solicitation, sales and related services concerning securities or any other financial products handled by us and/or our affiliates (“Morgan Stanley Group”) (including buy/sell transactions, intermediating buy/sell transactions, introduction or brokerage services, private and public offerings, underwritings as well as securitizations, leases and other types of structured finance transactions) or financial instruments business (as prescribed in the Financial Instruments and Exchange Act) (*);
  2. to confirm the validity of Morgan Stanley Group’s financial products or services, and the suitability of any of Morgan Stanley Group’s financial products or services (*);
  3. to check the client, etc.’s, or the client, etc.’s agent’s eligibility (through for example, identification) when Morgan Stanley Group offers our financial products to the client, etc., or enters into credit transactions with the client, etc.;
  4. to check the client, etc.’s, or the client, etc.’s agent’s eligibility (through for example, identification) when Morgan Stanley Group provides our services to the client, etc., in connection with a transaction (excluding Morgan Stanley Capital K.K.);
  5. to develop Morgan Stanley Group’s internal business practices, for example, in respect of evaluating credit risk and other types of risk and in respect of Morgan Stanley Group’s management of new or existing transactions with customers (including extending credit, service providing and similar transactions) (*);
  6. to inform or advise the client, etc., of performance results and account balances concerning Morgan Stanley Group’s financial products or services offered to the client, etc. (*);
  7. to provide market reports to the client, etc., from Morgan Stanley Group (*);
  8. to perform operational and marketing activities including customer development (*);
  9. to research or develop financial products and services provided by or to be provided by Morgan Stanley Group by conducting market research, data analysis or customer surveys (*);
  10. to conduct operations relating to transactions between Morgan Stanley Group and the client, etc.;
  11. to terminate transactions and manage the effects of such termination;
  12. to properly carry out any services, under contract, including where we are requested by a third party to handle part or all of such third party’s personal information (*);
  13. to exercise our rights or perform our obligations under the contracts with the client, etc., or the applicable laws and regulations, etc. This includes but is not limited to regulatory requests anywhere in the world; reporting to and being audited by national and international regulatory, enforcement or exchange bodies and complying with court orders (*);
  14. to provide services concerning investment advisory and agency business, and real estate asset management business(*) (applicable only to Morgan Stanley Capital K.K.);
  15. to provide Morgan Stanley Group’s services concerning investment trust entrustment business, investment corporation asset management business, investment advisory and agency business, or business related to discretionary investment contracts, and their associated businesses (including those that will be authorized in the future), or to provide solicitation, sales and related services concerning the foregoing (*) (applicable only to Morgan Stanley Investment Management (Japan) Co., Ltd.);
  16. to provide announcement or notification on events or seminars, etc. to be organized or held by Morgan Stanley Group, facilitate the registrations, and run and administrate such events or seminars, etc. as well as to provide any other services relating to such events or seminars, etc.; and
  17. for any other purposes in connection with the above purposes to enable Morgan Stanley Group to adequately and smoothly provide our services to the client, etc. (*).
2. Purposes of Use of Morgan Stanley Japan Group Co., Ltd. and Morgan Stanley Japan Business Group Co., Ltd.
  1. to provide solicitation, sales and related services concerning securities or any other financial products handled by Morgan Stanley Group (including buy/sell transactions, intermediating buy/sell transactions, introduction or brokerage services, private and public offerings, underwritings as well as securitizations, leases and other types of structured finance transactions) (*);
  2. to properly carry out any services under contract, including when requested by a third party to handle part or all of such third party’s personal information (*);
  3. to exercise our rights or perform our obligations under the contracts with the client, etc., or the applicable laws and regulations. This includes but is not limited to regulatory requests anywhere in the world; reporting to and being audited by national and international regulatory, enforcement or exchange bodies and complying with court orders (*);
  4. to provide (a) staff related services including human resource, payroll administrative, benefits, education, and training services, (b) IT related services including development and supply of software and hardware, (c) facility, corporate or general administrative services, and (d) any services related or incidental to the services referred to in the foregoing items (*) (applicable only to Morgan Stanley Japan Group Co., Ltd.); and
  5. for any other purposes to enable either company to facilitate a transaction between the client, etc., and us or adequately and smoothly provide our services to the client, etc. (*).
3. Purposes of Use of Shareworks Japan K.K.
  1. to perform services for our business partners
  2. to comply with legal and regulatory obligations (including financial and tax laws, codes, and regulations or any other guidelines), if applicable, and to respond to any inquiries from government authorities and any other public organizations, if any
(2) Purpose of Use of Specified Personal Information
Notwithstanding the preceding paragraph, with regard to the client, etc.’s individual number and specified personal information (“specified personal information, etc.”), Morgan Stanley and its affiliates in Japan may only use such information within the scope of achieving the following purposes:
1. for processing the affairs of application and notification of account opening regarding financial instruments transactions, preparation and provision of statutory documents regarding financial instruments transactions, and provision to transfer institutions in relation to financial instruments transactions (applicable only to Morgan Stanley MUFG Securities Co., Ltd., Morgan Stanley Investment Management (Japan) Co., Ltd., and Morgan Stanley Capital K.K.);
2. for processing the affairs of preparation and submission of payment records regarding the payment of remuneration, fees, contract money, awards or other considerations for services or rights, the payment of rent or consideration for transfer of real estate or the payment of dividends, surplus or interest, or the distribution of interest in other ways;
3. for processing the affairs of preparation of withholding records of employment income (including retirement income), preparation of salary payment reports, submission of reports of exemptions for dependents, and other affairs related to tax withholding, the affairs of submission of reports, on property accumulation housing savings and property accumulation pension savings, and the affairs of notification and application related to health insurance, employees’ pension insurance, employment insurance and other social or labor insurances or pensions (applicable only to Morgan Stanley Japan Group Co., Ltd. and Morgan Stanley Japan Business Group Co., Ltd.);
4. in cases where the affiliated companies of Morgan Stanley Group** entrust the handling of specified personal information, etc. to us, for processing the relevant affairs entrusted to such company (applicable only to Morgan Stanley Japan Group Co., Ltd. and Morgan Stanley Japan Business Group Co., Ltd.); and
5. for preparation and submission of other statutory records or documents on which an individual number is required to be written under provisions of laws and regulations.
Purpose of Use of Candidate, Etc.’s Personal Information
We will only use candidate, etc.’s personal information within the scope of achieving the following purposes:
1. to evaluate candidate, etc.’s eligibility for an interview;
2. to evaluate candidate, etc.’s suitability for employment and assignment at Morgan Stanley (whether in Japan or with one of our global affiliates);
3. to use as reference for future recruitment activities (*);
4. to manage and improve the recruitment process, and for internal planning and reporting (*);
5. to exercise our rights or perform our obligations under the applicable laws and regulations. This includes but is not limited to regulatory requests anywhere in the world; reporting to and being audited by national and international regulatory, enforcement or exchange bodies and complying with court orders (*); and
6. for any other purposes to enable us to adequately consider candidate, etc. as candidates for employment and/or to proceed with necessary procedures for employment (*).
Joint Use
(1) Joint Use of the Client, Etc.’s Personal Information
Morgan Stanley and its affiliates in Japan may, in whole or in part, jointly use the client, etc.’s personal information (excluding specified personal information, etc.) for the following:
1. Personal information used jointly
  - Name, address, telephone number, e-mail address, occupation or information relating to the client, etc., on business cards, type of products or services, transaction records, and/or account balance
  - Date of birth and account number (applicable only to Morgan Stanley MUFG Securities Co., Ltd., Morgan Stanley Investment Management (Japan) Co., Ltd., Morgan Stanley Capital K.K., and Morgan Stanley Japan Business Group Co., Ltd.)
  - Tax Identification Number (TIN) (i.e. SSM and SIN)(applicable only to Shareworks Japan K.K.
2. Scope of the joint users
  Affiliated companies within the Morgan Stanley Group including foreign corporations
3. Purpose of use
  Indicated in paragraph 2. (1) above
4. Responsibility for management of personal information to be used jointly
  Morgan Stanley Japan Group Co., Ltd
  Address: Otemachi Financial City South Tower 1-9-7 Otemachi, Chiyoda-ku, Tokyo
  Representative Director: David Richards
(2) Joint Use of the Candidate, Etc.’s Personal Information
We may, in whole or in part, jointly use the candidate, etc.’s personal information (excluding specified personal information, etc.) for the following:
1. Personal information used jointly
  Name, address, date of birth, gender, telephone number, e-mail address, information about affiliations of schools and organizations, current annual income, desired annual income, information on application documents and resumes, communication details, questionnaire responses, selection results, and/or information necessary to complete the onboarding process.
2. Scope of the joint users
  Affiliated companies within the Morgan Stanley Group including foreign corporations
3. Purpose of use
  Indicated in paragraph 3. above
4. Responsibility for management of personal information to be used jointly
  Morgan Stanley Japan Group Co., Ltd.
  Otemachi Financial City South Tower 1-9-7 Otemachi, Chiyoda-ku, Tokyo
  Representative Director: David Richards
Security Control Measures
We will take any necessary and adequate security measures and exercise adequate supervision over all officers and employees and any outsourcing service providers to protect your personal information and specified personal information, etc. against leaks, loss or damage.
Disclosure Etc., of Personal Information
You may request disclosure (including disclosure of records of provision to third parties), correction, addition or deletion, suspension of use, elimination or suspension of provision to third parties (collectively referred to as the “Privacy Rights Requests”) of the client, etc.’s personal information held by Morgan Stanley and its affiliates in Japan and the candidate, etc.’s personal information held by us by writing to the information desk at the address set out in paragraph 7 below. After each company obtains satisfactory evidence of your identity, each company will address your request in accordance with the applicable laws and guidelines.
Helpdesk
For Privacy Rights Requests of personal information, requests for disclosure of information related to a foreign country to which personal information is provided, questions related to security control measures, or questions or comments related to the International Privacy Policy and this Addendum, you can contact the Personal Information Helpdesk.

Morgan Stanley Japan Group Co., Ltd.
Information Helpdesk for Personal Information
Legal and Compliance Division
Otemachi Financial City South Tower 1-9-7 Otemachi, Chiyoda-ku, Tokyo 100-8109
Phone: 03-6836-5000
E-mail：data-protectionjp@morganstanley.com
Office hours: 9:00 a.m. – 5:00 p.m. (excluding Saturday, Sunday, national holidays and year-end through new year holidays)
Continuous Improvement of this Addendum
In order to constantly monitor and, where necessary, improve our handling of your personal information we will periodically review this Addendum and security measures or any other associated activities related to personal information.
Complaints and Consultations
Morgan Stanley MUFG Securities Co., Ltd., and Morgan Stanley Investment Management (Japan) Co., Ltd. are members of the Japan Securities Dealers Association (“JSDA”) which is a Personal Information Protection Authority certified by the Financial Services Agency. The Personal Information Helpdesk of JSDA accepts complaints and provides counselling services concerning the handling of personal information by JSDA's members.

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

Morgan Stanley Investment Management (Japan) Co., Ltd. is a member of the Japan Investment Trusts Association (“JITA”), and the Japan Investment Advisers Association (“JIAA”). The Helpdesks of JITA and JIAA accept complaints and provide counselling services concerning the handling of personal information by JITA/JIAA's members.

Japan Investment Trusts Association, Investor Consultation Helpdesk
Phone: 03-5614-8440
(http://www.toushin.or.jp/)

Japan Investment Advisers Association, Complaint Consultation Helpdesk
Phone 03-3663-0505
(http://www.jiaa.or.jp/)