1. Processing of Personal Data

1. 1.This EU Privacy Policy (this “Privacy Policy”) sets forth the rules and policy under which the Securities Analysts Association of Japan (“SAAJ” or “we”) processes personal data about users of this site (each a “User” or “you”), who are located in the European Economic Area including the European Union member states (collectively, the “EU”). Where the General Data Protection Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”) applies to SAAJ concerning the personal data of Users located in the EU, SAAJ will properly process such personal data in compliance with the GDPR, as well as in accordance with this Policy.
2. 2.SAAJ manages personal data such as names, addresses, telephone numbers and workplace information, which Users may voluntarily provide to SAAJ through "My Page" on SAAJ's website, contact form, chatbot, and various applications or questionnaires prescribed by SAAJ or the email distribution system of SAAJ’s website.
3. 3.To ensure that you feel secure in using our various services, SAAJ will take all possible measures to protect your personal data, such as by establishing guidelines for the processing of personal data and operating said guidelines with strict management of the collection, storage and use of personal data.
4. 4.Your personal data will be processed for the purpose of verifying your identity and providing and improving our services, and will not be processed, unless: (a) you have given your consent to processing; (b) processing is necessary for the performance of an agreement between you and SAAJ; (c) processing is deemed necessary under any applicable laws or regulations; (d) processing is considered to be necessary for the public interest; or (e) SAAJ has legitimate interests in processing your personal data.

2. Personal Data to be Processed

A.  Information obtained in relation to membership registration

When registering as a member (for details of the membership categories, please see: https://www.saa.or.jp/english/about_saaj/membership.html), SAAJ requests you to provide personal data such as name, address, telephone number, place of employment, e-mail address, and work experience. We use such personal data for the following purposes:

1. - To screen members for membership, determinate eligibility for membership, register members, and verify your identity;
2. - To provide and inform you of the SAAJ's services (electronic journals, etc.) and events (various seminars, lectures, IR meetings, etc.);
3. - To conduct administrative work for you (billing for annual membership fees, sending publications, etc.);
4. - To conduct questionnaires to improve member services, etc; and
5. - To preparate of various administrative materials.

B.  Information obtained in relation to correspondence courses or examinations

When you create a "My Page" on SAAJ's website to register for a course or examination offered by SAAJ, we request you to enter your personal data, such as name, address, telephone number, place of employment, e-mail address, etc., and confirm whether you agree to provide information about the course or examination to your organization. We use such personal data for the following purposes:

1. - To send course textbooks, etc.;
2. - To send information on examinations, etc. by e-mail;
3. - To send examination vouchers;
4. - To verify your identity when you take the examination;
5. - To prepare various administrative materials;
6. - To invite to events (seminars, lectures); and
7. - To conduct questionnaires to improve services, etc.

C.  Information obtained in relation to viewing of videos and access to abstracts and journal articles

When you as non-members wish to view videos, abstracts, and journal articles for a fee, SAAJ requests you to notify us of your personal data such as name, address, telephone number, work place, and e-mail address. We use such personal data for the following purposes:

1. - To carry out general operations such as distribution of videos and sending of abstracts and journal articles (e.g. registering you as an attendee of the courses, verifying the status of your attendance and providing you with post-attendance services); and
2. - To support for viewing videos, abstracts, and journal articles (e.g. replying to consulted matters and inquiries concerning the use of the services and resolving any issues which may arise)

D.  Information obtained in relation to participation in events and seminars

When you as non-members wish to attend an event/seminar (including IR meetings/seminars, the same below), SAAJ requests you to provide personal data such as name, address, telephone number, place of employment, and e-mail address upon application. We use such personal data for the following purposes:

1. - To register you as a participant of an event or seminar and to manage your attendance (e.g. collaborating and sharing information with the organiser of such event or seminar and managing your entry into the building/room of the venue); and
2. - To provide you with information on the relevant event or seminar as a participant thereof, as well as information on other related events and seminars.

E.  Information obtained in relation to payment

When various types of payment are required for the provision of services by SAAJ, SAAJ requests you to provide your personal data such as name, address, telephone number, place of employment, e-mail address, credit card information, bank account information, and other payment-related information at the time of payment. We use such personal data for the following purposes:

1. - To make payments of membership fees;
2. - To make payments for attending lectures and taking examinations (including course textbooks, etc.);
3. - To make payments for viewing videos, reading abstracts, and reading journal articles;
4. - To make payments for participation in paid events and seminars;
5. - To make payments for mediated books, etc; and
6. - To process payments for other transactions between you and SAAJ.

F.  Other information obtained in relation to contact forms and chatbots

When you submit an inquiry via the contact form on the SAAJ website or via the chatbot, SAAJ requests you to provide your personal data such as your name, address, telephone number, workplace information, e-mail address, and the content of your inquiry. We use such personal data for the following purposes:

1. - To verify your identity or to change your registered information;
2. - To perform services, operations, or administrative procedures (including billing for expenses) requested by the customer via the contact form or chatbot;
3. - To communicate with you (including communication with organizations other than SAAJ);
4. - To prepare various administrative materials; and
5. - To be used for other operations necessary to respond to inquiries.

G.  Information obtained in relation to SAAJ’s website

SAAJ’s website automatically collects cookies, your internet domain name, IP address, query information concerning searches made within the site and other information associated with your browsing, etc. of this site. SAAJ will use your personal data for the purpose of improving SAAJ’s services by carrying out statistical investigations/analyses on improved usability and on the status of Users’ accesses, as well as understanding the status of use of SAAJ’s services by Users.
Users can indicate in advance that a website uses cookies by setting their browsers, and users who wish to disable or delete cookies can do so by changing the settings of their web browsers. However, if cookies are disabled or deleted, some functions of the Association's services may not be available.
SAAJ uses Google Analytics provided by Google LLC on this service in order to research and analyse the usage of the services provided by us. For more information on how data is collected and processed by Google Analytics, please visit the Google Analytics website.

Google Analytics Terms of Service:
https://www.google.com/analytics/terms/jp.html
Google's use of your data when you use Google Partner sites and apps:
https://www.google.com/intl/ja/policies/privacy/partners/
Google Privacy Policy:
http://www.google.com/intl/ja/policies/privacy/

If you do not want your data to be used by Google Analytics, please use the Google Analytics Opt-Out Add-On provided by Google.

3. Transfer of Personal Data to Countries Outside of the EU

In order to provide services to you, SAAJ must transfer Users’ personal data to countries outside of the EU (including Japan).
Whenever SAAJ transfers your personal data to any country outside of the EU, we will do so pursuant to our obligations set forth in applicable laws and regulations. In the event that SAAJ transfers your personal data to Japan and/or Switzerland, your personal data will be transferred on the basis of an adequacy decision rendered by the European Commission. In the event that SAAJ transfers your personal data to any other country, your personal data will be transferred after having taken appropriate protection measures in accordance with the standard contractual clauses prescribed by the European Commission, or based on your consent. By consenting to this Privacy Policy, you agree to SAAJ’s transfer of your personal data, having understood that data protection equivalent to that in the EU may not be available in the country to which your personal data is transferred.
If you wish to obtain further detailed information, such as obtaining a copy of a document that is used to safeguard your information, please contact SAAJ, either by postal mail to SAAJ’s address or by email to SAAJ’s email address, as specified in “12. Contact” below.

4. Parties to Whom Personal Data Is Provided

SAAJ may provide your personal data to service providers to whom SAAJ outsources services. In addition, your personal data obtained by SAAJ at the time you take any of our examinations may be provided to third parties, including the operator of the relevant examination site, to the extent necessary to carry out such examination.

5. Sources of Personal Data

SAAJ mainly collects your personal data directly from you.

6. Storage Period

SAAJ will store your personal data for a period necessary to accomplish the purposes of processing thereof as set forth in this Privacy Policy.
SAAJ will determine the storage period for your personal data, based on: (i) the length of SAAJ’s continuous relationship with you; (ii) whether or not SAAJ has any legal obligations it needs to comply with; and (iii) whether SAAJ is required to perform any agreement to which you are a party.

7. Rectification or Erasure of Personal Data

At your request, SAAJ will promptly take measures such as rectification or erasure of your personal data controlled by SAAJ, after having verified the details, etc. of your request.
You have the right to (i) request a copy of, (ii) request rectification of, (iii) request erasure of, or (iv) restrict the processing of (or suspend the processing of) your personal data, or (v) receive, in a structured and machine-readable form, your personal data that has been provided to SAAJ either for the purpose of any agreement or based on your consent, and request SAAJ to provide such information to another data controller (i.e. the data portability rights). In this case, you may be asked to pay a handling fee.
In addition, under certain conditions, you have the right to (vi) object to the processing of your personal data. For further detailed information, please see “8. Right to Object to Processing of Personal Data” below.
Please note that we may not be able to fulfil your request if the request is not permitted by law.
The above-described rights to which you are entitled may be restricted, such as in the event that (a) SAAJ’s acceptance of your request will result in the disclosure of any third party’s personal data, or infringement upon the rights of any party other than you (including SAAJ’s rights), or (b) you make a request for the erasure of information which is required to be stored under any applicable law or regulation, or information for which SAAJ has imminent and legitimate interests in the storage thereof.
If you wish to exercise any of the above rights, please contact SAAJ, either by postal mail to SAAJ’s address or by email to SAAJ’s email address, as specified in “12. Contact” below.

8. Right to Object to Processing of Personal Data

You shall have the right to object, at any time, to the processing of personal data based on the grounds of legitimate interests that is processed by SAAJ. The term “processing of personal data” here includes profiling (meaning to analyse or predict your behaviour based on your information; the same applies hereinafter).
In cases where personal data is processed for direct marketing purposes, you have the absolute right to opt-out of such direct marketing or any profiling conducted for said purposes.
If you wish to exercise any of the above rights, please contact SAAJ, either by postal mail to SAAJ’s address or by email to SAAJ’s email address, as specified in “12. Contact” below.

9. Withdrawal of Consent

Where SAAJ processes your personal data based on your consent, you have the right to withdraw your consent at any time. Your withdrawal of consent shall not affect the lawfulness of the processing carried out on the basis of your consent, prior to such withdrawal.
If you wish to exercise said right, please contact SAAJ, either by postal mail to SAAJ’s address or by email to SAAJ’s email address, as specified in “12. Contact” below.

10. Personal Data Which You are Required to Provide

The personal data which you are required to provide to SAAJ is shown in the respective forms in which you have made entries. In cases where you are required to provide your personal data, SAAJ will be unable to provide the relevant services to you unless you provide us with the appropriate information.

11. Right to Lodge a Complaint with Supervisory Authority

You have the right to lodge a complaint with the competent supervisory authority.

12. Contact

Any opinion or question you may have regarding SAAJ’s processing of personal data should be addressed to the following:

Attention	The Securities Analysts Association of Japan, general affairs department (bureau)
Address	5th Floor, Tokyo Stock Exchange Building 2-1 Nihonbashi-Kabutocho, Chuo-ku, Tokyo 103-0026 JAPAN
Email	jouho@saa.or.jp