1.Compliance with laws and regulations

We will comply with applicable laws, regulations, etc. in relation to administration of personal information of our clients.

2.Collection personal information

Our collecting of personal information will be in a lawful and fair manner and to the minimum extent required for our business.

3.Use of the personal information

Our use of the personal information will be limited for the purposes of our investment management business, investment advisory/agency business, type 1 financial instruments business and type 2 financial instruments business and their ancillary businesses as well as other business approved by authorities only within the purposes described at the time of collection and it will be limited to the minimum extent required for our business. These purposes include:

1. To introduce investment funds established by us or our group companies;
2. To assess the suitability of products or services before providing them to clients;
3. To verify the identification of a client or the agent of such client (in case of an institutional client, to verify the identification of the representative persons;
4. To send reports on performance, outstanding AUM and securities transaction;
5. To develop products and services based on market research and data analysis through conducting survey, and
6. To facilitate business with our clients.

4.Sharing of personal information

We will not provide the personal information for any third party without customer’s prior consent, unless the disclosure is required by laws and regulations or it is regarded beneficial to the customer or the public interests.
We do not outsource the administration of the personal information of our clients to an external vendor. However, an appropriate investigation on the candidate outsourced vendor will be conducted and we will make sure that an appropriate control on confidentiality is in place in case of the outsourcing. Please note that we cannot be responsible for the protection of personal information on external linked pages.

5.Management of the personal information

1. We will keep the personal information of our clients accurate and updated and take necessary measures to protect it.
2. We will take necessary measures to prevent unauthorized access to the personal information.
3. We will keep our staff informed to protect personal information.
4. We will make sure that the control level of the administration of the personal information at the outsourced vendor (if any) is at the same level as ours.

6.Inquiries, etc. from the customer

If we receive an inquiry of disclosure, change or suspension of use, deletion, etc. with respect to the personal information from a client, we will respond to such inquiry once we have confirmed the inquiry is being made genuinely by the client himself/herself promptly, unless there is a special reason to respond otherwise.

7.Disclosing and change of our Privacy Policy

The Privacy Policy will be made public on our website.

This Policy may be amended to comply with amendment of provisions of laws and regulations, etc.

Contact:

ING Mutual Funds Management Company (Japan), Ltd.
Compliance & Risk Management Department
Telephone: 03-5210-0610
Hours: 9:00 to 17:00
(Except for Saturdays, Sundays, national holidays, year end holidays, New Year’s holiday season)

Japan Securities Dealers Association
Financial Instruments Mediation Assistance Center
Telephone: 0120-25-7900
Hours: 9:00 to 17:00
(Except for December 30 to January 4, Saturdays, Sundays, and national holidays)

The Investment Trusts Association, Japan
Compliant Center
Telephone: 03-5614-8440
Hours: 9:00 to 11:30, 12:30 to 17:00, Monday to Friday (except for national holidays)

Japan Securities Advisors Association
Compliant Center
Telephone: 03-3663-0505
Hours: 9:00 to 17:00, Monday to Friday (except for national holidays)