Safety initiatives

About the handling of personal information

QT capital deeply recognizes that the customer’s personal information is important privacy information, establishes regulations on how to handle the information, and works to protect the customer’s personal information.

privacy policy

The Company will formulate and publicly announce the following privacy policy as an approach policy for customer’s personal information and personal number (hereinafter referred to as “personal information, etc.”).

1. Compliance with related laws and regulations

We will comply with relevant laws and regulations regarding the protection of personal information, the guidelines of the competent minister, the guidelines of certified personal information protection organizations, and this privacy policy.

2. purpose of use

We will handle your personal information to the extent necessary to achieve the purpose of use, unless we have obtained your consent or are handled as an exception by law. Personal numbers will be handled only within the range specified by law.

2-1 Purpose of use of customer’s personal information

(1) We will handle your personal information, etc. to the extent necessary to achieve the following business content and purpose of use.

 

(2) To accept applications for financial products and services such as opening securities accounts

 

(3) To judge the adequacy of the provision of products and services in light of the principle of conformity

 

(4) To confirm that you are the customer or an agent of the customer, or a person who has become a representative, agent, transaction person, or messenger of a corporation, group, etc. involved in financial instrument transactions. For identity verification

 

(5) To report transaction results, deposit balance, etc. to customers

 

(6) To perform office work related to transactions with customers and business partners and internal management operations of the Company

 

(7) For research and development of products and services through market research, data analysis, questionnaire surveys, etc.

 

(8) To properly carry out the entrusted business in the case where the entrustment of the processing of personal information from other companies, etc., is performed in whole or in part.

 

(9) To exercise rights and fulfill obligations based on contracts with customers, laws, etc.

 

(10) In addition, in order to properly and smoothly execute transactions with customers and business partners

 

(11) Regardless of the purpose of using the personal information in the preceding items, the personal number is used only for “application/notification of account opening for financial instrument transactions” and “preparation/submission of statutory documents for financial instrument transactions” I will do it.

Sensitive information

Information regarding political views, religious beliefs (religions, thoughts and beliefs), membership of trade unions, race and ethnicity, family and domicile, health and sexual life, and criminal history (hereinafter referred to as “sensitive”) (“Sensitive) information”) will not be acquired, used or provided to a third party, except in cases where it is required by law.

2-2 Main sources of personal information, etc. and major outsourcing services

(1) Main sources of personal information

 

The Company will acquire customer’s personal information, etc. mainly from the following sources, etc., by appropriate and lawful means within the range necessary for achieving the purpose of use.

 

(1) Information directly entered and entered by the customer on the account opening application screen and questionnaires to be conducted

 

(2) Information provided by customer inquiries by telephone or email, inquiry form on WEB site, chat, etc.

 

(3) Information provided by customers and introducers through the provision of products and services (*For phone calls from customers to our contact center, we may record calls for the purpose of improving the accuracy of customer response and improving service. .)

 

④ Information published in commercially available books, etc., or information published in newspapers, the Internet, etc.

(2) Main work outsourced

We outsource some of the work to facilitate the work necessary to achieve the purpose of use. In addition, the following are the main operations that our company handles with personal information etc.

 

① Business related to development, operation and maintenance of information systems

 

(2) Business operations related to opening customer accounts and printing, sending, and accepting various reports

 

(3) Business related to the storage of customer’s personal information and other related books and documents

 

④Providing professional advice such as legal and accounting

 

(5) Outsourcing of financial product intermediary services

3. Safety management measures

We strive to keep your personal information accurate and up to date. In addition, in order to prevent leakage of customer’s personal information, etc., we will implement necessary and appropriate safety management measures and appropriately supervise executives and employees and contractors.

4. Qiqi improvement

The Company will review this policy and strive for continuous improvement in order to properly handle customers’ personal information.

Five. Disclosure request procedure

When the customer makes a request for disclosure, correction, suspension of use, etc. regarding personal information related to the customer, we will confirm that it is the person himself and strive for an appropriate and prompt reply. I shall go. In this case, you may be charged a prescribed fee. If there is a request to disclose whether or not you have an individual number, we will respond to you as to whether or not you have an individual number.

Risks related to transactions such as financial products

Market fluctuation risk

The domestic and overseas ETFs that make up the portfolio owned by the customer mainly target stocks, bonds, commodities, etc. as their actual investment targets, and their prices fluctuate greatly depending on the prices of these actual investment targets. As a result, there is a loss and the investment principal may be interrupted.

Currency fluctuation risk

With regard to the overseas ETFs that make up the portfolio owned by the customer, losses may occur due to fluctuations in the foreign exchange rate caused by changes in interest rates in the currency issuing countries, and investment principal may be interrupted.

Credit risk

If the domestic and overseas ETFs that make up the portfolio owned by the customer target stocks, bonds, etc. as a substantial investment target, and if the credit status of the issuer of the stocks, bonds, etc. changes, the investment target Fluctuations in market prices may result in losses and may even lower the investment principal.

Other risks

Although exchange financial instrument transactions and foreign financial instrument exchange transactions (domestic and overseas ETFs) are conducted in the market, there is a risk that the transactions will be hindered due to changes in the market environment and cannot be exchanged for cash (liquidity risk). .. If the target country of the ETF to be traded is a holiday, etc., transactions related to that ETF may not be performed.

Conflict of interest management policy overview

QT CAPITAL (hereinafter referred to as the “Company”) has established a conflict of interest management policy (hereinafter referred to as “the policy”) so as not to unreasonably harm the interests of customers, and transactions that may cause conflicts of interest. We will properly manage and carry out our business. In addition to directly damaging the interests of our customers, we will strive to manage our business so that it does not damage our social reputation or the credibility of our financial markets. The outline of the policy is announced below.

1. What is a conflict of interest?

“Conflict of interest” means the situation where the interests of the customer and the interests of the Company conflict with each other, or the interests of the customers for whom the Company is obliged compete or conflict. We will appropriately identify transactions that may cause conflicts of interest, and will make every effort to ensure that the interests of our customers are not unduly harmed by the transactions we carry out.

2. Types of transactions that may cause conflicts of interest

The Company classifies the situation of conflicts of interest according to the following types and manages transactions that may cause conflicts of interest in an efficient and complete manner.


Self-transaction type “When the Company acts as an agent for the customer, the Company acts as the counterparty of the transaction and the like.”


Bilateral agent type “Acts in which the Company acts as an agent of both parties and similar ones”


Competitive transaction type “When a customer has a competing relationship with the Company or between customers, unfairly prioritizing one profit or the like”


Information usage type “Acts that illegally use internal information and similar things”

3. Conflict of interest management system

The Company will centrally manage transactions that may cause conflicts of interest, with the Risk and Compliance Department as the Conflict of Interest Management Control Department and the person in charge of the Risk and Compliance Department as the Conflict of Interest Management Control Manager. The Conflict of Interest Management General Manager shall inform and thoroughly inform the officers and employees regarding conflict of interest management, establish the system necessary for conflict of interest management, and regularly verify this.

4. How to manage conflicts of interest

The Company will appropriately manage the target transactions by the following methods or a combination of them, and will work to prevent unreasonable harm to the interests of customers.


How to isolate information and block information between departments that carry out transactions with potential conflicts of interest


How to change the conditions or method of one or both transactions that may cause conflicts of interest


How to cancel one of the transactions that may cause a conflict of interest


How to disclose to your customers that you may have a conflict of interest


How to monitor who shares information


Other methods

5. Range of companies subject to conflict of interest management

Our company is the only company that is subject to conflict of interest management, and there is no other company.

Basic policy for antisocial forces

Our company establishes and declares the following basic policy in order to prevent damage by anti-social forces who are groups or individuals who pursue economic profit by making full use of violence, power and fraudulent methods.

1. We will respond to antisocial forces as a whole organization and ensure the safety of employees who respond to antisocial forces.

2. We will continue to build close working relationships with outside specialized institutions such as the police, the Center for the Expulsion of Violence, lawyers, and the Japan Securities Dealers Association.

3. We will block all relationships with anti-social forces, including business relationships.

Four. We will reject unreasonable demands by anti-social forces, and will firmly take legal action from both civil and criminal grounds.

Five. We will never sell or fund any antisocial forces.

Basic Policy on Money Laundering and Prevention of Terrorist Financing

QT CAPITAL (hereinafter referred to as “our company”) recognizes the importance of measures against money laundering and terrorist financing (hereinafter referred to as “manero, etc.”), and the services provided by our company are In order to prevent involvement in financial crimes, we will establish a basic policy regarding the prevention of mannelon, etc. as follows, and build an effective internal control system based on it.

1. Maintenance and operation of prevention system for manlon etc.

The Company considers countermeasures against manlon etc. to be a serious management issue, and with the active involvement of the management team, establishes and operates an effective internal control system to carry out prevention of manlon etc.

2. Organizational structure

The Company has the risk and compliance department as the department in charge of measures such as mannelon. In addition, a director or executive officer will appoint a general manager in charge of countermeasures against mannelon, etc., and under the supervision of that manager, will work to prevent mannelon etc. across the organization.

3. Risk identification, evaluation, and reduction

Based on a risk-based approach, the Company comprehensively and specifically verifies risks such as products/services provided by the Company, transaction types, countries/regions involved in transactions, customer attributes, etc., and identifies risks such as mannelon. To do. We will also evaluate the impact of the identified risks and, based on the results, take appropriate measures to reduce the risks.

4. Customer management policy

We carry out appropriate customer management (customer due diligence) by conducting surveys and analyzes of customer information etc. on a regular basis. In addition, at the beginning of a business relationship with a customer, we will endeavor to eliminate business relationships with inappropriate customers, including those subject to sanctions and anti-social forces, by determining whether or not to accept customers.

5. Suspicious transaction notification

We carry out transaction monitoring to ensure the effectiveness of risk reduction measures such as Maneron. As a result, if “suspicious transactions” such as abnormal transactions or transactions subject to sanctions are detected, we will deal with them appropriately and promptly notify the authorities.

6. Audit of efforts and continuous improvement

Our internal audit department audits the status of our efforts on countermeasures such as mannelon in a timely and appropriate manner. Based on the results, we will verify the effectiveness of measures such as Maneron and make continuous improvements.