Privacy Policy

Declaration on Personal Information Protection

When handling the personal information of its business partners, Community Trust Bank complies with acts concerning the protection of personal information by independent administrative institutions, handling this information as described below. Community Trust Bank requests that any opinions or complaints concerning its handling of personal information be directed to our Personal Information Desk.

Purpose of Using Personal Information

Community Trust Bank is entrusted by its business partners with necessary information, and the Bank uses this information to properly perform the operations defined by the Community Trust Bank Act.

Limiting the Purpose of Use of Personal Information

Community Trust Bank uses the personal information of its business partners only for the purposes described above. The specific purposes for such information are published on the Bank’s website. Use for any other purpose will be clearly indicated at the time that information is obtained.

Obtaining Personal Information Appropriately

When entrusted with personal information from its business partners, Community Trust Bank does not obtain it under false pretenses or through improper methods.

Managing Personal Information Content

Community Trust Bank endeavors to verify the validity of personal information from its business partners and requests that its partners cooperate.

Storing Personal Information Safely

To prevent leakage of the information received from its business partners, the Bank has established necessary and proper measures for its safe management and will consistently work to improve these measures. Community Trust Bank endeavors to maintain strict information-handling procedures, supervising and training its executives and regular employees on the handling of personal information and concluding non-disclosure agreements with subcontractors.

Providing Personal Information to Third Parties

The Bank releases personal information to outside parties only if the providers, its business partners, agree, or can be inferred to have agreed, to such use. However, such information is provided to third parties in certain legally defined situations deemed to be in an individual’s own or the public’s interest.

Disclosing Personal Information

If an individual requests the disclosure of personal information entrusted to the Bank by its business partners, the procedures for such disclosure are as specified in relevant acts concerning the protection of personal information held by independent administrative institutions.

Revising or Discontinuing the Use of Personal Information

If an individual requests that the use of personal information be discontinued, the procedures employed for such a request are as specified in acts concerning the protection of personal information held by independent administrative institutions.
Public Announcement Based on the Act on the Protection of Personal Information

Community Trust Bank.
(Business operator handling personal information)

Community Trust Bank., (hereinafter, “Community Trust Bank”) publicly announces the following matters based on the Act on the Protection of Personal Information (Act No. 57, promulgated May 30, 2003, including any subsequent amendment; hereinafter, the “Act”).
Ⅰ. Matters Concerning the Purpose of Use of Personal Information
(Article 18, Paragraph 1, of the Act)

Community Trust Bank handles clients’ personal information in order to perform the businesses described in item 1. below, and for the purposes of use described in item 2. below, and for no purpose of use exceeding those limits.

Business Content Financing business, guarantee business, capital investment business, businesses related to marketable securities, investment management business, investment advisory and agency businesses and businesses conducted by Community Trust Bank under the New Community Trust Bank Act (including business that it may handle in the future) and ancillary operations (hereinafter collectively referred to as “Bank operations”)
Purpose of Use To make decisions and perform follow-up management regarding Bank operations
To conclude contracts, verify identities or confirm eligibility related to Bank operations
To manage due dates or ongoing transactions pertaining to Bank operations
To provide to third parties within the necessary scope of operations
To exercise contractual and legal rights and fulfill such obligations
To monitor economic conditions by conducting surveys, distributing questionnaires or conducting related operations
To introduce Bank operations
To execute other activities to ensure smooth and appropriate client transactions

In the event that the purpose of use of specific personal information be limited by acts or regulations, such personal information will not be used other than for such purposes, as described below.

In accordance with Article 123, Item 7, of the Cabinet Order Relating to the Financial Instruments Transaction Business, Community Trust Bank does not use undisclosed information it has obtained on matters such as race, creed, family origin, registered address, medical history, or criminal background for any purposes except those required for the proper conduct of its business, nor does the Bank provide such information to third parties.

Ⅱ. Matters Concerning Sharing of Personal Data
(Article 23, Paragraph 5, Item 3, of the Act)

Community Trust Bank shares the personal data of its clients as follows.

Matters Concerning Shared Personal Data (1)
Information such as contact information, including the client’s name, birth date, physical address, telephone number and e-mail address; family-related information; employer-related information; information regarding the client’s assets and liabilities; information regarding transaction needs; and publicly disclosed information
(2)
Transaction status; type of service; agreement date, transaction amount, balance, term and other information related to the content of transactions with individual clients
(3)
Information needed to manage transactions with clients, such as information on the transaction process and information used in making loan decisions
Range of Parties Sharing Information

The Bank, and its subsidiaries and affiliated companies listed in its annual securities report (or in its lending reports)
(In the event that the sharing of information is limited by the Financial Instruments and Exchange Act or related legislation, information is handled in accordance with such legislation.)

Purpose of Use of Shared Personal Data (1)
To propose, inform about, study or develop investment and loan businesses and financial products and services: for example, to work with group companies in developing and proposing investment and loan businesses and financial products and services that meet client needs
(2)
To properly conduct group management activities, including the understanding and management of risks: for example, to create proper business management systems for the group and provide clients with stable and consistent services
Name of Party Responsible for Managing Personal Data

Community Trust Bank.
Ⅲ. Matters Concerning Retained Personal Data
(Article 27, Paragraph 1, of the Act)

Name of Business Operator Handling Personal Information

Community Trust Bank.

Purpose of Use of Retained Personal Data

The purpose of use of retained personal data is the same as described above in I (Matters Concerning the Purpose of Use of Personal Information) and II.3 (Purpose of Use of Shared Personal Data).

Procedures Followed to Meet Requests for Disclosure, etc.

Community Trust Bank follows the following procedures with regard to its clients’ retained personal data, as concerns notification of the purpose of use, correcting, adding or deleting; discontinuation of use or erasure; or discontinuation of provision to a third party (hereinafter, “disclosure, etc.”).
Community Trust Bank is unable to accept requests for disclosure, etc. if it is unable to confirm the identity of a person, or the proxy authority of an agent making the request, o ifr a request form or other stipulated document contains discrepancies. Therefore, those making such a request are asked to thoroughly understand the procedures described below and to provide any information required to identify the retained personal data in question. (In the interest of keeping personal data accurate and up-to-date, clients are requested to promptly notify the Community Trust Bank office with which they conduct transactions of any changes in information provided.)
Please note that Community Trust Bank may not be able to respond to requests for disclosure, etc. if it is prevented from doing so by law.
(1) Notification of Purpose of Use

Where to submit application

Community Trust Bank office with which applicant conducts business

Application method, required documents, etc.

The applicant should contact the Community Trust Bank office with which he or she conducts business.

Fees

Gratis

Response method, timing, etc.

The applicant will be provided with a Notice of Purpose of Use Form prescribed by Community Trust Bank.

(2) Disclosure

Where to submit application

Community Trust Bank office with which the applicant conducts business.

Application method, required documents, etc.

After completing the necessary items in a Retained Personal Data Disclosure Request Form prescribed by Community Trust Bank, the applicant should submit it, along with the documents indicated below to confirm his or her identity, to the Community Trust Bank office with which he or she conducts business.

Personal identification methods (including method of confirming proxy’s power of attorney)

For personal identification, provide one of the following.

(i)

Seal registration certificate for seal imprinted on the disclosure application form mentioned above (must be issued within the last six months)

(ii)

Public certificate issued or provided by a government body, containing the applicant’s photograph, name, date of birth and physical address. Acceptable documents include a driver’s license and passport. (Documents must be currently valid.)

(iii)

If providing documents other than those described in (i) or (ii) above: health insurance certificate, pension passbook, welfare booklet, etc. (Documents must be currently valid.)

If the applicant requesting disclosure, etc. is the legal representative of a minor or an adult ward, or an agent to whom the request for disclosure, etc. has been delegated, the documents listed below must be presented (for both the individual and the agent) in addition to those mentioned above.

If a person with parental rights,

One copy of the family register to confirm the party’s parental rights (must have been issued or prepared within the last six months)

If an adult ward,

One copy of the registration document certifying that the party has proxy authority (must have been issued or prepared within the last six months)

If a delegated agent,

One copy of a letter of attorney prescribed by Community Trust Bank

One copy of the individual’s seal registration certificate (must have been issued or prepared within the last six months)

Fees

Basic fee

$1,620 (including tax) for each disclosure request form mentioned above.

Fee payment methods

This fee may be paid (1) in cash (including by registered mail) or (2) by bank transfer. Bank transfers should be made to the following account: Community Trust Bank (financial institution number 0001), main branch (branch code 100), account number 0040029 (current account).

Response method and period

In principle, a response document will be posted to the address specified by the applicant within 10 business days of receiving the application.

If disclosure is refused

Disclosure may be refused for legal reasons in cases such as those listed below. In this event, the decision will be communicated along with an explanation for the decision. The specified fees will be charged even in the event of a non-disclosure decision.

If a request for disclosure, etc., does not apply to retained personal data

If there is difficulty in identifying the retained personal data requested, or if searching easily for such data is deemed impossible

If disclosure would expose the applicant or a third party to the risk of harm to life, limb, assets or other interests

If disclosure would expose Community Trust Bank to the risk of significant damage to its proper conduct of business

In other cases that contravene the Act

(3) Corrections, Additions and Deletions

Where to submit application

Community Trust Bank office with which the applicant conducts business

Application method, documents to provide, etc.

The applicant should apply to the Community Trust Bank office with which he or she conducts business. (After confirming the contents of the application, Community Trust Bank may ask the applicant to complete and submit a request form specified by Community Trust Bank for the correction, etc., of specified retained personal data.)

Personal identification methods (including method of confirming proxy’s power of attorney)

To be performed as under Disclosure (2)

Response method, timing, etc.

In principle, a response will be provided within 10 business days of receiving the application, either verbally or in writing.

If correction, addition or deletion is refused

Correction, addition or deletion may be refused in the cases listed below. In the event of a decision against correction, addition or deletion, this decision will be communicated, along with an explanation of the basis or reason for the decision.

If the content of the requested correction, etc., is untrue or if its truth cannot be verified

If the content of the requested correction, etc., is information that Community Trust Bank has evaluated or added

If the content of the requested correction, etc., is considered of little importance to achieving the purpose of use

(4) Discontinuance of Use, Erasure, and Discontinuance of Provision to a Third Party

Where to submit application

Community Trust Bank office with which the applicant conducts business

Application method, required documents, etc.

The applicant should respond to the Community Trust Bank office with which he or she conducts business. (After confirming the contents of the application, Community Trust Bank may ask the applicant to complete and submit a request form specified by Community Trust Bank for the correction, etc., of specified retained personal data.)

Personal identification methods (including method of confirming proxy’s power of attorney)

To be performed as under Disclosure (2)

Response method, timing, etc.

In principle, a response will be provided within 10 business days of receiving the application, either verbally or in writing.

If discontinuance of use, erasure, or provision to a third party is refused

In cases such as those indicated below, the discontinuance of use, erasure, or provision to a third party may be refused. In the event of a decision not to discontinue use, erasure, or provision to a third party, this decision will be communicated to the applicant along with an explanation for the decision.

If the content of the request for discontinuance of use, etc., is untrue or if its truth cannot be verified

Where to Direct Complaints Related to the Handling of Retained Personal Data

Please direct opinions or requests concerning the handling of retained personal data to the Community Trust Bank office with which the applicant does business or to the respective telephone numbers given below.

Hours: Weekdays (except for national and year-end holidays), 9:30 a.m. to 12:00 noon and 1:00 p.m. to 5:00 p.m.

Basic Policy on the Handling of Specific Personal Information

Community Trust Bank. (“Community Trust Bank”) has prepared the following basic policy to ensure that specific personal information and individual numbers (“personal information”) are properly handled on an organization-wide basis under the Act on the Use of Numbers to Identify Specific Individuals in Administrative Procedures (the “My Number Act”).

Name of enterprise

Community Trust Bank.

Compliance with related acts and guidelines

Community Trust Bank shall ensure the proper handling of specific personal information in compliance with the My Number Act, the Act on the Protection of Personal Information, and other related legislation, as well as the Guidelines on the Proper Handling of Specific Personal Information (Enterprise Edition) and other related guidelines.

Purposes of use

Community Trust Bank shall use specific personal information for the following purposes.
Specific personal information concerning officers and employees, including their dependent family members (includes jobs related to those listed at right)

Tax withholding

Preparation of declarations concerning tax exemptions for dependents (reassignment), declarations concerning deductions of insurance premiums and special exemptions for salaried workers

Preparation of salary payment notifications

Preparation of written notices concerning the transfer of salaried workers in regard to the special collection of salary payment reports

Preparation of replacement applications for special collection

Preparation of recipient-specific payment records for retirement allowances and other monies

Preparation of declarations of retirement income

Preparation of declarations, written notices, and applications concerning property accumulation savings for house construction and property accumulation pension savings

Notifications concerning health insurance, employees’ pension insurance, and corporate pension insurance

Filing of notifications under the third grade of the national pension plan

Applications and claims concerning health insurance, employees’ pension insurance, and corporate pension insurance

Notifications regarding unemployment insurance and workmen’s compensation insurance

Applications and claims concerning unemployment insurance and workmen’s compensation insurance

Preparation of certificates for unemployment insurance and workmen’s compensation insurance

Specific personal information concerning persons other than officers and employees, including their dependent family members (includes jobs related to those listed at right)

Preparation of payment records for compensation, fees and other outlays

Preparation of payment records for salaries, compensation, pensions, and prize monies paid to non-residents

Preparation of payment records for monies paid to non-residents for projects providing personal services

Preparation of payment records for the use of real estate

Preparation of payment records for the transfer of real estate

Preparation of payment records for commissions involving the sale or rental of real estate

Matters concerning security control measures

Community Trust Bank shall take necessary and appropriate measures to control the security of specific personal information.