NOTICE
We never solicit investments, request money transfers, or ask for personal information from individual customers. Please be highly vigilant against fraudulent activities impersonating our company representatives.
Should you receive any suspicious contact, please promptly consult your nearest police station or consumer affairs center.
Process For Resolving Complaints
SILQ Capital (“Company”) aims to respond to any complaints from customers promptly and in a forthright manner. The Company follows its internal policy established for complaint handling. Complaints may be registered with the Company through either of the following methods of contact:
Phone: +81-3-6555-0100
Email: notices@silq-capital.com
In addition, customers may lodge complaints through the independent non-profit corporation, Financial Instruments Mediation Assistance Center (FINMAC). FINMAC is contracted by Investment Management Association of Japan (IMAJ) with which SILQ Capital is a registered member, and is a mediator for conflicts concerning the investment management business. The contact information for FINMAC is as follows:
Phone: 0120-64-5005 (toll free)
Process For Resolving Conflicts
The Company resolves conflicts with customers utilizing mediation by FINMAC. Please refer to contact details provided above. The standard process of mediation through FINMAC is as follows:
A request for mediation is made by the customer.
Acceptance of the mediation and the selection of a mediation committee by FINMAC
Payment of the filing fee by the customer
Hearing to both the customer and the Company by the mediation committee
Proposal and acceptance of mediation
For further details please refer to FINMAC’s website: http://finmac.or.jp
Privacy Notice
SILQ Capital Co., Ltd. (the “Company”) recognizes the importance of personal information in conducting its hedge fund management and related businesses. The Company handles personal information appropriately in compliance with the Act on the Protection of Personal Information (“APPI”), guidelines issued by the Financial Services Agency, and other applicable laws and regulations.
1. Compliance with Laws and Regulations
The Company complies with the APPI and other applicable laws, regulations, and guidelines, and handles personal information appropriately in light of the nature of its asset management business.
2. Purpose of Use of Personal Information
The Company uses acquired personal information only within the scope necessary to achieve the following purposes:
· Conducting identity verification (KYC) and transaction verification procedures for investors
· Assessing and evaluating investor suitability
· Opening accounts, entering into agreements, and maintaining ongoing relationships
· Executing investment management services and transactions
· Providing communications regarding investments and accounts
· Responding to anti-money laundering and counter-terrorism financing requirements
· Making reports and filings in accordance with applicable laws and regulations (including to the Financial Services Agency and tax authorities)
· Risk management, internal controls, and audits
· Responding to inquiries and various requests
· Recruitment activities, including evaluation of applicants, communication, and hiring decisions
The Company does not use personal information for marketing purposes.
3. Categories of Personal Information Collected
The Company may collect the following personal information to the extent necessary for its business:
· Name, address, date of birth, and nationality
· Contact details such as telephone number and email address
· Identification documents and related verification information
· Financial information, including assets and investment experience
· Transaction history and account information
· For recruitment purposes: employment history, education, and qualifications
The Company does not, in principle, collect or use sensitive personal information (as defined under APPI), except where required by law.
4. Provision of Personal Data to Third Parties
The Company does not provide personal data to third parties without the prior consent of the individual, except where permitted under applicable laws and regulations.
However, personal data may be provided to the following third parties to the extent necessary to achieve the purposes described above:
· Fund administrators and custodians
· Tax and accounting advisors, audit firms, legal and other professional services
· Outsourcing service providers
· Supervisory authorities and other public institutions
In such cases, the Company will require such third parties to implement appropriate security management measures and will ensure proper handling of personal data through contractual or other appropriate arrangements.
Individuals may request the suspension of third-party provision in accordance with applicable laws and regulations.
5. Provision to Third Parties Located Outside Japan
The Company may provide personal data to third parties located outside Japan to the extent necessary for its business operations.
In such cases, the Company will take measures in accordance with APPI, including:
· Confirming that the recipient is in a country recognized as having an adequate level of data protection under applicable law;
· Confirming that the recipient has established a system to continuously implement appropriate protection measures consistent with the principles of APPI, and ensuring such measures through contractual or other arrangements where necessary; or
· Obtaining prior consent from the individual where required by law
6. Entrustment of Personal Data Processing
The Company may entrust the handling of personal data, in whole or in part, to third parties within the scope necessary to achieve the purposes of use.
In such cases, from the standpoint of personal data protection, the Company will appropriately select service providers that meet the standards we require, enter into contracts with them, and exercise necessary and appropriate supervision over them.
7. Security Management Measures
The Company implements necessary and appropriate measures to prevent leakage, loss, or damage of personal data and to otherwise ensure its secure management.
Such measures include:
· Access controls and authentication management
· Encryption of electronic data
· Proper storage and management of physical documents
· System logging and monitoring
· Employee training and internal rules and procedures
8. Retention Period of Personal Data
The Company retains personal data only for the period necessary to achieve the purposes of use or as required by applicable laws and regulations.
Furthermore, after the retention period has elapsed, the personal data will be properly deleted or disposed of.
9. Requests for Disclosure, etc.
The Company will respond to requests from individuals or their representatives regarding retained personal data in accordance with APPI, including:
· Notification of purpose of use
· Disclosure
· Correction, addition, or deletion
· Suspension of use or erasure
· Suspension of provision to third parties
When making such requests, the following information must be provided:
· Documentation to verify the identity of the requester
· Details of the request
· Information sufficient to identify the relevant personal data
A reasonable fee may be charged in accordance with applicable laws and regulations.
10. Contact Information
For inquiries regarding the handling of personal information or to exercise your rights, please contact:
SILQ Capital Co., Ltd.
the ARGYLE aoyama 15F 2-14-4, Kita-Aoyama, Minato-ku, Tokyo 107-0061
Operations Manager
Email: notices@silq-capital.com
11. Internal Governance Framework
The Company has established an internal framework to ensure the proper management of personal information, including:
· Appointment of a person responsible for personal information management
· Development of internal rules and procedures
· Employee education and training
· Periodic internal audits and compliance checks
12. Continuous Improvement
The Company will continuously review and improve its handling of personal information in response to changes in laws, regulations, and business practices.
13. Public Disclosure
This Policy is made publicly available on the Company’s website and through other appropriate means.