Privacy Policy

Ark Mori Building 31F, 1-12-32 Akasaka, Minato-ku, Tokyo

Capital Servicing Co., Ltd.

Representative Director Daniel Shireman


Establishment date: December 3, 2014

Last revised date: December 1, 2023


Privacy Policy


As a debt management and collection company,our company strives to protect personal information and thoroughly complieswith the "Act on the Protection of Personal Information" (hereinafterreferred to as the "Personal Information Protection Act") and relatedlaws and regulations. In order to thoroughly implement the above as ourcorporate philosophy, we will do our best to protect personal information inaccordance with the following policy.


1. Our company acquires, uses, and providespersonal information appropriately considering the content and scale of thebusiness, and does not handle personal information beyond the scope necessaryto achieve the specified purpose of use. We will also take measures for thispurpose.


2. Our company complies with laws andregulations, guidelines established by the government, and other normsregarding the handling of personal information.


3. Our company will take reasonable safetymeasures to prevent risks such as leakage, loss, and damage of personalinformation, and will build and continually improve the rules and systems.Additionally, in the event of an emergency, we will promptly take correctivemeasures.


4. Our company will promptly and honestly respond to complaints and consultations regarding the handling of personal information.


5. We will review our personal information protection management system in a timely and appropriate manner and continually strive to improve it, taking into account changes in the environment surrounding our company and the actual situation.


*For inquiries and consultations regarding the personal information protection policy and personal information, please contact the following contact point.



Handling of Personal Information


1. Proper acquisition of personal information

Our company shall clearly define the purpose of use of personal information and acquire personal information in an appropriate and fair manner to the extent necessary to achieve the purpose of use.


2. Purpose of use of personal information

Personal information acquired by our company will be used for the following purposes, and personal information will not be handled beyond these scopes without the consent of the individual. Furthermore, when using personal information, we will not use personal information inappropriately.

(1) Customer personal information

We will use your information to carry out thetasks listed below and to contact you as necessary.

Management and collection of specific monetaryclaims

Purchase of monetary claims other thanspecified monetary claims (non-specified monetary claims)

Administrative agency services for debtpurchasing companies, etc.

Collection agency service

Succession of the status of policyholders ofgroup credit life insurance contracts (collection of group credit lifeinsurance premiums, etc.) and preparation of group credit life insurancereports

Asset securitization/securitization relatedoperations (specified corporate bond related operations)

Servicer reporting industry

General affairs, human resources, accounting,IT support and internal audit operations

Servicer/consulting business

Buying and selling of specified monetaryclaims and brokerage of buying and selling of specified monetary claims

Administrative agency services related to duediligence services and receivables transfer procedures

Money lending business (intermediary forlending and borrowing money)

Administrative agency services related to financingoperations

Arrangement services related to assetsecuritization and securitization

(2) Personal information of those who havemade inquiries or requested materials.

The personal information of those who inquireabout our business will be used to respond to your inquiry.

(3)Personal information of employment applicants

Used for recruitment selection and relatedcommunications, etc.

(4) Our employee information

It is used for personnel and labor management, business management, welfare benefits, health management, security management, etc.

 (5) Personal number information provided by you

It is used for "social insurance procedures", "tax processing", etc. specified by law.


Dissemination of matters regarding retained personal data and records provided to third parties


Our company requests disclosure of retained personal data (notification of purpose of use, disclosure, correction, addition or deletion of content, suspension of use, erasure, and suspension of provision to third parties) and disclosure of records provided to third parties. We would like to inform you of the following regarding claims.


1. Name and address of our company, name of representative/personal information protection manager

Name: Capital Servicing Co., Ltd.

Address: Ark Mori Building 31F,1-12-32 Akasaka, Minato-ku, Tokyo

Representative: Daniel Shireman

Administrator: Senior Legal & Compliance Officer



2. Purpose of use of retained personal data

Purpose of use as described in "Handlingof personal information" above.


3. Ensuring the safety and accuracy ofpersonal data

In order to ensure the safety and accuracy ofpersonal data, our company will implement the following measures as safetymanagement measures. For details, please contact the Personal InformationConsultation Desk.


In order to ensure the appropriate handling ofretained personal data, we have established policies regarding compliance withrelated laws and guidelines, as well as responses to questions and complaints.


We have established personal informationmanagement regulations that stipulate handling methods, persons in charge,their duties, etc. for each stage of personal information acquisition, use,storage, provision, deletion, and disposal. We have also developed varioushandling regulations for managing subcontractors and responding to leakageincidents.


As an organizational safety measure, we haveestablished a personal information protection manager for personal informationprotection, and established department managers in each department to clarifyroles and responsibilities. We have put in place a system to report to theperson in charge when we learn of something. In order to understand thehandling status of personal data, we have created a ledger and regularlyconduct operational management and internal audits.


As a human security management measure, weregularly conduct in-house training for employees, including matters to benoted regarding the handling of personal data, and provide thorough educationand training on safety management, etc. Furthermore, we will conclude personaldata non-disclosure agreements with employees, clarify the roles andresponsibilities of employees, and confirm the status of employee compliancewith personal data management procedures.


As a physical security measure, we controlentry and exit in areas where personal data is handled, and also take measuresto prevent unauthorized persons from viewing personal data. We manage devices,electronic media, documents, etc. that handle personal data by locking them,setting passwords, etc., and take measures to prevent theft, loss, etc., andwhen carrying such devices, it is easy for personal data to be We are takingmeasures to prevent this from becoming known.


As technical safety measures, we will identifyand authenticate users of personal data, restrict and manage access privilegesto users, and limit the scope of users and personal information databases, etc.handled. I am teaching. We also take measures to prevent leaks and damage topersonal data, such as recording and analyzing the operating status ofinformation systems that access and handle personal data, and monitor and auditthese systems. Masu.


In order to understand the external environment,when storing personal data in a foreign country, we will implement safetymanagement measures after understanding the laws regarding the protection ofpersonal information and other related laws and regulations in that foreigncountry.


4. Supervision of employees

We will conduct education and training so thatour executives and employees understand the importance of protecting personalinformation and manage personal information safely.


5. Supervision of subcontractors

When outsourcing the handling of personalinformation, our company will select a subcontractor that can comply with ourpersonal information protection policy, and will adequately manage andsupervise its handling. In addition, when a subcontractor subcontracts, wesupervise whether the subcontractor is providing necessary and appropriatesupervision over the subcontractor.


6. Disclosure of retained personal data, etc.

If we receive a request for disclosure ofpersonal data held by our company or records provided to a third party, we willrespond in writing after verifying the identity in accordance with laws andregulations and in accordance with our company's regulations. We will respondby sending a CD-R (or DVD-R) or an email attachment (in the case of a requestfrom a representative, we will provide proof of identity as designated bygovernment ordinance and disclosure, etc.) (In this case, you will need tosubmit official documentation to support it.) Please note that the disclosurefee will be 3,000 yen (excluding consumption tax) per item. For details, pleasecontact the Personal Information Consultation Desk.


7. Execution of internal control program

Our company has established an internalcontrol program to ensure the protection and proper management of personal information,provides thorough education and training, and supervises the program, andstrives to ensure that employees understand and comply with the program. Wewill periodically revise the program in response to the social environment,legal revisions, etc.


8.About the certified personal informationprotection organizations that our company is a member of

There is no certified personal informationprotection organization that our company is affiliated with.



For inquiries and consultation regarding thehandling of personal information, please contact us below.


Personal information consultation desk

TEL: 03-6230-5542


Telephone reception hours Monday to Friday9:30 to 17:00

(Excluding public holidays and year-end andNew Year holidays)

FAX: 03-6230-5220



Delivery address:

Ark Mori Building 31F, 1-12-32Akasaka, Minato-ku, Tokyo 107-6031

Capital Servicing Co., Ltd.

Personal information consultation desk