Peninsula Assets Management
Tokyo, Japan
Last Updated: November 17, 2025
Introduction
Peninsula Assets Management (“Peninsula,” “we,” “us,” or “our”) recognizes the importance of protecting personal information and is committed to handling such information appropriately in accordance with the Act on the Protection of Personal Information of Japan (“APPI”) and other applicable laws and regulations.
This Privacy Policy explains how we collect, use, manage, and protect personal information obtained through our website (the “Site”) and in the course of providing our services.
Definition of Personal Information
For purposes of this Policy, “Personal Information” means information relating to a living individual that can identify the individual by name, date of birth, address, telephone number, email address, identification number, or other description, as defined under the APPI.
It may also include information that, when combined with other information, can identify a specific individual.
Information We Collect
We may collect the following categories of information:
(a) Information Provided Directly by You
- Name
- Address
- Telephone number
- Email address
- Employer and job title
- Financial and investment information (where applicable)
- Identification documents (as required for regulatory compliance)
(b) Automatically Collected Information
When you visit our Site, we may collect:
- IP address
- Browser type and version
- Device information
- Pages visited
- Access times
- Referring website addresses
(c) Regulatory and Compliance Information
Where required under applicable laws (including anti-money laundering and know-your-customer obligations), we may collect:
- Identity verification documentation
- Source of funds information
- Tax residency information
- Politically exposed person (PEP) status
Purpose of Use
We collect and use Personal Information for the following purposes:
- To provide asset management and investment advisory services
- To evaluate suitability and onboarding of clients
- To comply with legal and regulatory obligations
- To conduct identity verification and AML/CFT procedures
- To communicate with clients and prospective clients
- To improve our website and services
- To respond to inquiries
- To maintain internal records and risk management controls
We will not use Personal Information beyond the scope necessary to achieve these purposes without obtaining additional consent where required by law.
Legal Basis for Processing
We process Personal Information based on:
- Performance of contractual obligations
- Compliance with legal and regulatory requirements
- Legitimate business interests
- Consent, where required
Sharing and Disclosure of Information
We do not sell Personal Information.
We may disclose Personal Information when legally required or approved to:
- Regulatory authorities (including the Financial Services Agency of Japan)
- Service providers (e.g., custodians, administrators, IT providers, compliance consultants)
- Auditors, legal advisers, and professional consultants
- Financial institutions and counterparties
- Affiliates, where applicable
Such disclosures are limited to what is necessary for the purposes described in this Policy.
Cross-Border Transfers
Where Personal Information is transferred outside Japan, we will ensure that appropriate safeguards are in place in accordance with APPI requirements. This may include contractual protections or transfers to jurisdictions recognized as having adequate data protection standards.
Data Retention
We retain Personal Information only for as long as necessary to:
- Fulfill the purposes described above
- Comply with legal and regulatory retention requirements
- Resolve disputes and enforce agreements
Retention periods may be determined by financial regulations, tax laws, and anti-money laundering requirements.
Data Security
We implement appropriate administrative, technical, and physical safeguards to protect Personal Information against:
- Unauthorized access
- Loss
- Alteration
- Disclosure
- Destruction
Security measures include restricted access controls, encrypted systems (where appropriate), internal compliance policies, and periodic risk assessments.
Your Rights
Under the APPI and applicable laws, you may have the right to:
- Request disclosure of your Personal Information
- Request correction, addition, or deletion
- Request suspension of use
- Request cessation of third-party provision
- Request notification of purpose of use
Requests must be submitted in writing to the contact information provided below. We may require identity verification before responding.
Cookies and Tracking Technologies
Our Site may use cookies or similar technologies to:
- Improve functionality
- Analyze website usage
- Enhance user experience
You may configure your browser to refuse cookies; however, this may affect Site functionality.
Handling of Anonymized and Statistical Data
We may use anonymized or aggregated information for internal analysis, research, or statistical purposes. Such data does not identify individuals.
Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy at any time. Updates will be posted on this Site with a revised “Last Updated” date.
Contact Information
If you have questions regarding this Privacy Policy or wish to exercise your rights, please contact:
Peninsula Assets Management
Tokyo, Japan
info@pen-assets.com