Privacy Policy

This Privacy Policy explains how we collect, use, disclose, and protect Personal Data obtained through the Site, including pages such as Careers/Open Roles, newsletter sign-ups, and contact forms. (Your site plan and materials indicate a careers/open-jobs page and contact channel with the email above.)

1) Who we are and scope

• Controller: GBM Asset Management (Japan) Co., Ltd., Toranomon Hills, Tokyo 105-6408; info@gbmam.co.jp.  
• This Policy covers Personal Data collected via the Site and in connection with Site-related communications (e.g., when you apply for a role, request information, or subscribe to updates).
  

2) What we collect

We may collect:

• Identification and contact data (e.g., name, email, phone, company, role/title).
• Professional data (e.g., CV/resumé, certifications, work history) when you apply for roles via the careers page.  
• Technical data (e.g., IP address, device/browser type, pages viewed, time and date, referring URL).
• Communications data (e.g., inquiries sent to info@gbmam.co.jp).  
• Cookies and similar technologies (see §7).
  

We may collect data from you directly (forms, email) and automatically (cookies, logs). We may also receive data from service providers supporting our Site (hosting, analytics, security) or recruitment tools you use to apply.

‍3) How we use Personal Data

We use Personal Data to:

• Operate, maintain, and improve the Site (including troubleshooting, analytics, security, and preventing fraud/abuse).
• Respond to inquiries and provide information about GBM AM (e.g., strategies, platform, or general updates).  
• Process career applications (evaluate candidacies, schedule interviews, maintain recruiting records).  
• Comply with legal obligations and enforce our Terms.
• Communicate administrative notices and changes to this Policy or the Site.
  

Legal bases (where required, e.g., EEA/UK): (i) legitimate interests (to operate a secure, effective Site; to respond to requests; to recruit talent); (ii) consent (for certain cookies/marketing); (iii) legal obligations.

4) Disclosures of Personal Data

We may share Personal Data with:

• Affiliates within the GBM group (for Site administration, security, compliance, and recruitment operations consistent with this Policy). (Your materials describe a group structure with affiliates; we reference them as “affiliates” without implying any specific license status.)  
• Service providers (hosting, cloud, analytics, security, email delivery, recruitment tools) under contracts requiring confidentiality and appropriate safeguards.
• Professional advisers (e.g., legal counsel) and where required, authorities (to comply with law or protect rights).
• Business transfers: in connection with a corporate transaction (e.g., reorganization, merger, asset sale).
  

We do not sell your Personal Data.

5) International transfers

Given our global operations and infrastructure, Personal Data may be processed in countries outside your own. Where required, we implement appropriate safeguards (e.g., standard contractual clauses) for cross-border transfers.

6) Data security

We maintain administrative, technical, and physical safeguards designed to protect Personal Data against unauthorized access, loss, misuse, or alteration. These measures are aligned with our broader platform emphasis on centralized risk and robust controls.  

7) Cookies & similar technologies

• Essential cookies enable core functionality (e.g., page navigation, session management).
• Analytics/performance cookies help us understand Site usage and improve performance.
• Preference cookies remember choices (e.g., language toggle for English/Japanese), which your outline anticipates.  
  

Where required by law, we will request consent for non-essential cookies. You can control cookies through your browser settings; however, disabling certain cookies may affect Site functionality.

8) Retention

We retain Personal Data only as long as necessary for the purposes described in this Policy (e.g., to process an application or respond to an inquiry), to comply with legal, regulatory, accounting, or reporting obligations, and to resolve disputes.

9) Your rights

Depending on your jurisdiction, you may have rights to request access, correction, deletion, restriction, or portability of your Personal Data, and to object to certain processing. Where we rely on consent, you may withdraw it at any time (this will not affect processing prior to withdrawal). To exercise rights, contact us at info@gbmam.co.jp. We will respond as required by applicable law.  

10) Children’s privacy

The Site is not directed to children, and we do not knowingly collect Personal Data from children.

11) Careers (additional notice)

If you submit a CV/resumé or other application materials through the Site or by email, we will use that information solely for recruiting and employment-related purposes, share it only with personnel and service providers involved in hiring, and retain it consistent with our retention practices.  

12) Changes to this Policy

We may update this Policy from time to time. The “Last updated” date at the top indicates the latest revision.

13) How to contact us

Questions or requests regarding this Policy or your Personal Data:

GBM Asset Management (Japan) Co., Ltd. • Toranomon Hills, Tokyo 105-6408 • info@gbmam.co.jp