This notice is relevant to you if you are:

  • an individual associated with a client or potential client of an MUFG EU office, such as, an employee, other representative or beneficial owner of a client; or
  • an individual whose personal data are given to an MUFG EU office by a client or potential client, or which we otherwise receive, in the course of our dealings with that client or potential client.

This notice provides important information about how we process your personal data and your data protection rights.

For convenience, in this privacy statement we refer to our client or potential client whom you represent, or with whom you are otherwise associated, as our “Client".

This privacy notice was last updated on 6 December 2018.

Personal data we collect about you

We may collect and process the following personal data about you:

Personal data that you give us:

  • This is personal data about you that you give to us when filling in forms that we (or our Client on our behalf) ask you to complete or corresponding with us by email, telephone, post or otherwise. It may include, for example, your name, address, email address and telephone number; information about your business relationship with us; information about your professional role and background; limited details of your personal life; and identification documentation for verification and authorisation purposes.

    If you do not provide personal data that we request, we may not be able to provide (or continue providing) relevant services to or otherwise do business with you or our Client.

    If you are providing us with personal data about other individuals, such as your colleagues, please inform them of the purpose for which you are providing us the personal data and ensure they are aware of this notice.

Personal data that our systems collect about you:

  • If you exchange emails, telephone conversations or other electronic communications with us and our staff members, our information technology systems may record details of those communications, including their content.
  • If you visit our websites they will collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as your browser type and the pages on our site that you visit. Our websites may also download "cookies" to your device as described in our separate cookie statements on our websites if applicable.
  • Our premises have closed circuit TV systems and building access controls for security and safety purposes which may record you if you visit our premises.

Other personal data: We may also collect some personal data from other sources. In particular:

  • Your colleagues or other business contacts may give us personal data about you, such as your contact details or details of your role in our relationship with our Client. If we need to conduct anti-money-laundering or similar background checks involving you this may require more extensive personal data about you – for example, a copy of your passport.
  • We sometimes collect personal data from third party data providers, international sanctions lists, the internet or other publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.

Why we process your personal data

We process your personal data, as necessary to pursue our legitimate business and other interests, for the following purposes:

  • providing our products and services to our Client, including to ensure that agreements with and instructions from our Client are authorised and validly executed;
  • business development (including marketing of our products and services to our Client – we will not send marketing communications to you in your personal capacity) and managing our relationship with our Client;
  • assessing and managing the risks facing our businesses, including detecting and preventing fraud and other financial crimes;
  • managing and improving our systems and processes, including through monitoring and managing their usage;
  • complying with, or directly or indirectly facilitating compliance with, the requirements in any jurisdiction of any exchange, trading facility, trading system, organised market, clearing house, settlement system, exchange or other infrastructure provider to facilitate clearing and settlement (a “Market");
  • protecting the security and integrity of our premises, information technology systems and information;
  • investigating and responding to complaints and other incidents affecting our or our clients' businesses; and
  • enforcing and defending our legal rights and those of our clients, staff and affiliates, including potential legal claims or disputes.

We also process your personal data to comply with law and regulation and as necessary to pursue our legitimate interests in directly or indirectly facilitating compliance with the requirements of the law, co-operating with our regulators and other authorities, complying with foreign laws, preventing or detecting financial and other crimes and regulatory breaches, and protecting our businesses and the integrity of the financial markets. This involves processing your personal data for the following purposes:

  • carrying out know-your-client (“KYC"), anti-money laundering, anti-terrorism, anti-market-abuse, anti-bribery and corruption, anti-fraud / other financial crime and sanctions compliance activities, including identity checks and background screening ;
  • monitoring transactions and reporting on them to competent authorities;
  • keeping records of communications with our Client, including recording telephone, emails and instant messaging; and
  • responding to enquires from, and otherwise co-operating with, regulatory, tax, law enforcement and other governmental agencies, Markets, brokers or other intermediaries or counterparties and courts.

Personal data collected by us for the sole purpose of preventing money laundering and terrorist financing may not be processed in a manner incompatible with these purposes unless we have obtained the individual's express consent or we are otherwise permitted by law.

To whom do we disclose your personal data?

We will disclose personal data about you, where reasonably necessary for the various purposes set out above, to:

  • other members of the worldwide MUFG group of companies. Details of group may be found at http://www.mufg.jp/english/profile/globalnetwork/;
  • your colleagues representing our Client;
  • counterparty financial institutions, Markets and other persons from whom we receive, or to whom we make, payments, or with whom we conduct other transactions;
  • our legal, accounting and other professional advisors, so that they can advise us;
  • service providers who hold or process your personal data on our behalf, under strict conditions of confidentiality and security;
  • persons who take over our business and assets, or relevant parts of them;
  • regulatory, tax, law enforcement or other governmental agencies, courts or litigation counterparties, in any country or territory; and
  • other persons where we are required by law to disclose.

These disclosures may involve transferring your personal data abroad. You should be aware that this may include transfers to countries outside the European Economic Area, which do not have similarly strict data privacy laws, including, for example, Japan and the United States of America. In those cases, we will put in place appropriate safeguards such as data transfer agreements based on the European Commission's standard contractual clauses in accordance with article 46(2) of the EU General Data Protection Regulation. You may contact us for further information.

For how long do we keep your personal data?

We retain personal data only for as long as reasonably necessary for the purposes described above or as long as required by law or to resolve potential legal claims or disputes.

Your data protection rights

You have a right of access to the personal data that we hold about you, and to some related information, under data protection law. You can also require any inaccurate personal data to be corrected or deleted.

You can object to our use of your personal data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal data (and require them to be deleted), or to restrict our processing of your information to the bare minimum, in some other circumstances.

Please contact us if you wish to exercise any of these rights.

You can also lodge complaints with the local data protection authority, either where you live or work or where the relevant MUFG office is located.

How to contact us

If you have any questions about this privacy notice or our processing of your personal data, or if you wish to exercise your data protection rights, our contact details are below. We are committed to working with you to obtain a fair resolution of any complaint or concerns about privacy.

MUFG Bank, Ltd

United Kingdom
Data Protection Officer
MUFG Bank, Ltd., London Branch
Ropemaker Place, 25 Ropemaker Street,
London EC2Y 9AN
dpo@uk.mufg.jp

France
Data Protection Officer
MUFG Bank, Ltd., Paris Branch
Le Centorial, 18, rue du Quatre Septembre
75002 Paris
France
paris.dpo@fr.mufg.jp

Italy
Data Protection Officer
MUFG Bank, Ltd., Milano Branch
Via Filippo Turati, 9
20121 Milano
Republic of Italy
dpo@ita.mufg.jp

MUFG Bank (Europe) N.V.

The Netherlands, Austria, Belgium, Czech Republic, Poland, Portugal, Spain
Data Protection Officer
MUFG Bank (Europe) N.V.
World Trade Center, Tower I, Strawinskylaan 1887
1077 XX Amsterdam
The Netherlands
dpo@nl.mufg.jp

Germany
Data Protection Officer
MUFG Bank (Europe) N.V., Germany branch
Breite Strasse 34, 40213 Dusseldorf
Germany
erdmann@sicdata.de

MUFG Securities EMEA plc

United Kingdom
Data Protection Officer
MUFG Securities EMEA plc
Ropemaker Place, 25 Ropemaker Street,
London EC2Y 9AJ, United Kingdom
dpo@uk.mufg.jp

MUFG Securities (Europe) N.V.

The Netherlands
Data Protection Officer
MUFG Securities (Europe) N.V.
World Trade Centre, Starwinskylaan 1887
1077 XX Amsterdam
The Netherlands
dpo@uk.mufg.jp

France
Data Protection Officer
MUFG Securities (Europe) N.V.
Le Centorial, 18, rue du Quatre Septembre
75080 Paris
France
dpo@uk.mufg.jp