Japan Real Estate Asset Management Co., Ltd. (hereinafter referred to as "JREA") seeks to protect and properly handle personal information given that personal information should be handled cautiously under the principle of respecting the personalities of individuals, and has established and publishes the following "Privacy Policy" for the protection of personal information (hereinafter referred to as this "Policy"), as JREA's viewpoints and policies concerning the protection of personal information. With regard to an individual number and specific personal information (respectively defined in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures), JREA establishes separately, and complies with, the "Basic Policy on the Proper Handling of Specific Personal Information, etc.":
１．Declaration on Policies for the Protection of Personal Information
(Compliance with Relevant Laws and Regulations, etc.)
| ■ | JREA, as an business operator handling personal information defined in the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"), seeks to protect and properly handle personal information, in compliance with the Personal Information Protection Act, other laws and regulations concerning the protection of personal information, and rules such as guidelines, as well as this Policy. |
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(Proper Acquisition)
| ■ | JREA acquires personal information by legal and fair means, to the extent necessary for business operations, and does not acquire personal information by false or otherwise fraudulent means. Also, when JREA acquires personal information directly in writing from the person concerned, JREA informs such person of the purpose of use in advance; provided, however, that such indications of purpose of use may be omitted when permitted by laws and regulations, such as cases in which the purpose of use is obvious given the situation in which the personal information is acquired. JREA does not acquire special-care-required personal information without obtaining the consent of the person concerned except in cases provided for by laws and regulations, nor acquire, except in cases provided for in the guideline on the protection of personal information in the financial sector (hereinafter referred to as the "Financial Sector Guideline"), sensitive information (defined in the Financial Sector Guideline). |
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(Prohibition of Use Other Than for Intended Purpose)
| ■ | JREA specifies the purpose of use of personal information and, except in cases permitted under laws and regulations, does not handle personal information beyond the extent necessary to accomplish such purpose of use without the prior consent of the person concerned. JREA does not use sensitive information except in cases provided for in the Financial Sector Guideline. |
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(Securing of Accuracy)
| ■ | JREA seeks to keep personal data accurate and up-to-date, to the extent necessary to accomplish the purpose of use, as well as to delete such personal data without delay when it has become unnecessary to use such personal data. |
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(Security Management Measures)
| ■ | JREA takes necessary and appropriate measures to prevent leakage, loss, or damage (hereinafter referred to as "Leakage, etc.") of personal data handled and to safely manage personal data as follows: |
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| ・ | Take measures to control the entry and exit of employees in areas where personal data is handled, as well as measures to prevent unauthorized persons from viewing personal data; |
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| ・ | Take measures to prevent theft or loss of equipment, electronic media, documents, etc., for handling personal data, and measures to prevent personal data from being easily identified when transporting such equipment, electronic media, etc., including carrying within the business premises; |
| ・ | Implement access controls and limit the scope of personnel in charge and personal information databases to be handled; and |
| ・ | Introduced a mechanism to protect information systems for handling personal data from unauthorized access from outside sources or from unauthorized software. |
| ■ | Please direct inquiries about our safety control measures to the Contact Point described in section 6. below (hereinafter referred to as the "Contact Point"). |
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(Supervision of Employees)
| ■ | When we have our employees handle personal data, we maintain rules and internal records concerning the handling of personal data in order to ensure the safe management of such personal data. We regularly check the status of the handling of personal data, and conduct necessary and appropriate supervision such as regular training for such employees. In addition, we have established an internal reporting and liaison system in the event that leakage, etc., of personal data, or any sign of it is detected. |
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(Supervision of Entrusted Persons)
| ■ | JREA may entrust the handling of personal data in whole or in part, to the extent necessary to accomplish the purpose of use but in such case, JREA exercises necessary and appropriate supervision of the entrusted person in order to ensure the secure management of such personal data. |
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(Understanding of External Environments)
| ■ | When handling personal data in foreign countries, we regularly collect and understand information related to the personal information protection system of the country concerned and take necessary and appropriate safety management measures. |
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(Restrictions on Provision to Third Parties)
| ■ | JREA does not provide personal information to any third party except in cases provided for in Section 4 below, such as when JREA obtains prior consent of the person concerned or when provision is permitted in laws and regulations. JREA does not provide sensitive information to any third party except in cases provided for in the Financial Sector Guideline. |
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(Handling Complaints, etc.)
| ■ | When JREA is consulted with on, or receives complaints, etc. on, the handling of personal information, JREA seeks to investigate the details and respond in an appropriate and prompt manner, within a reasonable period of time. Please be informed that JREA accepts consultations, complaints and other inquiries on the handling of personal information at the contact point provided for in Section 6 below (hereinafter referred to as the "Contact Point"). |
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２．Purpose of Use of Personal Information
JREA handles personal information in the following contents of operations, to the extent necessary to accomplish the purpose of use stated below and, except in cases permitted under laws and regulations, does not handle personal information beyond the extent necessary to accomplish such purpose of use, without the prior consent of the person concerned.
(Contents of Operations)
| (ⅰ) | Asset management operations for an investment corporation and operations incidental or related thereto; and |
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| (ⅱ) | Other operations which an asset management company can conduct and operations incidental or related thereto (including operations in which handling is allowed hereafter). |
(Purpose of Use)
| (ⅰ) | To exercise rights and perform obligations under the Act on Investment Trusts and Investment Corporations (hereinafter referred to as the "Investment Trust Act"), the Companies Act and other relevant laws and regulations, in the relationship between (a) holders of securities issued by the investment corporation from which JREA undertakes asset management (hereinafter referred to as the "Investment Corporation") in accordance with the Investment Trust Act and (b) the Investment Corporation; |
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| (ⅱ) | To ensure that the Investment Corporation notifies the Investment Corporation's investors of information on the Investment Corporation's businesses and provides other various services; |
| (ⅲ) | To take various measures to secure the smooth relationship between the Investment Corporation and its investors; |
| (ⅳ) | To create various data for the purpose of the Investment Corporation's preparation and submission of various reports in accordance with the Investment Trust Act, the Companies Act and other relevant laws and regulations, and management of the information of the Investment Corporation's investors; |
| (ⅴ) | To conduct operations to acquire, dispose of, lease and manage assets which JREA undertakes or other operations pertaining to the asset management conducted in accordance with the Investment Trust Act (including operations pertaining to financing conducted as a part of the asset management), as well as to conduct various operations pertaining to related investigations and reviews; |
| (ⅵ) | To conduct various operations associated with investigations and research, collection and analysis of information, and provision of and guidance on information which are necessary or useful to acquire, dispose of, lease or manage assets which JREA undertakes or other operations pertaining to the asset management conducted in accordance with the Investment Trust Act (including operations pertaining to financing conducted as a part of the asset management); |
| (ⅶ) | To respond to inquiries, etc. on JREA's contents of operations; |
| (ⅷ) | To conduct operations incidental or related to Subsection (i) to Subsection (vii) above; and |
| (ⅸ) | To otherwise conduct JREA's and the Investment Corporation's operations and operations incidental or related thereto in an appropriate and smooth manner. |
３．Personal Information Sources and Acquisition Means
Examples of ways in which JREA acquires personal information are as follows:
| (ⅰ) | Investors of the Investment Corporation and persons who consider purchasing securities issued by the Investment Corporation: JREA acquires information on investors of the Investment Corporation such as their name, address, and number of investment units, by accessing the investors' registry submitted by the administrator of the investors' registry, etc. of the Investment Corporation. JREA may acquire information on persons considering purchasing securities issued by the Investment Corporation such as their name, address and phone number from an inquiry from securities corporations that handle securities issued by the Investment Corporation or from such person directly. JREA may otherwise acquire personal information on investors or creditors of the Investment Corporation such as their name and address, in connection with the exercising of rights or performance of obligations by such investors or creditors; |
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| (ⅱ) | Sellers and purchasers of the Investment Corporation's investment assets or prospective sellers and purchasers thereof or other persons related to the sale and purchase thereof: If individuals, JREA may acquire personal information on such individuals such as their name and address stated on a certificate of seal impression or certified copy of registry, etc. which JREA obtains as an identity verification document for an agreement on the sale and purchase of investment assets. JREA may also acquire personal information on an owner of a neighboring property such as their name and address, in order to confirm the boundary therewith; |
| (ⅲ) | Lessees of the Investment Corporation's investment assets or persons who consider leasing: If individuals, JREA acquires personal information on such individuals such as their name, address, phone number, employer and income, from real estate brokers whom such individuals ask to lease investment assets on their behalf or from property management companies in charge of managing properties. JREA may also acquire personal information similar to that stated above from guarantors. JREA acquires personal information on lessees of investment assets such as the property name, room number, name of lessees, amount paid and amount unpaid, all of which is rent receiving management information, from property management companies. JREA may otherwise acquire personal information on lessees or persons who consider leasing, and other persons related thereto, in order to conduct operations related to each of the foregoing; and |
| (ⅳ) | Other: In addition to cases stated in Subsection (i) to Subsection (iii) above, JREA may acquire personal information such as names, addresses, and phone numbers, employers and titles, for the purpose of use stated in Section 2 above. JREA may also acquire personal information such as names, addresses, and phone numbers as contact information for persons that make inquiries and file complaints, etc. |
４．Restrictions on the Provision of Personal Data to Third Parties
JREA does not provide personal data to any third party except in the following cases. JREA does not provide sensitive information to any third party except in cases provided for in the Financial Sector Guideline:
| (ⅰ) | where JREA obtains consent from the person concerned; |
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| (ⅱ) | where provision is in accordance with laws and regulations; |
| (ⅲ) | where provision is necessary for the protection of human life, body, or property, and when it is difficult to obtain consent from the person concerned; |
| (ⅳ) | where provision is necessary specially for the improvement of public health or the healthy development of children, and when it is difficult to obtain consent from the person concerned; |
| (ⅴ) | where it is necessary for JREA to cooperate with any national government organs, local government, or persons entrusted thereby with performing the functions prescribed by laws and regulations, and when obtaining consent from the person concerned might interfere with performance of these functions; or |
| (Ⅵ) | Where the third party is an academic research institute, etc., and it is necessary for the third party to handle the personal data for academic research purposes (including cases where part of the purpose of handling the personal data is for academic research purposes, and excluding cases where there is a risk of unreasonably infringing the rights and interests of data subjects). |
However, JREA may provide personal data other than to its personnel in cases that do not fall under provision to third parties in the Personal Information Protection Act, such as cases where JREA entrusts the handling of personal information, in whole or in part, to the extent necessary to accomplish the purpose of use.
５．Disclosure, etc., of Retained Personal Data
When JREA receives a request for notification, disclosure, correction, etc., (correction, adding or deletion), suspension of use, etc., (suspension of use or erasure), suspension of provision to third parties, or disclosure of records concerning provision to third parties (hereinafter collectively referred to as the “Request, etc., for Disclosure, etc.”) concerning matters related to the retained personal data pursuant to the Personal Information Protection Act, JREA responds appropriately and without delay pursuant to laws and regulations having first confirmed that such requests are from the person concerned or a duly authorized representative thereof; provided, however, that in the case where human life, body, property or any other rights or interests of the person concerned or any third party might be impaired, JREA may not be able to accept demands for disclosure, etc., and in such case, JREA informs the person concerned or a representative thereof of the reasons therefor, without delay. JREA may ask any person who makes a Request, etc., for Disclosure, etc., of the retained personal data to bear the prescribed charge.
６．Inquiries on Personal Information
Please be informed that JREA accepts the Request, etc. for Disclosure, etc. of retained personal data and other inquiries at the Contact Point below. JREA also accepts consultations, complaints and other inquiries on the handling of personal information at the Contact Point below.
Strategic Planning Department, Japan Real Estate Asset Management Co., Ltd.
| Tel. | +81-3-3211-7951 |
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| Business hours | 9:30am to 5:30pm (closed on weekends, national holidays and the year-end and New Year's holidays) |
Also, JREA is a covered enterprise of the Investment Trusts Association, Japan, an accredited personal information protection organization. Please be informed that the association accepts consultations and complaints, etc. on the handling of personal information by covered enterprises.
Investment Counseling Center, The Investment Trusts Association, Japan
| Tel. | +81-3-5614-8440 |
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Please be informed that the administrator of the investors' registry, etc. of the Investment Corporation accepts inquiries, etc. on personal information relating to entries in the investors' registry of the Investment Corporation.
Corporate Agency Division, Mitsubishi UFJ Trust and Banking Corporation
| Tel. | 0120-232-711 (domestic only) |
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| Business hours | 9:00am to 5:00pm (closed on weekends, national holidays and the year-end and New Year's holidays) |
７．Continuous Improvements to the Personal Information Protection System
JREA seeks to improve the personal information protection system, including this Policy, by reviewing the system on an ongoing basis. JREA may revise this Policy where necessary, in response to revisions, etc. to laws and regulations.
