Japan Real Estate Investment Corporation

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Privacy Policy

Japan Real Estate Investment Corporation (hereinafter referred to as "JRE") 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 JRE'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), JRE 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.)

JRE, 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.

(Proper Acquisition)

JRE 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 JRE acquires personal information directly in writing from the person concerned, JRE 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.
JRE 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).

(Prohibition of Use Other Than for Intended Purpose)

JRE 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.
JRE does not use sensitive information except in cases provided for in the Financial Sector Guideline.

(Securing of Accuracy)

JRE 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.

(Security Management Measures)

JRE takes necessary and appropriate measures to ensure the secure management of personal data, such as measures to prevent leakage, loss, or damage to the personal data.

(Supervision of Entrusted Persons)

In the cases where, for example, (a) JRE entrusts asset management operations to an asset management company, (b) JRE entrusts clerical work such as an entry or recording in the investors' registry to the administrator of the investors' registry, etc., or (c) JRE requests any real estate broker to provide agency or mediation services for sale and purchase or lease of property, JRE may entrust the handling of personal data in whole or in part, to the extent necessary to accomplish the purpose of use.
When JRE entrusts the handling of personal data in whole or in part, JRE exercises necessary and appropriate supervision of the entrusted person in order to ensure the secure management of such personal data the handling of which has been outsourced.

(Restrictions on Provision to Third Parties)

JRE does not provide personal information to any third party except in cases provided for in Section 4 below, such as when JRE obtains prior consent of the person concerned or when provision is permitted in laws and regulations.
JRE does not provide sensitive information to any third party except in cases provided for in the Financial Sector Guideline.

(Handling Complaints, etc.)

When JRE is consulted with on, or receives complaints, etc. on, the handling of personal information, JRE seeks to investigate the details and respond in an appropriate and prompt manner, within a reasonable period of time. Please be informed that JRE 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").

2. Purpose of Use of Personal Information

The content of operation of JRE is investing assets mainly into the specified assets under the Act on Investment Trusts and Investment Corporations (hereinafter referred to as the "Investment Trust Act"). JRE handles personal information in the course 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.

(Purpose of Use)

(ⅰ) To exercise rights and perform obligations under the Investment Trust Act, the Companies Act and other relevant laws and regulations, in the relationship between (a) holders of securities issued by JRE and (b) JRE;
(ⅱ) To ensure that JRE notifies JRE's investors of information on JRE's businesses and provides other various services;
(ⅲ) To take various measures to secure the smooth relationship between JRE's investors and JRE;
(ⅳ) To create various data for the purpose of the 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 JRE's investors;
(ⅴ) To conduct operations to acquire, dispose of, lease and manage assets by JRE 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 by JRE 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 additional issuance of investment units or issuance of investment corporation bonds, etc. by JRE;
(ⅷ) To conduct operations incidental or related to Subsection (ⅰ) to Subsection (ⅶ) above; and
(ⅸ) To otherwise conduct JRE's operations and operations incidental or related to general clerical work in an appropriate and smooth manner.

3. Personal Information Sources and Acquisition Means

Examples of ways in which JRE acquires personal information are as follows:

(ⅰ) Investors of JRE and persons who consider purchasing securities issued by JRE:
JRE acquires information on investors of JRE such as their name, address, and number of investment units, by accessing the investors' registry submitted by the administrator of the investors' registry, etc..
JRE may acquire information on persons considering purchasing securities issued by JRE such as their name, address and phone number from an inquiry from securities corporations that handle securities issued by JRE or from such person directly.
JRE may otherwise acquire personal information on investors or creditors of JRE such as their name and address, in connection with the exercising of rights or performance of obligations by such investors or creditors;
(ⅱ) Sellers and purchasers of JRE's investment assets or prospective sellers and purchasers thereof or other persons related to the sale and purchase thereof:
If individuals, JRE 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 JRE obtains as an identity verification document for an agreement on the sale and purchase of investment assets.
JRE 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 JRE's investment assets or persons who consider leasing:
If individuals, JRE 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. JRE may also acquire personal information similar to that stated above from guarantors.
JRE 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.
JRE 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, JRE may acquire personal information such as names, addresses, and phone numbers, employers and titles, for the purpose of use stated in Section 2 above.
JRE 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

JRE does not provide personal data to any third party except in the following cases. JRE does not provide sensitive information to any third party except in cases provided for in the Financial Sector Guideline:

(ⅰ) where JRE obtains consent from the person concerned;
(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; or
(ⅴ) where it is necessary for JRE 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.

However, JRE 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 JRE 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 JRE receives a request for notification of utilization purpose, and requests for the disclosure, correction, etc. (correction, adding or deletion) or suspension of use, etc. (suspension of use or erasure) (hereinafter collectively referred to as the "Request, etc. for Disclosure, etc.") pursuant to the Personal Information Protection Act, of retained personal data of JRE, JRE 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, JRE may not be able to accept demands for disclosure, etc. and in such case, JRE informs the person concerned or a representative thereof of the reasons therefore, without delay. JRE may ask any person who requests disclosure of the retained personal data or notification of utilization purpose to bear the prescribed charge.

6. Inquiries on Personal Information

Please be informed that JRE accepts the Request, etc. for Disclosure, etc. of retained personal data and other inquiries at the Contact Point below. JRE also accepts consultations, complaints and other inquiries on the handling of personal information at the Contact Point below.

(Contact Point)

(ⅰ) Personal information relating to entries in the investors' registry:
Please be informed that the administrator of the investors' registry, etc. of JRE accepts inquiries, etc., on personal information relating to entries in the investors' registry of JRE.
Administrator of the Investors' Registry, etc. Corporate Agency Division, Mitsubishi UFJ Trust and Banking Corporation
Tel 0120-232-711 (domestic only)
Business hours 9:00 am to 5:00 pm (closed on weekends, national holidays and the year-end and New Year's holidays)
(ⅱ) Personal information other than Subsection (ⅰ) above:
Please be informed that the asset management company of JRE accepts inquiries, etc., on personal information other than Subsection (ⅰ) above, which is handled by JRE.
Asset Management Company Planning Department, Japan Real Estate Asset Management Co., Ltd.
Tel +81-3-3211-7951
Business hours 9:30 am to 5:30 pm (closed on weekends, national holidays and the year-end and New Year's holidays)

Application for Inquiry on the Personal InformationPDF (16KB)
* When contacting, please use the "Application for Inquiry on the Personal Information" after entering the necessary matters therein.

7. Continuous Improvements to the Personal Information Protection System

JRE seeks to improve the personal information protection system, including this Policy, by reviewing the system on an ongoing basis. JRE may revise this Policy where necessary, in response to revisions, etc. to laws and regulations.

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