Privacy Policy

The Investment Corporation recognizes the importance of personal information. To ensure careful handling, the Investment Corporation follows the policy below and acts responsibly to protect personal information.

1. Policy on handling personal information

The Investment Corporation considers the appropriate protection and use of personal information to be part of its social responsibility. The Investment Corporation will operate in compliance with the Act on the Protection of Personal Information (Act No. 57 of 2003; including amendments thereto; “Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of 2013; including amendments thereto; “Number Use Act”) and other applicable laws, regulations, and guidelines.

2.Proper procedures for obtaining personal information

When the Investment Corporation obtains personal information, it will obtain the information by fair and legitimate means to the extent necessary to accomplish purposes of use that are reported to the person or publicly announced, unless otherwise provided for in laws and regulations. The Investment Corporation will not, unless otherwise provided for in laws and regulations, obtain special care-required personal information as defined in the Personal Information Protection Act without obtaining the consent of the person in advance.

3.Purposes of use

The Investment Corporation will use personal information only within the scope of the purposes described in the “Purposes of Use of Personal Information.” The Investment Corporation will not use personal information beyond this scope unless the consent of the person has been obtained in advance or otherwise provided for in laws and regulations. Furthermore, pursuant to the Number Use Act, the Investment Corporation will not use the Individual Number and Specific Personal Information that have been collected, used and kept for a specific purpose beyond this scope, with or without the consent of the person, unless otherwise provided for in laws and regulations.

4.Restriction on providing personal information to third parties

The Investment Corporation will not provide personal data to any third party unless the consent of the person has been obtained in advance or otherwise provided for in laws and regulations. Furthermore, pursuant to the Number Use Act, the Investment Corporation will not provide the Individual Number and Specific Personal Information that have been collected, used and kept for a specific purpose to any third party, with or without the consent of the person, unless otherwise provided for in laws and regulations.

5.Obtainment of sensitive information, etc.

The Investment Corporation will not obtain, use or provide to any third party special care-required personal information as well as information concerning participation in union activities, family origin, registered domicile, health care and sex life (excluding such that falls under special care-required personal information) in the financial field unless stipulated in the Guidelines for Personal Information Protection in the Financial Field (excluding information published by the person, state institution, local public body or persons stated in the Personal Information Protection Act or the Enforcement Rules for the Act on the Protection of Personal Information; and information that clearly shows the external appearance of the person obtained by looking at or taking a photo of the person).

6.Notification of purposes of use, disclosure, correction, addition or, deletion of content, suspension of use, removal and suspension of provision to third parties pertaining to retained personal data based on the Personal Information Protection Act

If a person requests, with respect to his/her personal data that is retained by the Investment Corporation as well as by the Asset Management Company, the General Administration and the Asset Custodian, etc. to which the Investment Corporation has entrusted provision of services (“Service Providers”), notification of purposes of use of his/her personal information; disclosure of the retained personal data; correction, addition or deletion of the retained personal data; suspension of use of the retained data or its removal; or suspension of provision of the retained personal data to third parties (“Procedures for Disclosure, Etc.”), the Investment Corporation will respond to the request promptly, within the scope reasonable and necessary, with identity verification upon the Procedures for Disclosure, Etc. The Investment Corporation and Service Providers will receive the prescribed fees for the Procedures for Disclosure, Etc.

7.Complaints concerning personal information

When the Investment Corporation receives complaints concerning handling of personal information, it will do its utmost to respond appropriately and promptly within a reasonable period. The contact desk shown later in the page will accept complaints concerning handling of personal information.

8.Safe management

To keep personal data accurate and up to date, the Investment Corporation and Service Providers will strictly manage information and take precautions and safety measures against any unauthorized access, loss, destruction, falsification, or leaks, as well as try to delete such data without delay when there is no longer a need for use. If the Investment Corporation outsources the collection and management of personal data to a third party, the Investment Corporation will oversee the third party to ensure strict management of the personal data.

9.Constant reexamination of system for protection of personal information

With respect to regulations of the Investment Corporation and Service Providers related to the handling of personal information and the organizational structures to implement such regulations, the Investment Corporation will constantly reexamine and revise them to ensure that operations remain effective and reasonable.

10.Disclaimer

The website of the Investment Corporation includes links to external websites. However, the Investment Corporation cannot assume responsibility for the protection of personal information on external websites.

【Purposes of Use of Personal Information (excluding Individual Number and Specific Personal Information)】

The Investment Corporation will use personal information (excluding Individual Number and Specific Personal Information) it has obtained for the following purposes:

  1. To manage information on the Investment Corporation's unitholders, analyze their attributes, and disclose their data (the Investment Corporation will not disclose any information that permits personal identification, except for the top ten unitholders, which are posted on this website)
  2. To perform tasks related to unitholders exercising their rights and the Investment Corporation’s fulfillment of its obligations to unitholders.
  3. To perform tasks related to research and analysis necessary for the Investment Corporation to consider the acquisition and sale of assets, trust beneficiary interests related to real estate as trust property (hereinafter “real estate trust beneficiary interests,” and real estate as trust property is “real estate in trust”), and other assets.
  4. To perform tasks related to research (including, but not limited to, identity verification and credit research) necessary for considering the leasing of real estate, real estate in trust, and other assets owned by the Investment Corporation, and the implementation of relevant lease agreements (including communications, inquiries, and registration)
  5. To perform tasks related to the management of the real estate and real estate in trust owned by the Investment Corporation
  6. To perform tasks related to identifying and responding to those who make inquiries or visits to the Investment Corporation or Service Providers and those who request materials from the Investment Corporation or Service Providers, as well as preparing records detailing the response.
  7. To perform other tasks related to the financial instruments business concerning real estate, securities and other financial assets.
  8. To perform operations related to the steps taken to facilitate relations with unitholders and potential unitholders (including providing information)
  9. To verify the identities of the counterparties of transactions according to the Act on Prevention of Transfer of Criminal Proceeds
  10. To use personal information for market analysis, customer satisfaction surveys, or research and analysis for product development in association with the items above
  11. To fulfill obligations, exercise rights, and perform tasks incidental to these tasks
  12. To provide personal information to third parties to the extent necessary for the appropriate execution of operations

【Inquiries about the disclosure, correction and suspension of use of personal information】

Inquiries about personal information

Please inquire with Comforia Management Division at TLC REIT Management Inc. (Tel: +81-3- 6455-3388), which is the Asset Management Company of the Investment Corporation, indicating that the inquiry concerns personal information.

Daily 9:30 a.m. to 6:00 p.m., except for Saturdays, Sundays, public holidays, and year-end and New Year holidays

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