Daiwa House REIT

TSE code : 8984

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Privacy Policy

Personal Information Protection Policy

Daiwa House REIT Investment Corporation ("DHR") recognizes the importance of personal information (including specific personal information defined under the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the "Number Use Act"). The same shall apply hereinafter.) and shall handle all personal information it receives in accordance with the Act on the Protection of Personal Information (the "Personal Information Protection Act"), the Number Use Act and other laws and regulations and the guidelines from competent authorities related to the protection of personal information. DHR shall also appropriately handle, protect and manage personal information in accordance with the following policy (Privacy Policy):

1. Basic Policy regarding the Protection of Personal Information

DHR has a strong awareness of the importance of the protection of personal information. Accordingly, DHR complies with the Personal Information Protection Act and other laws and regulations and the guidelines from competent authorities related to the protection of personal information, and endeavors to appropriately handle and protect personal information.

In handling personal information, DHR complies with the following matters:

  1. DHR shall not obtain personal information through deception or other wrongful means;
  2. DHR shall not, without your prior consent, obtain any of your sensitive personal information, unless permitted by law;
  3. DHR shall not, without your consent, handle any personal information it has obtained beyond the scope of the purposes of use specified in advance, unless permitted by law;
  4. DHR shall not use any personal information it has obtained in a method that is likely to encourage or induce illegal or wrongful conduct;
  5. DHR shall not, without your consent, provide to any third party any personal information it has obtained, unless permitted by law;
  6. DHR shall make every effort to keep personal information it has obtained accurate and current to the extent necessary to achieve the purposes of use; and also shall make every effort to delete such personal information without delay, if it is no longer needed;
  7. DHR shall take necessary and appropriate measures to prevent divulgence, loss, or damage of personal information it has obtained and to manage the safety of personal information.

2. Obtaining Personal Information

DHR shall obtain personal information in a legal and appropriate manner to the extent necessary to achieve the purposes of use described in Item 3 below. Further, prior to obtaining personal information, DHR shall state the purposes of use of that personal information on its website or by other means and if DHR receives personal information directly from you in writing or through a webpage or other means, DHR shall specify the purposes of use of that personal information in advance. If, however, the purposes of use of personal information are obvious from the circumstances at the time that personal information is obtained or are otherwise pursuant to laws and regulations, DHR may omit to specify the purposes of use of that personal information. Further, DHR will not use personal information in a method that is likely to encourage or induce illegal or wrongful conduct.

3. Purposes of Use of Personal Information

DHR shall handle personal information only to the extent necessary for the following purposes of use. DHR shall promptly state the details of any change to the purpose of use:

  1. To exercise rights and perform obligations under the Act on Investment Trusts and Investment Corporations (the "Investment Trust Act") and other laws and regulations and other rules applicable to DHR;
  2. For DHR’s acquisition, sale, leasing and management of properties (including real estate pertaining to trust beneficiary interests; the same hereafter) and the examination, consideration, etc. concerning such (including identification, credit check, rights relations research, etc.);
  3. To collect rent, repay leasehold deposits and engage in other leasing services for the properties that are or were held by DHR;
  4. To provide information on business operations to DHR's unitholders (the "Unitholders");
  5. To handle businesses concerning the exercise of the rights of the Unitholders and performance of the obligations of DHR prescribed in the laws and regulations and other rules applicable to DHR, such as sending asset management reports, convocation notices of general meetings of unitholders, and dividend payment notices to the Unitholders;
  6. To prepare unitholders registry and other data pursuant to the Investment Trust Act and other laws, regulations and rules applicable to DHR and to manage Unitholders by using the prepared unitholders registry and other data of DHR;
  7. To respond to inquiries or requests for documents, etc. from potential purchasers of the securities issued by DHR;
  8. To issue investment corporation bonds and offer investment units of DHR;
  9. To borrow funds on behalf of DHR;
  10. To respond to inquiries from the Unitholders;
  11. To carry out account settlements and other businesses pertaining to accounting and tax matters of DHR; and
  12. To carry out any services incidental or related to any of the above items.

Regardless of the above, specific personal information shall be used only when it is necessary to complete procedures for affairs related to the individual number defined under the Number Use Act and other procedures or to achieve purposes permitted by laws and regulations.

4. Provision and Disclosure of Personal Information to Third Parties

DHR shall not provide or disclose to any third party any personal information it holds unless:

  1. You consent to that provision or disclosure in writing;
  2. It is required to provide or disclose personal information by laws and regulations;
  3. It is necessary to provide or disclose personal information for the purpose of protecting life, body or property and it is difficult to obtain your consent;
  4. It is particularly necessary to provide or disclose personal information for the purpose of improvement of public health or promotion of sound development of children and it is difficult to obtain your consent;
  5. It is necessary to cooperate with a national governmental organ or a local government or its delegate which performs the affairs stipulated by laws and regulations, and it is likely to impede the performance of affairs to obtain your consent;
  6. DHR provides personal information to the service providers (including Daiwa House Asset Management Co., Ltd.) under the supervision of DHR to the extent reasonably necessary to achieve the purposes of use;
  7. Otherwise permitted to provide or disclose personal information under the Personal Information Protection Act.

Regardless of the above, specific personal information collected, used, stored in accordance with the Number Use Act shall not be provided to third parties, with or without the consent of the concerned individuals, except when required by laws and regulations.

5. Proper Management of Personal Information

DHR shall endeavor to keep personal information it has obtained accurate and current to the extent possible, and shall endeavor to properly manage personal information by taking necessary and appropriate measures to prevent divulgence, loss, damage, destruction, misuse, modification, etc. of personal information and to manage safety of personal information. Further, as a registered investment corporation, DHR delegates asset management services and general administration services under the Investment Trust Act, but DHR shall conduct necessary and appropriate supervision of its service providers by striving to make strict safety management measures a requirement of its service providers and taking other measures to prevent divulgence, loss, damage, destruction, misuse, modification, etc. of personal information that you provide. DHR delegates services in relation to the asset management to Daiwa House Asset Management (the "Asset Manager") and requires the Asset Manager to take appropriate safety management measures. Specifically, the Asset Manager takes the following measures.

  1. Systematic safety management measures
    1. The Asset Manager has established necessary organizational structures, such as clarifying the roles and responsibilities of personal information handlers regarding the handling of personal data at each management stage and limiting the persons who can handle personal data;
    2. The Asset Manager has established structures to ensure that operations are conducted in accordance with rules regarding handling of personal information and methods to confirm the status of handling of personal data by centrally managing the acquisition, storage, transfer, transmission, or disposition of personal data by recording them in a personal data management ledger, and regularly confirming such records;
    3. The Asset Manager has established structures to handle incidents such as divulgence of personal data, such as by clearly setting rules on handling of such incidents, procedures for examining their effects and causes, prevention measures, procedures for examining measures following an incident, reporting to competent authorities, providing notification to the individual concerned in the event of incidents such as divulgence of personal data; and
    4. The Asset Manager’s compliance officer conducts internal audits regarding protection and handling of personal information and has established structures to ascertain the status of handling of personal data and review safety management measures.
  2. Human safety management measures
    1. Regarding the protection of personal information, the Asset Manager regularly and continuously clarifies the roles and responsibilities of officers and employees and thoroughly disseminates, and provides education and training on safety management obligations for officers and employees.
    2. At the time of employment and retirement, officers and employees are required to submit a written pledge or execute an agreement to the effect that they will not divulge personal information obtained in the course of business to third parties or use such personal information for any purpose other than the intended usage purpose.
  3. Physical safety management measures
    1. The Asset Manager has taken measures to manage areas where personal data is handled and prevent theft by storing and saving personal data in a storage place that fulfills requirements such as using locks if the obtained or entered personal data is paper media or CD-ROM, and in the case of electronic files, by storing and saving in the designated management folder after applying a password;
    2. Regarding mailing, transfer by removal from the place of storage, etc., or transmission by e-mail, and the like of personal data, the Asset Manager has taken measures to prevent divulgence, etc., such as limiting the methods that can be used for mailing, etc. to forms in which a record of collection and delivery is kept and making it compulsory to apply a password regarding transmission, etc. by e-mail; and
    3. When disposing or deleting personal data which is no longer needed or whose storage period has expired, necessary measures are taken to prevent divulgence, etc., such as by using shredders, or data deletion measures, etc.
  4. Technical safety management measures
    1. Regarding the roles and responsibilities, etc. of personal information handlers, the person responsible for management of personal information protection has taken measures to control access by setting appropriate access authority;
    2. The Asset Manager has taken measures to make employees using the information system identifiable by user IDs and to allow access to information systems only after going through necessary authentication;
    3. The Asset Manager has taken measures to prevent unauthorized access from outside, etc. by installing firewalls at the connection points between internal systems and external networks as well as installing security software to equipment that manages personal data and keeping it up to date by using automatic update functions; and
    4. The Asset Manager has taken measures to prevent divulgence, etc. in accordance with the usage of information systems, such as regularly reviewing information systems from the viewpoint of security as well as making it compulsory to apply passwords to personal data to be transferred.

6. Disclosure, etc. of Personal Information

If you make any request concerning personal information, DHR first confirms your identity in accordance with prescribed procedures before responding to any request for notification of the purpose of use, disclosure (including disclosure by methods such as provision of electromagnetic records), correction, addition, deletion, suspension of use, elimination or suspension of provisioning any information to third parties pursuant to laws and regulations (collectively the “Disclosure, etc.”). However, if the disclosure, etc. violates other laws or regulations, DHR may not be able to respond to demands for the disclosure, etc. In such case, DHR will endeavor to explain the reason to you. The same will apply to disclosure of records of provision to and from third parties regarding acceptance or provision of personal data. If, however, you wish to make a correction, addition or deletion of any registered matter in the unitholders registry, please contact the unitholder registration operator provided at the end of this Privacy Policy.

7. Contact Details

  1. If you have any question regarding the details of this Privacy Policy or any request for the disclosure, etc., please contact the following. You will be instructed on all necessary procedures.
    Inquiries are accepted from 9 am to 6 pm on weekdays.
    Asset Manager Administration and Accounting Department
    Daiwa House Asset Management Co., Ltd.
    Address 7th Floor, Nissei Nagatacho Building, 2-4-8, Nagatacho,
    Chiyoda-ku, Tokyo 100-0014
    Telephone +81-3-3595-1151
  2. For inquiries regarding matters registered in the unitholders registry and administrative matters, please contact the transfer agent provided below.
    Transfer Agent Stock Transfer Agency Business Planning Department
    Sumitomo Mitsui Trust Bank, Limited
    Address 2-8-4, Izumi, Suginami-ku, Tokyo 168-0063
    Telephone 0120-782-031 (toll-free within Japan only)
    (9 a.m. to 5 p.m. on weekdays)

8. Ongoing Improvement of Framework for the Protection of Personal Information

DHR will strive to revise this Privacy Policy in the event of amendment or elimination of laws, regulations, etc. or otherwise as necessary to enhance and improve its initiatives for the protection of personal information.

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