Privacy Policy

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Hulic Reit Management Co., Ltd. (hereafter referred to as the “Company”) works to ensure the appropriate management, use, and protection of personal information by implementing the personal information protection policy and related approaches set out below.
In addition, the Company has also separately established the “Basic Policy on Appropriate Handling of Individual Numbers and Specific Personal Information,” which governs the Company’s policies on the protection, the purpose of use, acquisition and third-party provision of individual numbers and specific personal information.

Basic Policy

The Company recognizes the importance of personal information and complies strictly with the Act on the Protection of Personal Information and related regulations, standards, internal corporate regulations, and so on. The Company will not use personal information other than for the stated purposes, will respond appropriately to related complaints, and so on, and will work to ensure the appropriate handling of personal information and its safe and accurate management.

Purposes of Use

(1) The Company will use the personal information other than that of the directors and employees of the Company (including full-time employees, contract employees, junior employees, temporary employees, temporarily transferred employees, and dispatched employees), persons who attempt to become a director or an employee of the Company, persons who attempted to become an employee, or retired employees (hereinafter, referred to as “Personal Information of Employees, etc.”) that it obtains only within the scope of the Purposes of Use set out below.

(i) To allow the exercise of unitholders’ rights and perform Hulic Reit, Inc.’s (hereafter referred to as “Hulic Reit”) duties pursuant to the Act on Investment Trusts and Investment Corporations and other related laws and regulations.
(ii) To manage unitholder information
(iii) To conduct operations in connection with the issuance of investment units for subscription and the issuance of investment corporation bonds for subscription by Hulic Reit.
(iv) To conduct operations (e.g., provision of responses, confirmation of content) arising from inquiries, requests for information materials, or similar applications from potential customers who are considering the purchase of securities (investment securities and investment corporation bonds) issued by Hulic Reit.
(v) To conduct surveys, analyses, and investigations concerning the asset management operations commissioned to the Company.
(vi) To conduct operations involved in the acquisition, transfer, leasing, and sale of assets and in the management of real estate by Hulic Reit.
(vii) To conduct operations related to the investor relations activities, sales activities and general administration, and other activities of the Company.
(viii) To provide to a third party within the scope necessary to carry out operations associated with or connected to items (i) to (vii) above or to perform such operations.

(2) The Company will use Personal Information of Employees, etc. within the scope of the following Purposes of Use.

(i) Determining and paying remuneration, assessing human resources, deciding positions, training employees, procedures for social insurance and employment insurance, providing welfare benefits, health management and other matters relating to human resource and employment management (including cases when Personal Information of Employees, etc. is used for hiring procedures, and correspondence and procedures following retirement)
(ii) Contacting employees for work purposes and conducting other procedures required for work
(iii) Disclosing and providing personal information to third parties within the necessary scope to achieve the Purposes of Use prescribed above

Acquisition, Use, Provision, and Entrustment of Personal Information

(1) Acquisition and use of personal information
The Company will acquire personal information only in approved ways and handle the personal information to remain within the scope of the stated Purposes of Use.

(2) Provision of personal data including personal information
Where the Company provides or discloses personal data including personal information to third parties, the consent of the person concerned will as a general rule be obtained in advance.
However, we may use personal data including personal information or provide it to third parties without the consent of the person concerned in the following cases: (i) where it is prescribed by laws; (ii) where it is necessary for the protection of human life, health, or property and it is difficult to obtain the consent of the person concerned; (iii) where it is specifically necessary for the improvement of public health or the healthy development of children, and it is difficult to obtain the consent of the person concerned; (iv) where it is necessary in order to cooperate in the execution of legally prescribed duties by central or local government organizations or parties working on their behalf and obtaining the consent of the person concerned might interfere with the execution of such duties; and (v) in other cases where provision to third parties is permitted by the Act on the Protection of Personal Information. Furthermore, in case of(3) below, the Company may provide personal data including personal information without the consent of the person concerned. In addition, personal data including personal information may be provided to outside parties other than the Company where such action does not constitute provision to third parties under the terms of the Act on the Protection of Personal Information, for instance where the Company has outsourced all or part of its handling operations of personal data including personal information within the scope of the stated Purposes of Use.
In cases where the Company outsources handling operations of personal data including personal information, it will put in place appropriate measures in accordance with laws and regulations to ensure the protection of personal data and will select an outsourcing partner that has adequate measures for personal information protection and perform necessary and appropriate supervision, thus, the Company will seek to ensure a guaranteed level of personal information protection.

(3) Sharing of Information Among the Group
With regards to personal data including personal information, containing name, address, telephone number, e-mail address, and terms and conditions of leases such as rent, the Company may, within the scope of applicable laws and regulations, etc., jointly use this information with the parent company, Hulic Co., Ltd., and other group companies of the Company within the scope necessary for the purpose of management controls among the group and the Purposes of Use prescribed in (2) above. The party responsible for the management of this personal data including personal information that is shared among the group is the Company. If you have any inquiry regarding the sharing of such personal data including personal information, please direct it to each contact prescribed in “Inquiries Concerning the Handling, Etc., of Personal Information.”

Appropriate Management of Personal Information

(1) The Company will handle the personal information it acquires appropriately and responsibly and will take the greatest care and put in place the necessary and appropriate safety management measures to prevent unauthorized access to the personal information, its loss, destruction, falsification, leaking, and so on.
(2) In the event of an accident, the Company will take measures to minimize damages and will put in place corrective measures to prevent recurrence.
(3) The Company will seek to conduct necessary and appropriate supervision to comply with relevant laws and regulations and protect personal information.

Acquisition, Etc., of Sensitive Information

Unless prescribed in the Guidelines on Personal Information Protection in the Financial Industry, in relation to personal information in the finance industry, the Company will refrain from the acquisition, use, or provision to third parties of sensitive information (i.e., information concerning personal information requiring consideration as prescribed in the Act on the Protection of Personal Information, membership of labor unions, family origin, domicile of origin, healthcare, and sexual orientation (except information that falls within the category of personal information requiring consideration)) except information publicly disclosed by the person concerned, national government agency, local government, or person specified by the Act on the Protection of Personal Information or Ordinance for Enforcement of the Act on the Protection of Personal Information or information that is clear from appearance through observation or filming of the person concerned.

Continuous Improvement

The Company subjects the contents of this policy to continuous review and amends it appropriately as necessary, and thus work to improve its personal information management systems and related functions.

Inquiries Concerning the Handling, Etc., of Personal Information

If the Company receives a request for disclosure, amendment, discontinuation of use, or notification of the purposes of use of retained personal data, a complaint or similar communication regarding the handling of personal information, the Company will promptly respond to the reasonable extent. If you wish to request disclosure or amendment, discontinuation of its use, or notification of the purposes of its use of the content of retained personal data, or if you have a complaint or similar communication or other questions or comments regarding the handling of retained personal data, please direct them to each contact shown below.

(1) Contact for inquiries

If you have a question regarding personal information, if you wish to request the disclosure or amendment of personal data or the discontinuation of its provision to third parties, or if you have a complaint or similar communication or other inquiries, please direct them to the contact shown below.

Hulic Reit Management Co., Ltd., Compliance Department

Address 2-26-9 Hatchobori, Chuo-ku, Tokyo 104-0032, Japan
Tel +81-3-6222-7253
9:00 a.m.-5:00 p.m. (Closed Saturdays, Sundays, holidays, and company holidays)

However, for amendment, addition, or deletion of entries in the unitholders’ registry of an investment corporation whose assets are managed by the Company, the transfer agent acts as the contact. Please use the contact details shown below.

Mizuho Trust & Banking Co., Ltd., Stock Transfer Agency Department

Address 2-8-4 Izumi, Suginami-ku, Tokyo 168-8507, Japan
Tel 0120-288-324 (Toll free in Japan)
9:00 a.m.-5:00 p.m. (Closed Saturdays, Sundays, holidays, and company holidays)

The Company is an entity supervised by The Investment Trusts Association, Japan and the Japan Investment Advisers Association, which are authorized personal information protection organizations and handle inquiries, complaints, and other queries relating to the handling of personal information by the entities they supervise.

The Investment Trusts Association, Japan, Member Inspection Department, Investor Consultation Section

Tel +81-3-5614-8440

(2) Procedure for requesting disclosure of retained personal data
For details of the procedure for requesting retained personal data disclosure, and so on, details of the necessary documentation and the various other procedures involved, and details of the methods used for confirmation of identity, the form of response from the Company, and other procedures, please address your inquiry to the relevant contact as shown above. Please note that in the case of requests for disclosure of retained personal data and requests for notification of the purposes of its use, we may request payment of the designated handling fees.

Amendment

This privacy policy is subject to amendment in response to revision of the laws or other events.

Date of adoption: December 11, 2013
Revision: July 1, 2016
Revision: May 30, 2017