1. Basic Policies on Personal Information
With respect to personal information provided to the Company by relevant parties or personal information acquired through asset management operations of TOKYU REIT, Inc. (“TOKYU REIT”), Tokyu Real Estate Investment Management Inc. (“Tokyu REIM” or “the Company”) shall comply with the Act on the Protection of Personal Information (hereafter the “Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (hereafter the “Numbers Act”), other laws and ordinances and related rules and regulations (including administrative guidelines, hereafter “laws and ordinances”) and shall properly handle, protect and manage personal information in line with the following policies.
- Tokyu REIM will never acquire personal information by deception or other wrongful means.
- With the exception of cases permitted under laws and ordinances, Tokyu REIM will not collect personal information requiring special care without prior consent of the relevant party.
- Upon acquisition of personal information from third parties, Tokyu REIM will not engage in unjust infringement of the interests of the individual for which personal information was acquired, nor will it acquire the information knowing that the information is personal information that has been leaked, etc. from third parties that are engaged in wrongful acquisition of personal information or other unjust acts.
- Personal information shall be acquired only to the extent necessary for the conduct of business.
- With the exception of cases permitted under the laws and ordinances, Tokyu REIM will never go beyond the scope of the “purpose of use of personal information” (hereafter, “purpose of use”) as described in the next section, nor will it provide personal information to third parties.
- Tokyu REIM will not use personal information in a manner that may encourage or induce illegal or unjust acts.
- Personal information that Tokyu REIM has acquired shall be maintained so that it is accurate and up to date to the extent necessary to fulfill its purpose of use. At the same time, strict security management measures will be taken to prevent mishaps, including the loss, misuse and alteration of such information.
- Tokyu REIM will delete collected personal information without delay when its use is no longer necessary.
- Tokyu REIM will constantly assess the circumstances surrounding the acquisition and management of personal information and shall review measures for protecting personal information on an as-needed basis.
- When Tokyu REIM receives inquiries or complaints concerning the handling of personal information, it investigates them and tries to respond appropriately and swiftly within a reasonable period of time. Inquiries, complaints and other queries concerning the handling of personal information are handled by the Inquiry Desk described under item 9 or 10 below.
2. Purpose of Use of Personal Information
With the exception of cases permitted under the Personal Information Protection Act and other laws and ordinances, Tokyu REIM will never use personal information for purposes other than those listed below without the consent of the relevant party through asset management operations contracted with TOKYU REIT.
- Exercise of rights of unitholders and fulfilling the obligations of TOKYU REIT under the Act on Investment Trusts and Investment Corporations and other laws and ordinances.
- Information management of unitholders
- Assistance related to the issuance of investment units and the issuance of investment corporation bonds by TOKYU REIT.
- Performance of duties, including the verification of and response to inquiries from unitholders and those who are considering the purchase of investment units and investment corporation bonds issued by TOKYU REIT.
- Analysis, research and consideration to implement asset management related operation contracted with relevant parties.
- Performance of contracted duties related to acquisition, transfer and borrowing and lending of assets and the management of real estate by TOKYU REIT.
- Performance of IR activities and general business duties related to Tokyu REIM.
- Performance of ordinary tasks related with corporate activities.
- Performance of duties incidental or directly related to (1) through (8) above.
3. Acquisition of Personal Information
To the extent required for business, Tokyu REIM acquires personal information through proper means. Moreover, in acquiring personal information, Tokyu REIM pays attention to the following points. Provided, however, that, this shall not apply in the cases permitted under laws and ordinances.
- When personal information has been acquired, except for cases in which the purpose of use has been announced in advance, the relevant party is promptly informed of the purpose of use through an appropriate means or by public announcement.
- When acquiring personal information through direct written correspondence (including correspondence that has been electronically or magnetically recorded and stored) from the relevant party, the relevant party either receives advance clarification of the purpose for which the information will be used or their consent for use is obtained. However, there is no need for clarification or the obtaining of consent when the information is urgently needed to protect a person from death, physical harm or to safeguard their property.
- When the purpose of use has been changed, the relevant party is informed or an announcement is made regarding the new purpose of use.
4. Provision of Personal Information to Third Parties
Except for the cases cited below, Tokyu REIM never provides personal information that it has acquired to third parties without the prior consent of the relevant party.
- In cases dictated by laws and ordinances.
- In cases where the information is needed to protect a person from death, physical harm or to safeguard their property and when it is difficult to obtain the relevant party’s consent.
- In cases where the information is needed in order to improve public health or provide solid protection for children and circumstances make it difficult to obtain the relevant party’s consent.
- In cases where it is necessary to cooperate with a person who has been commissioned by a national institution or a local public authority for the performance of legal duties and when obtaining the consent of the relevant party could potentially interrupt the performance of said duties.
Furthermore, with the exception of cases based on laws and ordinances, Tokyu REIM will never provide individual numbers or specific personal information it collects, uses or keeps for specific purposes based on the Numbers Act to third parties, regardless of the consent of the relevant party.
5. Personal Information Disclosure, Revision and Suspension of Use
When Tokyu REIM is requested by the relevant person regarding retained personal data, upon recognizing this person as the actual person or the proxy of that person, Tokyu REIM will respond by notifying purpose of use or retained personal data that identifies the relevant party, disclosing (including disclosure by providing electromagnetic records, etc.), revising, supplementing, deleting, suspending the use of or removing (hereafter, “disclosure, revision or suspension of use”) that information in keeping with laws and regulations. However, if such action should violate other laws and ordinances, Tokyu REIM will not be able to respond to the request for disclosure, revision or suspension of use. In such a case, Tokyu REIM will explain the reason to the relevant party.
The same applies to the disclosure of records regarding the transfer of personal data TOKYU REIT provided to third parties.
6. Security Management of Personal Information
To the extent necessary to fulfill its purpose of use, Tokyu REIM will make every effort to manage its retained personal data so that said information is accurate and up to date. Tokyu REIM will manage personal information in compliance with laws and ordinances in order to prevent the leakage, loss, damage, falsification or other corruption of that information and will implement appropriate security management measures with regard to the organization, personnel, infrastructure and technology.
- Organizational security management measures
(a) Tokyu REIM has appointed a general manager for company-wide handling of personal data, appointed a manager for each department, clarified which officers and employees handle personal data and the scope of personal data the relevant officers and employees handle and established a system for contacting and reporting to the relevant manager and general manager in the event that any fact or indication of a violation of the Personal Information Protection Act or internal regulations concerning personal information management (hereafter, “personal information protection regulations”) is detected.
(b) It conducts periodic self-inspections on the status of personal data handling as well as audits by the department in charge of internal audits.
- Personnel security management measures
(a) Tokyu REIM enters into personal information non-disclosure agreements with officers and employees that include the roles and responsibilities of officers and employees regarding handling of personal data and disciplinary measures taken in the event of a violation, or takes equivalent measures.
(b) Tokyu REIM has established personal information protection regulations, ensuring that all officers and employees are aware of the security management measures, and implements education and training for all officers and employees.
- Infrastructural security management measures
(a) When personal data is input, it is done in a building or other location only accessible to authorized personnel.
(b) When documents or electronic media containing personal data are taken outside the company, measures are taken to prevent theft, leakage or damage.
- Technological security management measures
(a) Tokyu REIM controls access to limit personnel and the scope of the personal information database, etc. personnel handle.
(b) Tokyu REIM has installed systems to protect the information systems handling personal data from unauthorized external access or unauthorized software.
7. Outsourcing the Handling of Personal Information
To the extent necessary to fulfill the purpose of use, Tokyu REIM may outsource all or a portion of the management of personal information. In such case, the Company will verify the personal information protection system of the outsourced company and take measures to protect personal information with formal agreements while also providing proper supervision of the outsourced company.
8. Inquiries Concerning Personal Information
With respect to questions or complaints regarding personal information as well as inquiries and other requests for the disclosure, revision or suspension of use of retained personal data held by the Company, please contact the Inquiry Desk below for instructions regarding the necessary procedures.
|SHIBUYA MARKCITY, WEST 11F, 1-12-1, Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan
Tokyu Real Estate Investment Management Inc.
With respect to inquiries regarding entries in the list of unitholders and other queries, please contact the Administrator of the Register of Unitholders below.
＜Administrator of the Register of Unitholders＞
|1-1, Nikkocho, Fuchu City, Tokyo, Japan
Mitsubishi UFJ Trust and Banking Corporation, Corporate Agency Division
Toll-free number (Japan only): 0120-232-711
Post-office box 29, Shin-Tokyo Post Office, Tokyo 137-8081, Japan
Mitsubishi UFJ Trust and Banking Corporation, Corporate Agency Division
9. Authorized Personal Information Protection Organization
With respect to complaints regarding protection of personal information, please contact the Authorized Personal Information Protection Organization below.
＜Authorized Personal Information Protection Organization＞
|The Investment Trusts Association, Japan
Counseling office for investors
10. Continuous Improvement of the Personal Information Protection System