Policy Regarding the Protection of Personal Information (Privacy Policy)

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Ⅰ. Our Policy for the Protection of Personal Information

In order to ensure the smooth operation of the business, Mori Building Real Estate Investment Advisory (the "Company") acquires and uses certain personal information about our clients, including names, addresses, telephone and fax numbers and e-mail addresses ("Personal Information"). We recognize that the proper safeguarding of this Personal Information is an important obligation, and we have therefore established the following policies for the handling of all Personal Information.

  1. In addition to complying with all laws, regulations, ordinances and guidelines related to the protection of Personal Information, we adopt and implement practices for the appropriate handling of Personal Information that comply with generally accepted public standards, and will strive to improve the implementation of those practices.
  2. We have established clear in-house regulations regarding the handling of Personal Information and make these regulations known to all of our employees. In addition, we require our trading partners, etc., to handle all Personal Information in an appropriate manner.
  3. Upon acquiring any Personal Information, we will specify the purpose which that information will be used for, make a notification or public announcement of that purpose, and only handle the Personal Information within the scope of that specified purpose. Furthermore, we will acquire all Personal Information only through appropriate means and no Personal Information will be acquired through deception or any other wrongful means.
  4. If we engage any third party in handling all or any part of our Personal Information to the extent required to achieve the purpose of the use of that information, before we provide such Personal Information to the third party, we will confirm that the third party has adequate measures for the safeguarding of that information, and will enter into a contract with that third party, as well as put in place any other appropriate measure. We will supervise such third party in an appropriate manner. In addition, in order to make efforts to ensure the transparency of the handling of personal data, we will, to the maximum extent possible, report to the client that the handling of such personal data was delegated to a third party and explain the content of such outsourced clerical work, such as the acquisition of a real estate appraisal, environmental report (ER), etc.
  5. We will establish the necessary measures and provide appropriate supervision to prevent any disclosure or loss of, or tampering with, any Personal Information.
  6. If we receive a request from any client in relation to his/her Personal Information that we hold to disclose, amend, delete, cease the use or limit the purpose of the use of that information, we will respond accordingly in good faith in accordance with the laws and regulations.

Ⅱ. Purpose of Use of Personal Information

The Company obtains Personal Information as may be necessary in the course of undertaking its business, and that Personal Information will be used for any of the following purposes:

  1. To provide advisory and other activities for our clients, to enter into asset management contracts and all other types of contracts with our clients, and to manage those contracts in relation to asset management, asset maintenance, real estate investment and the like.
  2. In the event that the Company is consigned by another business to handle all or any part of the Personal Information of that business, to undertake the consigned operations in an appropriate manner.
  3. To implement any other operation related to any business of the Company.

Ⅲ. Management and Protection of Personal Information

The Company will appoint a Chief Privacy Officer to ensure the proper and strict safeguarding of the Personal Information received from our clients, and will strive to maintain the accuracy of all Personal Information. Furthermore, we will implement the necessary and appropriate level of safety measures to guard against the risk of any Personal Information being disclosed outside of the Company and of any improper external access to the Personal Information, based on our Regulations for the Protection of Personal Information and Rules for the Safety and Control of Personal Data.

Ⅳ. Provision of Personal Information to Third Parties

Except where required by law, we will not disclose any individual's Personal Information to a third party without the consent of that individual.

Ⅴ. Disclosure

In the event that any individual whose Personal Information we hold wishes us to disclose that information, we will, without delay, after first confirming the identity of the individual making such request, disclose the relevant Personal Information, except where otherwise required by law. Furthermore, if we receive a request from any client to disclose the source of the Personal Information or the manner in which it was obtained (i.e the nature of the source, etc.), after first confirming the identity of the individual making such request, we will provide him/her with information to the extent that is possible.

Ⅵ. Amendments, Additions and Deletions

In the event that any individual whose Personal Information we hold wishes us to amend, supplement or delete that information, we will, without delay, after first confirming the identity of the individual making such request, make the relevant change so that the corresponding Personal Information is in accordance with the facts.

Ⅶ. Suspension and Cessation of Use

In the event that any individual whose Personal Information we hold wishes us to suspend, or cease our use or limit the purpose of the use (for example, to stop sending direct mails, etc.) of that information or to delete the information, or cease providing that information to a third party, we will, without delay, after first confirming the identity of the individual making such request and ascertaining that there is a reason for the request, implement the relevant suspension, limitation , deletion or cessation.

Ⅷ. Contact for Disclosure and Other Matters

1. Procedure

All requests in relation to an individual's Personal Information as set forth in Clauses V, VI or VII above, and any inquiries or complaints regarding the Company's handling of Personal Information should be made to the following contact person. Requests, inquiries and complaints shall be made in accordance with the procedures separately stipulated by the Company. Please note that we may not be able to respond to requests for disclosure and the like unless such procedures are followed.

<<Contact>>
Mailing Address Attn: Personal Information Protection Office
Mori Building Real Estate Investment Advisory Co., Ltd.
Roppongi Annex 6F
7-6 Roppongi 6-Chome, Minato-ku, Tokyo 106-0032
Tel +81-3-6406-9411
FAX +81-3-6406-9374
E-mail kojin@mori-advisory.com

Business hours: 10:00am to 5:00pm on weekdays (excluding company holidays).

2. Fee

Requests for notification of the purpose of the use of Personal Information or for the disclosure of Personal Information held will incur a handling fee of five hundred yen per request (inclusive of consumption tax and local consumption tax), which may be paid by bank transfer or other methods.

IX. Authorized Personal Information Protection Organization and Inquiries Concerning the Handling of Personal Information

We are an association member of the Japan Securities Investment Advisers Association as follows. The Association handles complaints and inquiries in relation to the handling of Personal Information by its members.

Japan Investment Advisers Association
Customer Inquiries for complaints/consultation (for Personal Information)
Tel: +81-3-3663-0505
Office Hours: Monday through Friday from 9:00 am to 5:00 pm (excluding national holidays)