Policy Regarding the Protection of Personal Information (Privacy Policy)

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Mori Building Real Estate Investment Advisory Co., Ltd.
6F Roppongi Annex, 7-6, Roppongi 6-Chome, Minato-ku, Tokyo
Sadao Muraoka, President & CEO

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 clients associated with operations consigned by other business operators), including names, addresses, telephone and fax numbers and e-mail addresses ("Personal Information"). In addition, we may handle the individual number and specific personal information (collectively, “Specific Personal Information, etc.”) of our clients within the scope permitted by laws and regulations. We recognize that the proper safeguarding of this Personal Information and Specific Personal Information, etc. of our clients is an important obligation, and we have therefore established the following policies for the handling of all Personal Information and Specific Personal Information, etc.

  1. In addition to complying with all laws, regulations, ordinances and guidelines related to Personal Information and Specific Personal Information, etc., we adopt and implement practices for the appropriate handling of Personal Information and Specific Personal Information, etc. 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 Specific Personal Information, etc. and make these regulations known to all of our employees. In addition, we require our trading partners, etc., to handle all Personal Information and Specific Personal Information, etc. in an appropriate manner.
  3. Upon acquiring any Personal Information and Specific Personal Information, etc., we will specify the purpose of the use of that information, make a notification or public announcement of that purpose, and only handle the Personal Information and Specific Personal Information, etc. within the scope of that specified purpose. As for Specific Personal Information, etc., we will handle them only within the scope permitted by laws and regulations. Furthermore, we will acquire all Personal Information and Specific Personal Information, etc. only through appropriate means and no Personal Information and Specific Personal Information, etc. 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, engineering report (ER), etc. We will also make the same efforts when we delegate the handling of the Specific Personal Information, etc. of our clients to a third party.
  5. We will establish the necessary measures and provide appropriate supervision to prevent any disclosure or loss of, or tampering with, any Personal Information and Specific Personal Information, etc.
  6. If we receive a request from any client in relation to his/her personal data 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.

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.

Regardless of the above, pursuant to the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, we will use the Specific Personal Information, etc. only for the purpose specified in the Act and for no other purpose.

Ⅲ.Safety Management Measures

Upon handling the Personal Information and Specific Personal Information, etc. received from our clients, the Company will appropriately implement following measures in order to safely manage such information.

  1. Organizational Safety Management Measures
    We will appoint a Chief Privacy Officer that oversees the development of a system to protect and safely manage the Personal Information and Specific Personal Information, etc. In addition, we will also appoint a Privacy Officer at each of the departments that handles the Personal Information and Specific Personal Information, etc. and clarify the scope of information handled by the employees and their authority. Under the system, we will strive for secure management of the Personal Information and Specific Personal Information, etc. of our clients by implementing the necessary and appropriate level of safety measures to guard against the risk of any information being disclosed outside of the Company and of any improper external access to the information, based on our in-house rules including Regulations for the Protection of Personal Information, Rules for Handling Individual Number and Specific Personal Information, etc. and Rules for the Safety and Control of Personal Data.
  2. Human Safety Management Measures
    Upon having our employees handle the Personal Information and Specific Personal Information, etc., we will require a pledge of confidentiality and have them thoroughly comply with the aforementioned in-house rules under the supervision of the Privacy Officer of their department. Furthermore, we will have them recognize the importance of the Personal Information and Specific Personal Information, etc. and promote their awareness for proper handling of such information by regularly providing them with appropriate educational training.
  3. Physical Safety Management Measures and Technical Safety Management Measures
    We will strive to physically and technically prevent improper external access to the Personal Information and Specific Personal Information, etc., and leakage, loss or damage of such information by managing access to and restricting taking out the Personal Information and Specific Personal Information, etc., introducing anti-virus software, implementing measures to prevent theft or loss of documents and such.

Ⅳ. Provision of Personal Information/Specific Personal Information, etc. to Third Parties

Except where required by law or outsourcing part of operations, we will not disclose any individual's Personal Information to a third party without the consent of that individual. As for any individual's Specific Personal Information, etc., we will not disclose such information to a third party even with the consent of that individual, except where required by law.

Ⅴ. Provision of Personal Information to Third Parties in Foreign Countries

Except where required by law, we will not disclose any individual's Personal Information to a third party in a foreign country without the consent of that individual.
When obtaining consent from an individual, we will, in principle, provide the name of the country, information on the system for the protection of Personal Information in the country, and information on the measures taken by the third party to protect Personal Information. However, if these matters cannot be identified upon obtaining the consent, we will inform the individual to the effect and the specific reason, as well as any information that should serve as reference if available. In such a case, if we were able to identify these matters later on, the individual may request the provision of the information from us.
When we are providing Personal Information to those who have a system that meets the requirements set forth by the rules of the Personal Information Protection Commission, we are to take necessary measures to ensure continuous implementation of measures equivalent to the measures to be taken by personal information handling business operators in Japan pertaining to handling of Personal Information, pursuant to the rules. Our clients may request the provision of information on said necessary measures from us.

Ⅵ. Disclosure

In the event that any individual whose personal data 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 data, except where otherwise required by law.

Ⅶ. Amendments, Additions and Deletions

In the event that any individual whose personal data 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 data is in accordance with the facts.

Ⅷ. Suspension and Cessation of Use

In the event that any individual whose personal data we hold wishes us to suspend, or cease our use or limit the purpose of the use 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.
When any individual requests us to stop sending direct mails or soliciting over the phone, we will, without delay, stop using the personal data for such purpose.

Ⅸ.Contact for Disclosure and Other Matters

1. Procedure

All requests in relation to an individual's personal data as set forth in Clauses VI, VII or VIII above, and any inquiries or complaints regarding the Company's handling of Personal Information and Specific Personal Information, etc. 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 6:00pm on weekdays (excluding company holidays).

2. Fee

Requests for notification of the purpose of the use of personal data or for the disclosure of personal data 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.

X. 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)