SANKEI REAL ESTATE Inc.

Privacy Policy

SANKEI REAL ESTATE Inc. (hereinafter, “SANKEI REAL ESTATE”) strives for appropriate management, use and protection of personal information by setting the following policy on and initiatives for personal information protection. Please note that the policy on protection, purposes of use, acquisition, provision to third parties and other matters concerning individual numbers and specific personal information shall be based on the “Basic Policy on Specific Personal Information, Etc.” separately set by SANKEI REAL ESTATE.

1. Basic Policy on Handling of Personal Information

Recognizing the importance of personal information, SANKEI REAL ESTATE shall strive for proper handling and secure and reliable control and management of personal information in compliance with the Act on the Protection of Personal Information (hereinafter, the “Personal Information Protection Act”) and other relevant laws and regulations, the “Guidelines on the Act on the Protection of Personal Information,” the “Guidelines for Personal Information Protection in the Financial Field” and other guidelines, etc.

2. Purposes of Use of Personal Information

When SANKEI REAL ESTATE is to use personal information, use shall be limited to within the scope necessary for achievement of the following purposes of use, and use shall not be beyond the scope of such purposes unless the person’s consent has been obtained in advance or unless otherwise provided for in laws and regulations.

  1. For exercise of rights and performance of obligations of SANKEI REAL ESTATE pursuant to the Act on Investment Trusts and Investment Corporations (hereinafter, the “Investment Trusts Act”) and other laws, regulations, rules, etc.
  2. For preparation of data for the unitholder register, etc. and other management of information on unitholders pursuant to the Investment Trusts Act
  3. For provision of information to unitholders, establishment of measures for unitholders and other response to unitholders
  4. For carrying out operations pertaining to loan of funds, issuance of investment units for subscription, issuance of investment corporation bonds for subscription, other fund procurement and capital policy by SANKEI REAL ESTATE
  5. For survey analysis and review relating to management of the assets of SANKEI REAL ESTATE
  6. For carrying out operations pertaining to acquisition, transfer and other disposition, leasing, maintenance and management of assets by SANKEI REAL ESTATE
  7. For verification of transaction counterparties and other matters upon transaction pursuant to the Act on Prevention of Transfer of Criminal Proceeds
  8. For carrying out operations for preparation, submission, etc. of various reports, etc. of SANKEI REAL ESTATE pursuant to laws, regulations, rules, etc.
  9. For carrying out operations concerning IR activities, operating activities, general administration, etc. pertaining to SANKEI REAL ESTATE
  10. For carrying out operations for verification of content, response, etc. for inquiries, requests for materials, etc. made to SANKEI REAL ESTATE
  11. For internal control (internal management) operations of SANKEI REAL ESTATE
  12. For carrying out the operations incidental or relating to any of the operations listed in (1) through (11), or for provision to third parties within the scope necessary for the achievement thereof

3. Acquisition of Personal Information, Provision of Personal Data to Third Parties, Outsourcing of Handling of Personal Data, Etc.

  1. Acquisition of personal information
    SANKEI REAL ESTATE shall acquire personal information by proper and legal means within the scope necessary for achievement of the purposes of use listed above under “2. Purposes of Use of Personal Information.”
  2. Provision of personal data to third parties
    SANKEI REAL ESTATE shall not provide personal data including personal information to third parties, except in the following cases:
    • Cases where the person’s consent has been obtained in advance
    • Cases pursuant to laws and regulations
    • Cases where necessary for protection of the life, body or property of humans, and it is difficult to obtain the person’s consent
    • Cases where particularly necessary for improvement of public health or promotion of the sound growth of children, and it is difficult to obtain the person’s consent
    • Cases where there is a need to cooperate with national government organs or local governments, or parties entrusted by such, in performing affairs prescribed by laws and regulations, and there is a possibility that obtaining the person’s consent would interfere with the performance of the affairs
    • Cases where otherwise provided for in the Personal Information Protection Act
  3. Outsourcing of handling of personal data
    SANKEI REAL ESTATE may outsource the handling of personal data, in whole or in part, to third parties within the scope necessary for achievement of the purposes of use. In cases where SANKEI REAL ESTATE is to outsource the handling of personal data, in whole or in part, to third parties, necessary and appropriate supervision shall be exercised over the parties so entrusted so as to ensure that the personal data for which the handling has been entrusted is securely managed.

4. Proper Management of Personal Data

SANKEI REAL ESTATE shall take necessary and appropriate security control measures according to each of the stages—acquiring and inputting, using and processing, keeping and storing, transferring and sending, disposing and erasing, and responding to cases of divulgence, etc. of personal data—to ensure prevention of divulgence, loss or damage of the handled personal data and other secure management of personal data. In addition, when use of personal data is no longer necessary, SANKEI REAL ESTATE shall strive to erase the personal information without delay. If you have any inquiries concerning the details of the security control measures taken by SANKEI REAL ESTATE, please contact the “Contact for Requests for Disclosure, Etc. of Retained Personal Data and Other Inquiries Concerning Personal Information” below.

5. Acquisition, Etc. of Sensitive Information

Concerning personal information in the financial field, unless otherwise provided for in the “Guidelines for Personal Information Protection in the Financial Field,” SANKEI REAL ESTATE shall not acquire, use or provide to third parties any sensitive information (special-care-required personal information as defined in the Personal Information Protection Act, and information concerning labor union membership, family origin, place of registered domicile, healthcare and sex life (other than those of which fall under the category of special-care-required personal information), except those disclosed by the person, national government organs, local governments, academic research institutes, etc. or the parties set forth in the Personal Information Protection Act or the Enforcement Rules for the Act on the Protection of Personal Information or those seemingly clear from acquiring by visual observation, filming or photographing of the person).

6. Continual Improvement

SANKEI REAL ESTATE shall strive to continually review the content of the Policy and also revise accordingly as needed, and thereby improve the management system, etc. for personal information.

7. Contact for Requests for Disclosure, Etc. of Retained Personal Data and Other Inquiries Concerning Personal Information

The trade name, address and name of the representative of SANKEI REAL ESTATE, the personal information handling business operator, are as follows:

Trade name SANKEI REAL ESTATE Inc.
Address S-GATE Otemachi-Kita 4F, 2-3-4 Uchikanda, Chiyoda-ku, Tokyo　101-0047
Representative Yuichi Ota, Executive Director

In cases where SANKEI REAL ESTATE is requested to be informed of the purposes of use or receives requests for disclosure (including disclosure of records provided to third parties), correction, addition, deletion, cessation of use, erasure or cessation of provision to third parties pursuant to the Personal Information Protection Act (hereinafter, collectively referred to as “requests, etc. for disclosure, etc.”) of retained personal data, SANKEI REAL ESTATE shall respond appropriately without delay pursuant to laws, regulations, etc. once verification can be made that the person or legitimate agent is making the requests, etc. However, requests, etc. for disclosure, etc. may not be met in certain cases, such as cases where there is a possibility of harming the life, body, property or other rights and interests of the person or third parties. In such cases, the person or the person’s agent shall be informed of the reasons for such without delay.

The contact below is available to take requests, etc. for disclosure, etc. of details of the security control measures of personal data, retained personal data and other inquiries concerning personal information.

The contact below is available to take consultations, complaints, etc. concerning the handling of personal information of SANKEI REAL ESTATE, too, which shall be dealt promptly and appropriately by SANKEI REAL ESTATE.

Name Corporate Planning and Administration Department,
Sankei Building Asset Management Co., Ltd.
Address S-GATE Otemachi-Kita 4F, 2-3-4 Uchikanda, Chiyoda-ku, Tokyo　101-0047
TEL 03-5542-1316
Hours of operation 9:30 to 17:45 (excluding Saturdays, Sundays, national holidays, year-end through New Year holidays and the company’s designated holidays)

However, the unitholder register administrator is the contact when concerning correction, addition or deletion of unitholder register entries. Please contact below in such cases.

Name Stock Transfer Agency Department, Mizuho Trust & Banking Co., Ltd.
Address 2-8-4 Izumi, Suginami-ku, Tokyo 168-8507
TEL 0120-288-324
Hours of operation 9:30 to 17:00 (excluding Saturdays, Sundays, national holidays, year-end through New Year holidays and the company’s designated holidays)

End

Established on March 5, 2019
Revised on April 1, 2022
Revised on January 23, 2023
Revised on February 1, 2024