Privacy Policy

Established July 30, 2021

　Tokaido REIT, Inc. (the “Investment Corporation”), recognizing the importance of personal information, which hereinafter includes specific personal information as defined in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (the “Numbers Act”), shall comply with the Act on the Protection of Personal Information (the “Personal Information Protection Act”), the Numbers Act, and any other laws, regulations, guidelines issued by the relevant authorities, etc. with regard to the handling of personal information that it obtains.
　Furthermore, based on the following policy (the “Privacy Policy”, it shall handle, protect, and manage personal information in an appropriate manner.

1. Basic Policy on Personal Information Protection

　The Investment Corporation is strongly aware of the importance of protecting personal information, and in compliance with the Personal Information Protection Act and other laws, regulations, guidelines issued by the relevant authorities, etc. relating to the protection of personal information, it shall not use personal information for other purposes, work to resolve complaints, etc. in an appropriate manner, and strive to implement appropriate handling and protection of personal information.

　With respect to the handling of personal information, the Investment Corporation shall abide by the following:

It shall not obtain personal information using deception or other unlawful methods.
Except in cases where permitted to do so by law and regulation, it shall not obtain personal information requiring special care without the prior consent of the individual in question.
Except in cases where permitted to do so by law and regulation, it shall not use obtained personal information for reasons that fall outside the scope of the specified purpose without the prior consent of the individual in question.
Except in cases where permitted to do so by law and regulation, it shall not provide obtained personal data to any third party without the prior consent of the individual in question.
Within the scope required to fulfill the purpose of use, it shall strive to keep obtained personal data accurate and up to date, and if its use is no longer required, it shall delete the personal data in question without undue delay.
It shall implement any measures that are necessary and appropriate in order to prevent obtained personal data from being leaked, lost, or damaged and ensure its safe management.

2. Acquisition of Personal Information

　The Investment Corporation shall obtain personal information by fair and appropriate means, solely as required to fulfill the purposes of use indicated in Section 3 below. Furthermore, before obtaining personal information, the Investment Corporation shall disclose the purposes of use on its website and so forth, and if personal information is provided directly by the individual in question in writing, on a web page, etc., the purpose for which the personal information will be used shall be explicitly stated in advance.
　However, in cases where it is deemed that the purpose of use is clear based on the circumstances of acquisition, or in other cases based on the relevant laws and regulations, explicitly stating the purpose of use may be omitted.

3. Purposes of Using Personal Information

　Except in cases where consent has been obtained in advance from the individual in question or exceptional cases where it is allowed based on the relevant laws, regulations, etc., the Investment Corporation shall only use personal information within the scope required to fulfill the purposes below. If the Investment Corporation modifies the applicable usage purpose, it shall promptly publish the details of the change on its website or the like.

To exercise rights or fulfill obligations based on the Act on Investment Trusts and Investment Corporations (the “Investment Trusts Act”) and other laws, regulations, and rules that apply to the Investment Corporation.
To carry out tasks relating to the acquisition or disposal of assets under management by the Investment Corporation, tasks relating to leasing or management of assets under management, other tasks relating to the management of assets conducted based on the Investment Trusts Act (including financing-related tasks conducted as part of asset management), and various tasks relating to the collection, examination, analysis, consideration, etc. of relevant information (including identify verification, credit checks, rights-related checks, etc.).
To provide information relating to business operations, etc. to the Investment Corporation’s unitholders (“the Unitholders”).
To handle tasks relating to the exercising of Unitholders’ rights as stipulated in the laws, regulations, and rules applying to the Investment Corporation and its asset management company (“the Asset Manager”), the fulfillment of the Investment Corporation and Asset Management Manager’s obligations, and other measures aimed at Unitholders, including sending them asset management reports, notices of convocation for unitholder meetings, and notices of dividend payments.
To manage information about Unitholders using data such as the Investment Corporation’s Unitholder Register prepared based on the Investment Trusts Act and other laws, regulations, and rules applying to the Investment Corporation.
To prepare and submit various types of notifications, reports, etc. relating to the Investment Corporation and Asset Manager based on the Investment Trusts Act, the Financial Instruments and Exchange Act, and other laws, regulations, and rules applying to the Investment Corporation and Asset Manager.
To handle inquiries, requests for documents, etc. relating to the Investment Corporation.
To issue and borrow Investment Corporation investment units, investment corporation bonds, and investment unit acquisition rights and handle other financing and IR activity tasks.
To perform tasks relating to the Investment Corporation’s financial results and other accounting- and tax-related tasks.
To perform tasks commissioned by the Investment Corporation in an appropriate, smooth manner or to perform other incidental or related tasks for the usage purposes indicated in the above items.

　Notwithstanding the foregoing, handling of specific personal information shall be limited to cases where it is necessary for the fulfillment of a process related to an individual number as defined in the Numbers Act or for another process or legally permitted purpose.

4. Provision of Personal Data to Third Parties

　The Investment Corporation shall not provide personal data in its possession to any third party without prior written consent of the individual in question, except in the following cases:

In cases stipulated by law
In cases where it is necessary to protect life, health, or properties of an individual and it is difficult to obtain the consent of the individual in question
In cases where it is specifically needed to improve public health or promote the healthy growth of children and it is difficult to obtain the consent of the individual in question
In cases where it is necessary to collaborate with government institutions, local public authorities, or parties they have commissioned in order for them to execute duties stipulated by law and regulations and there is a risk that obtaining consent from the individual in question will impede the execution of said duties.

Notwithstanding the foregoing, specific personal information that is collected, used, and stored based on the Numbers Act shall not be provided to any third party, regardless of whether the individual in question provides their consent, except in cases stipulated by law and regulation.

5. Appropriate Management of Personal Information

Insofar as is possible, the Investment Corporation shall strive to keep obtained personal information accurate and up to date and manage it appropriately, such as implementing any necessary and appropriate measures to prevent it being leaked, lost, damaged, destroyed, misused, or altered and otherwise ensure safe management. Moreover, there are cases where the Investment Corporation shall, within the scope required to fulfill the usage purpose, outsource the handling of obtained personal information in whole or in part, but in the applicable cases, it shall perform any necessary and appropriate monitoring of the outsourced work provider, including taking efforts to oblige the provider to implement rigorous safety management measures in order to prevent personal information being leaked, lost, damaged, destroyed, misused, altered, etc.

6. Requests for Notifications Relating to the Usage Purpose of Personal Data and Requests for Disclosure, Etc.

If it receives a request from the individual in question relating to personal data in its possession, the Investment Corporation shall, after verifying the identity of the individual using the designated procedure, accept any request to provide notification of the usage purpose based on the law and regulation or to disclose, revise, add, delete, or eliminate personal data, prevent its use, or prevent its being shared with any third party (hereinafter collectively referred to as “Disclosure, Etc.”). To request notification of the usage purpose or request Disclosure, Etc. with respect to personal data possessed by the Investment Corporation, please use the contact information in Section 7 below. No processing fees will be charged for requests for Disclosure, Etc.

7. Inquiries

For questions or complaints relating to the handling of personal information, requests for notification of the usage purpose, or requests for Disclosure, Etc., please use the contact information below. We will inform you of the necessary procedures, etc.
Financial Planning Department, Tokaido REIT Management Co., Ltd.

2-2-1 Otemachi, Chiyoda-ku, Tokyo 100-0004
Phone no.: +81-3-6281-6880
Hours of operation: Monday to Friday, 9 a.m. to 6 p.m. (excluding national holidays, year-end and New Year holidays)
Inquiries about matters relating to the unitholder register are handled by the Investment Corporation’s Unitholder Register Administrator.
Securities Agent Department, Mizuho Trust & Banking Co., Ltd.

2-8-4 Izumi, Suginami-ku, Tokyo 168-8507
Phone no.: 0120-288-324 (toll-free in Japan only)
Hours of operation: Monday to Friday, 9 a.m. to 5 p.m. (excluding national holidays, year-end and New Year holidays)

8. Continuous Improvement of Personal Information Protection System

　In addition to cases based on revisions of laws, regulations, etc., the Investment Corporation shall review the Privacy Policy as needed and work to strengthen and improve its initiatives relating to personal information protection.