Privacy Policy
(Personal Information Protection Declaration)

1. Basic policy on the handling of personal information

ESCON JAPAN REIT Investment Corporation (hereinafter, "ESCON REIT") complies with the Act on the Protection of Personal Information (2003 Act No. 57,including subsequent amendments; hereinafter, the "Personal Information Protection Law"), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (2013 Act No. 27, including subsequent amendments; hereinafter, the "My Number Act"), and other related laws, regulations and guidelines (collectively with the Personal Information Protection Law and the My Number Act, hereinafter, "Laws"). ESCON REIT recognizes the importance of protecting personal information (individual number and specific personal information, hereinafter, "specific personal information"; unless otherwise stipulated elsewhere in this Privacy Policy, the same applies below), and shall properly handle, protect, and manage personal information.

  1. Acquisition of personal information
    ESCON REIT will acquire personal information only to the extent necessary for the purpose which ESCON REIT has established and by proper and legal means. ESCON REIT will not acquire any personal information without the prior consent of the person except as permitted by laws and regulations.
    ESCON REIT will not acquire any personal information untruthfully or by inappropriate means.
    ESCON REIT will clarify the purpose of use in advance, when acquiring personal information from an individual directly, through written documents and so forth.
    However, when the purpose of use is clear from the situation or when Laws permit, this clarification of the purpose of use may be omitted.
  2. Management of personal data
    ESCON REIT strives to keep personal data as accurate and up to date as possible, and to delete those pieces of personal data without any delay when they are no longer necessary. ESCON REIT will educate its employees and appropriately take necessary measures in accordance with each phase, such as acquisition, handling and protection of specific personal data, to appropriately control the acquisition, usage and management of personal data, to prevent unauthorized access, leakage, loss, destruction, and tampering of specific personal information and personal data.

2. Reasons for using personal information

  1. Reasons for use of personal information (excluding specific personal information. The same applies throughout this section, “2. Reasons for using personal information”).
  2. Except as permitted by laws and regulations or with the prior consent of the relevant person, ESCON REIT will handle personal information only to the extent necessary to achieve the purposes of use in the following cases.

    1. For the exercise of unitholders’ rights and duties based on the Act on Investment Trusts and Investment Corporations (Act No. 198 of 1951, including subsequent amendments; hereinafter, the "Investment Trusts Act") and other related laws and regulations as well as the exercise of ESCON REIT’s rights, duties and related procedures
    2. For the preparation and submission of ESCON REIT's reports, and the preparation and management of unitholders’ data based on the Investment Trust Act and the Financial Instruments and Exchange Act (Act No. 25 of 1948, including subsequent amendments) and other related laws and regulations
    3. To facilitate borrowings by ESCON REIT, to issue investment corporation bonds and investment units, and to implement other fund-raising tasks
    4. For the acquisition, disposition, lease of assets under management and implementation of various tasks such as research, review, collection and analysis of information based on the Investment Trusts Act
    5. To analyze market trends, conduct customer satisfaction surveys, and conduct product development surveys and analysis
    6. To provide information, etc. concerning the business of ESCON REIT to unitholders
    7. To respond to inquiries, requests for materials, etc. directed at ESCON REIT
    8. For the verification at the time of transaction on the Act on Prevention of Transfer of Criminal Proceeds (Act No. 22 of 2007, including subsequent amendments)
    9. To perform IR activities and general administrative duties related to ESCON REIT
    10. To provide personal information to third parties within the scope necessary to achieve or execute business related to the reasons for using personal information described above in items (1) to (9)
  3. Reasons for use of specific personal information
  4. Except as permitted by the My Number Act, ESCON REIT will handle specific personal information only to the extent necessary to achieve the purposes of use in the following cases, regardless of the consent of the person.

    1. Specific personal information related to officers of the company, etc.
      For office processes, including office processes related to tax withholding, notifications and applications related to social insurance/labor insurance, corporate pensions, etc.
    2. Specific person information related to individuals who are not officers of the company
      For business processes to create legal records, etc. that are legally required to include individual numbers

3. Providing personal data to third parties

ESCON REIT will not provide any personal data (here, excluding personal data related to specific personal information, etc.) to any third parties, except in the following cases. With regard to specific personal information, except for cases stipulated in the My Number Act, specific personal information will not be provided to any third parties, either with or without the consent of the person.

  1. When agreed to by the person
  2. When in accordance with laws and regulations
  3. When necessary for the protection of life, body or property under circumstances where it is difficult to obtain consent from the person in advance
  4. When necessary for the improvement of public well-being or the promotion of the healthy growth of children under circumstances where it is difficult to obtain consent from the person in advance
  5. When necessary for cooperating with national institutions, local public bodies, or the person entrusted by them, in executing operations prescribed by laws and regulations, and obtaining consent may impede the execution of those operations

4. Supervision over outsourcees

ESCON REIT may entrust to outsourcees all or part of the handling of specific personal information and personal data, to the extent necessary for achieving the purpose of use. ESCON REIT shall take necessary and appropriate safety measures for outsourcees to ensure the strict control of the security of entrusted specific personal information and personal data. ESCON REIT shall also perform supervision to determine whether appropriate oversight supervision is implemented when the personal information is further entrusted to other outsourcees.

5. Handling of sensitive information

Except as permitted by the Guidelines for the Protection of Personal Information in the Financial Sector, ESCON REIT will not acquire, use or provide to any third party sensitive information. Here, “sensitive information” is defined in the Guidelines for Protection of Personal Information in the Financial Sector as “personal information requiring attention” along with information regarding labor unions, family origin, legal address on family registry, healthcare and sex life that are not part of the “personal information requiring attention”. Notwithstanding the forgoing, information disclosed by the person concerned, national institutions, local public bodies, or the person set out in the Personal Information Protection Act or the Ordinance for Enforcement of the Act on the Protection of Personal Information is not considered “sensitive information”. Also, information obtained by visual inspection or photography which can be identified by its presence is not considered “sensitive information”.

6. Application for disclosure of personal data

ESCON REIT shall, in accordance with an invoice including identifying documents specified by the asset management company (hereinafter, Asset Management Company) to which ESCON REIT has entrusted assets management, immediately and without delay respond to a request from the person to receive notification of the purpose of use, or disclose, correct, append to, delete, cease use of, remove, or cease provision to a third party of personal data pertaining to that person (hereinafter, Application for Disclosure), after confirmation of identity and ownership.
For further details, apply to one of the service desks indicated in Section 8. There are cases where we will charge for sending documents that constitute a response to a request for notification of purpose of use or disclosure of retained personal data. However, ESCON REIT may refuse the disclosure of all or part of the personal data, and give the reason without delay, in the following cases:

  1. When it may harm the life, body, property and other rights and interests of the person or a third party
  2. When it may result in conspicuous impediment to the business operations of ESCON REIT
  3. When it is in violation of laws and regulations

7. Continuous improvement

In addition to complying with the Privacy Policy, ESCON REIT will continue to make improvements in the future by reviewing the policy in accordance with the revision of laws and regulations, and an increase or a change in public demand.

8. Inquiries and help desks

Please see the contact information below for questions and requests for disclosure, correction, and suspension of provided personal information. If ESCON REIT receives any complaints about the handling of acquired personal information, etc., it will investigate the details in order to deal with them in an appropriate way within a reasonable period of time.

Asset Management

ES-CON ASSET MANAGEMENT Ltd. Department of Finance and Control
Address

The Okura Prestige Tower 20F, 2-10-4, Toranomon, Minato-ku, Tokyo, 105-0001

Phone +81-3-6230-9338
Hours 9:00 am – 5:00 pm
(closed on weekends, holidays, and the New Year period)

For inquiries about the unitholders registry, please contact our transfer agent at the number shown below.

Sumitomo Mitsui Trust Bank Ltd. Stock Transfer Agency Business Planning Dept.
Address

2-8-4 Izumi, Suginami-ku, Tokyo, 168-0063, Japan

Phone 0120-782-031 (toll-free in Japan)
Hours 9:00 am – 5:00 pm
(closed on weekends and holidays)
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