In recognition of the importance of maintaining the security of personal information, ESR REIT Management Ltd. (the "Company") strives to handle personal information appropriately, and complies with the Act on the Protection of Personal Information (the "Personal Information Protection Act") and other related laws and regulations, and rules when protecting such information. Note that the Company has established and observes a separate policy entitled the "Basic Policy on the Handling of Specific Personal Information" in relation to individual numbers and specific personal information (the meanings of each as provided in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures).
1. Basic Policy on the Handling of Personal Information
The Company recognizes personal information it handles as a vital information asset for business, and that the proper handling of personal information in its possession is not only a legal requirement but also a social responsibility. In light of this, the Company strives to protect personal information in accordance with the following basic policy:
- The Company shall obtain personal information through appropriate and lawful means, and only to the extent necessary for conducting business. Except as provided under laws and regulations, etc., the Company shall not acquire personal information considered to be important without obtaining the prior consent of the relevant person; nor shall the Company acquire sensitive information (as defined in the Guidelines on the Protection of Personal Information in the Financial Sector; hereinafter referred to as the "Financial Sector Guidelines"), except as provided for under the Financial Sector Guidelines.
- Unless otherwise required by laws and regulations, etc., the Company shall not handle any personal information in its possession beyond the scope necessary to achieve the purpose of use of the personal information. Unless otherwise set forth in the Financial Sector Guidelines, the Company shall not use sensitive information.
- The Company shall endeavor to manage personal information in its possession accurately and with the most up to date content to the extent necessary to achieve the purpose of use, and shall take strict safety management measures below for prevention of leakage, loss, and damage in respect of personal data and for other safe management of personal data.
- Organizational security measures
The Company designates a person responsible for handling of personal information and protection plan to implement, evaluate and improve security measures.
- Personnel security measures
The Company provides its employees with education and training on the proper handling of personal information.
- Physical and technical security measures
The Company has implemented access control measures for personal information and the information systems that handle personal information as well as measures against unauthorized software, monitoring of information systems, etc.
- Understanding of the external environment
The Company stores the customers’ personal information in its possession in Japan.
2. Purposes of Use of Personal Information
- Unless otherwise required by laws and regulations, etc., the Company shall use personal information and retained personal data in its possession to the extent of the purposes of use set forth below in order to perform the asset management entrusted by an investment corporation (the "Investment Corporation"):
- To allow unitholders to exercise their rights, and to carry out the Investment Corporation's obligations to the unitholders in accordance with the Act on Investment Trusts and Investment Corporations (the "Investment Trusts Act") and other laws and regulations, etc.
- To prepare each item of data pertaining to unitholders of the Investment Corporation, manage other information, and provide information to the unitholders in accordance with the Investment Trusts Act and other laws and regulations, etc.
- To perform operations related to the acquisition, transfer and leasing of property, as well as entrustment of property management by the Investment Corporation, as well as the information collection, research, analyses and studies for the performance of such operations.
- To perform operations related to IR activities and general administration, etc. for the Company.
- To perform work incidental or related to the duties listed above.
- To disclose or provide personal information to external experts such as lawyers and certified public accountants to the extent necessary for the purpose of achieving the objectives listed above.
- Except as provided under laws and regulations, etc., the Company shall notify or announce the purpose of use of personal information as follows:
- The Company shall notify the relevant person of or announce the purpose of use of personal information promptly when it acquires personal information, except where the purpose has been announced in advance.
- When, upon concluding an agreement with the relevant person, the Company acquires personal information described in the agreement or in other documents, the Company shall clearly state the purpose of use to the relevant person in advance, except as urgently necessary for protecting a person’s life, body or property.
- When the Company amends the purpose of use, the Company shall notify the relevant person of or announce the amended purpose of use.
3. Provision of Personal Data to Third Parties
The Company does not provide personal data to third parties without obtaining the prior consent of the relevant person, except in the following cases:
- When the provision of personal data is permitted by laws and regulations.
- When it is difficult to obtain the consent of the relevant person where providing the personal data is necessary for protecting a person's life, body or property (including the property of a corporation).
- When it is difficult to obtain the consent of the relevant person where providing the personal data is particularly necessary for improving public health or promoting the sound development of children.
- When providing personal data is necessary for cooperating in the activities of national or local government authorities, or of a representative entrusted by such authorities in accordance with laws and regulations, and obtaining the consent of the relevant person is likely to impede the execution of such activities.
4. Outsourcing and Supervision of Contractors
When the Company consigns third parties to manage all or part of the handling of personal data, the Company conducts necessary and proper supervision of the third parties to ensure that the personal data which the third parties are consigned to handle is securely managed.
5. Proceedings in respect of Disclosures, Etc., of Retained Personal Data
With respect to requests for disclosure (including disclosure regarding whether or not personal data is held), correction, addition, deletion, suspension of use, erasure, or suspension of provision to third parties (the “Disclosures, Etc.”) by the relevant person with regard to retained personal data by which the relevant person is identified, for the purpose of protecting privacy of the relevant person, the Company shall accept such requests only in the case where the relevant person (including a representative) makes a request in accordance with the procedure set forth below, and in the form specified by the Company (the “Request for Disclosures, Etc.”). In the case where the Company is unable to accept all or part of the requests, the Company shall notify the relevant person to that effect without delay and explain the reason to the relevant person.
- Contact Information in respect of Request for Disclosures, Etc.
See “Contact for Inquiries” in 7 below.
- Method of request for form of documents to be submitted in requesting Disclosures, Etc. and for any other Disclosures, Etc.
In requesting Disclosures, Etc., please submit the Request for Disclosures, Etc., to include the following items, by postal mail:
- Name, address, and contact details of the relevant person
- If the request is made by a representative: the name, address, and contact details of the representative
- Items identifying the retained personal data connected with the request for Disclosures, Etc.
- The address to which any notifications, results of surveys, or responses from the Company should be sent
- Method of confirming whether the person who requests Disclosures, Etc. is the relevant person or its legal representative
In order to allow us to identify the relevant person, please submit copies of each of the following documents:
- Identification documents such as driving license, health insurance certificate, alien registration certificate, or basic resident registration card of the relevant person
- Either the resident certificate or the original alien registration certificate.
If the request is made by a representative, please submit one of the following documents to confirm the authority of the representative (in case of (b) below, by presentation or submission).
- In the case of a representative by proxy: a letter of proxy specified by the Company and signed by the relevant person with his/her own registered seal and the person's seal-registration certificate
- In the case of a legal representative: a document confirming eligibility to make the request, such as an official copy of the family register, an excerpt of the family register, or a certificate of registered matters
- Amount of fees and methods of payment
The fee is 1,000 yen per request for Disclosures, Etc. (not including consumption tax) and should be enclosed in the form of a postal order in the same envelope as the Request for Disclosures, Etc., when the request is sent by postal mail.
- Methods used to reply to requests for Disclosures, Etc.
The Company will send by postal mail its written responses to current address of the relevant person, as listed in the Request for Disclosures, Etc. (or, in the case of a request from a representative, responses will be sent to the contact address for the representative provided that the letter of proxy gives him/her the authority to receive personal information on the relevant person). Written responses will be dispatched, by certified mail, within one month of the date the Company receives the Request for Disclosures, Etc.
6. Efforts to Make Continuous Improvements
7. Contact for Inquiries
Please contact the following [Contact for Inquiries] for any question or complaint regarding personal information; any request for Disclosures, Etc. in respect of retained personal data; or any other inquires.
Contact for Inquiries at the Company
|3rd Floor, Kamiyacho Prime Place, 4-1-17 Toranomon, Minato-ku, Tokyo
|9:00 a.m. to 5:00 p.m. excluding Saturdays, Sundays, national holidays and New Year holidays
The Company is a subject business operator of the Investment Trusts Association of Japan, an authorized organization for the protection of personal information. The Association provides consultation for and accepts complaints on how subject business operators handle personal information.
Contact for Inquiries at the Investment Trusts Association
|9:00 a.m. to 5:00 p.m., excluding Saturdays, Sundays, national holidays, and New Year holidays
|ESR REIT Management Ltd.
|3rd Floor, Kamiyacho Prime Place, 4-1-17 Toranomon, Minato-ku, Tokyo
|Name of representative
|Kazuhiko Watanabe, Representative Director and President