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Handling of Personal Information

Privacy Policy

Last modified: May 30, 2017

Premier REIT Advisors Co., Ltd. (PRA) has prepared the following policy (hereafter, the "Policy") regarding handling of personal information from the viewpoint of preventing loss, leakage, falsification, etc. of the information and protecting it, and declares compliance with the Policy.

Based on the Policy, PRA is resolved to make the utmost effort to appropriately manage personal information by establishing rules and regulations to protect personal information and having them thoroughly implemented by all officers and employees.

Please note that, of the personal information, the Policy does not cover the Social Security and Tax Numbers (the individual numbers as defined in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (Act No. 27 of 2013, as amended). For the handling of the Social Security and Tax Numbers, please refer to the Policy on the Social Security and Tax Numbers PRA has established separately.

1. Compliance with Applicable Laws and Regulations

PRA shall comply with the Act on the Protection of Personal Information (Act No. 57 of 2003, as amended; hereafter, the "Act"), other laws and regulations as well as guidelines by competent government agencies, etc. by appointing an administrative officer in charge of handling personal information.

2. Appropriate Collection of Personal Information

PRA shall collect personal information through legitimate and fair methods. When personal information is collected indirectly through any third party, PRA shall not accept it if PRA suspects that it may have been obtained unjustly by the providing party.

3. Purpose of Use of Personal Information

PRA will use personal information only to the extent necessary for achieving the following purposes except for cases permitted under relevant laws and regulations.

1) Exercise of rights by the holders of securities issued by the investment corporation established under the Act on Investment Trusts and Investment Corporations (Act No. 198 of 1951, as amended; hereafter, the "Investment Trusts Act") and other relevant laws and regulations and that entrusts its asset management to PRA (hereafter, the "Investment Corporation"), and fulfillment of the obligations of the Investment Corporation
2) Implementation of measures to facilitate smooth relationships between the Investment Corporation and the unitholders, its stakeholders
3) Administration of information on unitholders, including preparation and filing of various reports on the Investment Corporation pursuant to the Investment Trusts Act and other relevant laws and regulations as well as preparation of the unitholder's data
4) Responses to inquiries or requests for materials from those considering purchase of the securities issued by the Investment Corporation and other people, and contact with such persons
5) Issuance of corporate bonds and additional issuance of investment units by the Investment Corporation
6) Implementation of tasks related to acquisition of investment properties by the Investment Corporation, research before acquisition and investigation of acquisition, and solicitation of buyers, etc.
7) Implementation of tasks related to leasing of investment properties owned by the Investment Corporation, grasp of their leasing status, and collection, statistics and analyses of data regarding leasing
8) Registration procedures
9) Other use as necessary to facilitate the appropriate and smooth implementation of tasks related to PRA and the Investment Corporation
10) Provision of personal information to third parties as needed to achieve the use purposes described in the above items

4. Securing Accuracy of Information and Keeping It Up-to-date

PRA shall make efforts to secure accuracy of personal information it possesses and keep the information up-to-date.

5. Provision of Personal Information to Third Parties

Except where approved by laws and regulations and similar cases, PRA shall not provide personal information to any third party without obtaining the prior consent of the individual.

6. Outsourcing of Services

When consigning the handling of personal information to third parties in association with outsourcing of services, PRA shall take measures to protect personal information by checking the personal information protection systems of the consigned parties, establishing necessary provisions in contracts and through other means.

7. Security Management of Personal Information

Upon handling personal information, PRA shall establish a security management system necessary for protecting personal information, by taking appropriate security management measures in terms of organization, personnel affairs and information systems.

8. Procedures regarding Disclosure, Etc. of Personal Information PRA Owns

1) When a person wishes to request disclosure of his or her own personal information that PRA owns or makes other requests pursuant to Article 27-2, 28-1 and 29-1, and 30-1 and 2 of the Act, he or she is asked to do so by sending or bringing the request form designated by PRA along with an identification material (original or copy of driving license, residence certificates, etc.) in advance. Furthermore, when such a request is made through a proxy, please also submit a material that identifies the proxy (power of attorney, family register, abstract of family register, etc.).
2) As a rule, any response or other notification from PRA will be sent to the requesting person in a confidential mail that cannot be received by anyone other than the designated person in order to protect his or her privacy. Accordingly, please note that PRA may respond directly to the requesting person even if the request is made through a proxy.
3) PRA's contact regarding inquiries or complaints, etc. regarding handling of personal information is as follows:
General Affairs Dept., Premier REIT Advisors Co., Ltd.
Phone: +81-3-6630-4611 (9:00 am - 5:00 pm Japan Standard Time (weekdays only)
(4) The name and contact for complaint resolution of the authorized personal information protection organization, of which PRA is a member, is as follows.
Investor Consultation Section, The Investment Trust Association, Japan
Phone: +81-3-5614-8440

9. Continuous Improvement of the Personal Information Protection System

PRA shall prepare and enhance internal regulations regarding protection of personal information and continuously review them in an effort to make improvements.

10. PRA may modify the Policy as necessary. Please check when it was last modified.

Policy on the Social Security and Tax Numbers

Last modified: December 22, 2015

Premier REIT Advisors Co., Ltd. (PRA) has prepared the following policy (hereafter, the "Policy") in an organizational endeavor to secure appropriate handling of specific personal information, etc., and declares compliance with the Policy.

Based on the Policy, PRA has also established rules and regulations to secure appropriate handling of the individual numbers (the Social Security and Tax Numbers) and personal information that contains the individual numbers (hereafter, collectively referred to as the "specific personal information, etc.") and had them thoroughly known and implemented by all officers and employee. As such, PRA is resolved to make the utmost effort to secure appropriate handling of the specific personal information.

1. Compliance with Applicable Laws and Regulations

PRA shall comply with the Policy as well as the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (Act No. 27 of 2013, as amended; hereafter, the "Act"), other relevant laws and regulations as well as guidelines by competent government agencies, etc. by appointing an individual numbers administrative officer in charge of handling the specific personal information, etc.

2. Appropriate Collection of the Specific Personal Information, Etc.

PRA shall collect the specific personal information, etc. through legitimate and fair methods and only when it is approved by laws and regulations and in similar cases.

3. Purpose of Use of the Specific Personal Information, Etc.

PRA will use the specific personal information, etc. only within the extent necessary for performing the following operations related to the individual numbers except for cases authorized under relevant laws and regulations.

1) Preparation of tax withholding slips for salary income and retirement income
2) Filing for inhabitants tax
3) Filing for employment insurance
4) Filing for employees' health insurance and employees' pension insurance
5) Filing for insured individual (type 3) under the National Pension System
6) Preparation of records on the payments of compensations, fees, etc.
7) Preparation of records on the payments of dividends, surplus or interests
8) Preparation of records on the payment of use fees for real estate, etc.
9) Preparation of records on the payment of considerations for acquiring real estate, etc.

4. Securing Accuracy of Information and Keeping It Up-to-date

PRA shall make efforts to secure accuracy of the specific personal information, etc. it possesses and keep the information up-to-date.

5. Provision of the Specific Personal Information, Etc. to Third Parties

Except where approved by laws and regulations and similar cases, PRA shall not provide the specific personal information, etc. it collects to any third party.

6. Outsourcing of Services

When consigning the handling of the specific personal information, etc. to any third party in association with outsourcing of services, PRA will select parties that have taken full measures to protect the specific personal information, etc. and will conduct necessary and appropriate supervision on the consignees by establishing necessary provisions in contracts and through other means.

7. Security Management Measures of the Specific Personal Information, Etc.

Upon handling the specific personal information, etc., PRA shall establish a security management system necessary for protecting the specific personal information, etc. by taking appropriate security management measures in terms of organization, personnel affairs and information systems, etc.

8. Procedures regarding Disclosure, Etc. of the Specific Personal Information

(1) For the procedures with regard to requests for disclosure, etc. of the specific personal information, etc. that PRA owns, please refer to 8. Procedures regarding Disclosure, Etc. of Personal Information PRA Owns in the Privacy Policy.
(2) PRA's contact for inquiries or complaints, etc. regarding handling of the specific personal information, etc. is as follows:
General Affairs Dept., Premier REIT Advisors Co., Ltd.
Phone: +81-3-6630-4611 (9:00 am - 5:00 pm Japan Standard Time, weekdays only)

9. Continuous Improvement of the Protection System for the Specific Personal Information, Etc.

PRA shall prepare and enhance internal regulations regarding protection of the specific personal information, etc. and continuously review them in an effort to make improvements.

10. PRA may modify the Policy as necessary. Please check when it was last modified.

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