Handling of Personal Information

Recognizing the importance of protecting personal information when handling it, we (NTT UD REIT Investment Corporation) comply with the Act on the Protection of Personal Information (the “Act”) and other relevant laws, regulations, guidelines, etc., and strive to properly handle, manage and protect personal information by establishing and complying with the following Privacy Policy (the “Policy”). Regarding Individual Numbers and specific personal information (respectively defined in the Act on the Use of Numbers to Identify Specific Individuals in Administrative Procedures), we have separately established and comply with our Basic Policy on Proper Handling of Specific Personal Information.

1. Basic Policy on Handling of Personal Information

We understand that personal information is an important information asset and, recognizing that its acquisition, management and use to the extent necessary for business is not only a legal requirement but also our social responsibility, we comply with the following basic policy.

  • We acquire personal information by appropriate and lawful means to the extent necessary to achieve our stipulated purposes of use. We do not acquire personal information in a manner that is deceptive or otherwise fraudulent or that unjustly infringes the interests of the individual. In addition, we do not acquire sensitive personal information without the consent of the individual unless otherwise stipulated by laws and regulations.
  • We store and manage acquired personal data in an accurate and up-to-date state and endeavor to delete such personal data without delay when it is no longer necessary to use it. In addition, in order to prevent unauthorized access, leakage, loss, damage or alteration of personal data, we thoroughly educate employees and take necessary and appropriate measures to safely manage it.
  • We do not handle acquired personal information beyond the scope necessary to achieve our stipulated purposes of use except in cases where we have obtained prior consent from the individual or in exceptional cases permitted by laws and regulations.
  • We endeavor to respond appropriately and promptly within a reasonable period of time when we receive a complaint regarding the handling of personal information. For inquiries regarding our handling of personal information, please contact us using the information in 9. below.

2. Purposes of Use of Personal Information

We handle personal information only to the extent necessary to achieve the purposes of use set forth below, except in cases where we have obtained prior consent from the individual or in exceptional cases permitted by laws and regulations. In addition, when acquiring personal information described in a contract or other document directly from the individual, we specify the following purposes of use to the individual beforehand. However, we may not specify the purposes of use when they are clear from the context of the acquisition or otherwise recognized by laws and regulations.

  • In the relationship between our unitholders and us, to exercise unitholders’ rights or fulfill our obligations to unitholders based on the Act on Investment Trusts and Investment Corporations (the “Investment Trusts Act”) and other relevant laws. To fulfill our other obligations and exercise our rights as well as execute any work incidental to this.
  • To prepare and submit various reports based on the Investment Trusts Act, the Financial Instruments and Exchange Act (the “Financial Instruments Act”) and other relevant laws and regulations and prepare various data and manage information related to our unitholders.
  • To execute asset acquisition, brokerage, sale, transfer, lease and management as well as information collection, research analysis and examination.
  • To conduct market trend analysis, customer satisfaction surveys and research analysis for product development, etc., and analysis of the attributes of our unitholders for the purpose of implementing IR activities.
  • To execute business borrowing capital and issuing additional investment units and raising capital.
  • To notify our unitholders of our business.
  • To respond to inquiries or requests for materials, etc. to us.
  • To confirm the Act on Prevention of Transfer of Criminal Proceeds when transacting.
  • To provide to third parties to the extent necessary to execute appropriate business.
  • To execute business incidental or relevant to the above.

3. Proper Use of Personal Information

We do not use personal information in a manner that may encourage or induce illegal or unjust acts.

4. Provision of Personal Data to Third Parties

We do not provide acquired personal data to third parties except in the following cases.

  • When the individual consents
  • When based on laws and regulations
  • When necessary to protect a person’s life, body or property, and it is difficult to obtain the consent of the individual
  • When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the individual
  • When it is necessary to cooperate with national institutions or local public entities or those entrusted to carry out their affairs as stipulated by laws and regulations, and there is a risk of obstructing the execution of these affairs by obtaining the consent of the individual
  • When otherwise provided in the Act

5. Acquisition of Sensitive Information

Except in cases stipulated in the Guidelines for Personal Information Protection in the Financial Field, we do not acquire, use or provide to third parties sensitive personal information or information on trade union membership, ancestry, homeland, healthcare or sex life (excluding that which falls under sensitive personal information, is disclosed by the persons listed in the Act or the Enforcement Rules for the Act on the Protection of Personal Information (the “Enforcement Rules of the Act”) such as the individual, a national institution, local public entity and academic research institute, or is obvious from the individual’s appearance such as that which can be acquired by seeing or photographing the individual).

6. Safety Management Measures and Supervision of Subcontractors

We take preventive and safety measures against leakage, loss or damage of personal data as well as necessary and appropriate organizational safety management measures, human safety management measures, physical safety management measures and technological safety management measures to ensure other safe management of personal data (when handling personal data in a foreign country, we take such safety management measures after understanding the system on the protection of personal information, etc. in the foreign country). In addition, when we outsource all or part of the handling of personal data to an outside party, we take appropriate measures to protect personal data based on laws and regulations and implement the necessary and appropriate supervision of the subcontractor to ensure safe management of entrusted personal data. For details of our safety management measures for personal data, please use the contact information in 9. below.

7. Procedure for Disclosure of Stored Personal Data

If we receive a request for stored personal data disclosure, correction, addition, deletion, suspension of use, elimination, suspension of provision to a third party or disclosure of record on provision to a third party (“disclosure, etc.”) based on the Act or for notification of purposes of use by a request form prescribed by the asset management company to which we entrusts asset management (the “asset management company”) with stipulated ID verification documents attached, we respond appropriately without delay based on laws and regulations as soon as we can confirm that the request is from the individual or a legitimate proxy. However, we may not be able to respond to requests for disclosure, etc. or notification of purposes of use in certain cases such as when there is a risk of harming the life, body, property or other rights or interests of the individual or a third party. In those cases, we will notify the individual or their proxy of the reason without delay. For details of the procedure, please use the contact information in 9. below. In addition, notification of purposes of use, disclosure of stored personal data or disclosure of record on provision to a third party may incur a prescribed fee.

8. Continuous Improvement

The contents of this Policy will be applied from the date it is posted on this website. We strive to improve our management of personal information by continuously reviewing its contents and revising it as necessary. If the contents of this Policy are revised, we will immediately post it on our website.

9. Contact

Please use the following contact information for inquiries regarding details of the measures which we have taken to ensure safe management of personal data and our handling of personal information, requests for disclosure of stored personal data, requests for notification of purpose of use and complaints.

【Inquiries regarding matters stated in unitholder registries of the Investment Corporations】

Please use the following information to contact the unitholder registry administrator to correct, add to or delete items in the unitholder registries.

Name Securities Agency Department, Sumitomo Mitsui Trust Bank, Ltd.
Address 2-8-4 Izumi, Suginami Ward, Tokyo 168-0063
TEL 0120-782-031 (toll-free only in Japan)
Business Hours 9 a.m. to 5:00 p.m. (excluding Saturdays, Sundays, public holidays, etc.)

【Inquiries regarding other personal information】

Please use the following information to contact the asset management company to correct, add to or delete personal information other than the above.

Name NTT Urban Development Asset Management Corporation
Address 1-5-1 Otemachi, Chiyoda Ward, Tokyo 100-0004
TEL +81-3-6262-9400
Business Hours 9 a.m. to 5:30 p.m. (excluding Saturdays, Sundays, public holidays, etc.)

10. Name, Address, and Title and Name of Representative of Entity Handling Personal Information

Name NTT UD REIT Investment Corporation
Address of Head Office 1-5-1 Otemachi, Chiyoda Ward, Tokyo 100-0004
Title and Name of Representative Takeshi Oodera, Executive Director
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