Personal Information Protection Policy
(Privacy Policy)

Established August 4, 2020

Tokaido REIT Management Co., Ltd. (“the Company”), 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 other personal information protection-related laws, regulations, guidelines from relevant authorities, etc., with regard to the handling of personal information 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 Company is strongly aware of the importance of protecting personal information, and in compliance with the Personal Information Protection Act and other laws, regulations, guidelines from relevant authorities, etc., it shall not use personal information for purposes other than the intended use, 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 Company shall abide by the following items:

It shall not obtain personal information using deception or other unlawful methods.
Except in cases where permitted to do so by the laws and regulations, 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 the laws and regulations, 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 the laws and regulations, 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 strive to 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 Company 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 Company 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 it 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 Company shall only use personal information within the scope required to fulfill the purposes below. If the Company 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 Trust Act”) and other laws, regulations, and rules that apply to the Company.
To carry out tasks relating to the acquisition or disposal of assets under management by Tokaido REIT, Inc. (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 Trust 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 identity 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 Company and the Investment Corporation, the fulfillment of the Company and the Investment Corporation’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 Trust 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 the Company based on the Investment Trust Act, the Financial Instruments and Exchange Act, and other laws, regulations, and rules applying to the Investment Corporation and the Company.
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 Company shall not provide personal data in its possession to any third party without the prior written consent of the individual in question, except in the following cases:

In cases stipulated by the laws and regulations
In cases where it is necessary to protect an individual’s life, health, or property 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 the laws 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 consent, except in cases stipulated by the laws and regulations.

5. Appropriate Management of Personal Information

Insofar as is possible, the Company 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 Company 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. Safe Management Measures and Internal System

The Company shall appoint a personal information protection manager, implement necessary and appropriate safe management measures, and implement appropriate personal information management. The Company shall provide education and practical training for executives and employees relating to personal information protection and appropriate management methods, and it shall comprehensively implement appropriate handling of personal information in its day-to-day tasks.

7. 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 Company 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 laws and regulations 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.”).

8. 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)
In addition, the Company is a member of The Investment Trusts Association, Japan, an authorized personal information protection organization accredited by the Financial Services Agency. The Association handles complaints and inquiries regarding personal information handled by its members, with its Investor Enquiry Section serving as the contact point. Please use the following contact information:

Investor Enquiry Section, The Investment Trusts Association, Japan

Phone no.: +81-3-5614-8440
Hours of operation: Monday to Friday, 9 a.m. to 11:30 a.m. and 12:30 p.m. to 5 p.m. (excluding national holidays and the Association’s designated non-business days)

9. Continuous Improvement of Personal Information Protection System

In addition to cases based on the revision or elimination of laws, regulations, etc., the Company shall review its personal information protection policy as needed and work to strengthen and improve its initiatives relating to personal information protection.

Personal Information Protection Policy(Privacy Policy)