Declaration of Policy for Initiatives on Personal Information Protection
In recognition of the importance of personal information, Japan Prime Realty Investment Corporation ("JPR") shall respect and comply with the laws, regulations and guidelines, etc. on the protection of personal information, and endeavor to properly handle and protect personal information it has obtained.
Management of Personal Information
In order to prevent leakage, losses or damages, etc. of the personal information, JPR will endeavor to protect the personal information it owns by taking appropriate security management measures pursuant to laws, regulations and guidelines, etc.
JPR will provide education on appropriate handling of personal information also to employees, and strive to ensure the protection of such information.
Consignment of Handling Personal Information and Supervision of the Consigned Parties
JPR may totally or partially consign handling of personal information it holds to external operators. When it does so, it shall select parties recognized to appropriately handle personal information, and include measures such consigned parties have to take to ensure security management in the contracts, etc. with them. Through these and other arrangements, JPR shall periodically check how personal information is handled by them to make sure that security management measures for the personal information consigned to them are implemented.
Collection of Personal Information
When JPR collets personal information, it shall do so through appropriate and fair means. In addition, JPR shall disclose the purposes of use when it obtains personal information directly from individuals in writing, such as application forms and contracts, or through the website, etc. However, indication of the purposes of use may be omitted if they are clearly understood from the circumstances in which such information is collected.
Purposes of Use of Personal Information
JPR will use the personal information it has obtained for the following purposes.
- Identity verification and credit checks of parties indicated in application forms, contracts and other documents as well as websites with regard to JPR's business
- Various work operations associated with implementation of its contractual assignments regarding the investment management business
- Survey and analysis, collection of materials, marketing activities and provision of various information (such as making visits, sending post carts and direct mails, making phone calls and sending e-mails) needed for implementing the investment management business
- General administrative work regarding the investment management business and related or incidental work operations (notifications and inquiries to the unitholders and other notifications and inquiries regarding general administrative work)
- Confirmation of visitors to JPR and recording of how such visits are handled
- Other corporate activities related or incidental to the operations of JPR (recruitment activities, shareholder communications and inquiries and other general administrative communications and inquiries)
- Disclosure and provision of personal information to third parties to the extent necessary to achieve the purposes of use in 1 through 6 above
When there is the necessity to use personal information beyond the scope of the purposes of use after receiving such personal information, JPR shall obtain the consent of the relevant individuals in advance.
Disclosure and Provision of Personal Information, etc to Third Parties
JPR will not disclose or provide personal information it has acquired to third parties with the exception of the following. Also, JPR will not disclose or provide personal-related information it has acquired to third parties with the exception of the following. Records will be made in accordance with laws and regulations when disclosing or providing personal information or personal-related information to third parties.
- When consent has been obtained from the relevant individuals
- When disclosure or provision is based on laws and regulations
- When it is necessary to do so for protecting people's lives, bodies or estates, in cases when it is difficult to obtain consent from the relevant individuals
- When it is necessary to do so particularly for improvement in public health or sound development of children, in cases when it is difficult to obtain consent from the relevant individuals
- When it is necessary to cooperate with national administrative organs, local governments or parties entrusted by them in conducting administrative operations designated by laws and regulations, in cases when obtaining consent from relevant individuals may cause problems in conducting such operations
- When JPR provides personal information to subcontractors which it supervises appropriately, within the scope necessary for achieving the purposes of use
- When personal information is acquired for the purpose of provision to a third party and the purpose, items of the personal information to be provided, the means or method of provision and the contact information for suspension requests are notified or when such is readily available to the individual
- When JPR provides personal information due to such occasions as mergers, corporate splits or business transfers, etc.
〔Personal-related information is information pertaining to a living individual which does not correspond to personal information, pseudonymized information or anonymized information〕
Provision of Personal Data, etc. to Third Parties Located in Foreign Countries
In the event that personal data or personal-related information is provided to a third party located in a foreign country , helpful information with regard to the provision will be given.
〔 Foreign country here excludes any "foreign country, etc. establishing a personal information protection system recognized to have equivalent standards to that in Japan in regard to the protection of an individual's rights and interests," namely Iceland, Ireland, Italy, the United Kingdom, Estonia, Austria, the Netherlands, Cyprus, Greece, Croatia, Sweden, Spain, Slovakia, Slovenia, the Czech Republic, Denmark, Germany, Norway, Hungary, Finland, France, Bulgaria, Belgium, Poland Portugal, Malta, Latvia, Lithuania, Liechtenstein, Romania and Luxembourg. 〕
Handling of Sensitive Information
JPR shall not collect, use or provide to third parties sensitive Information except for cases permitted under the guidelines set forth by the Financial Services Agency. Moreover, even when collection, use or provision to third parties is permitted, JPR shall obtain the consent of the relevant individuals in advance if such is required by laws and regulations.
〔Sensitive information refers to personal information which includes statements, etc. of which handling requires special care so as not to cause unfair discrimination, prejudice or other disadvantages to the individual, and includes personal information requiring special care defined in laws and regulations. 〕
Production of Anonymously Processed Information , etc.
When JPR produces anonymously processed information or provides such to a third party, JPR shall lawfully handle anonymously processed information, such as by processing personal information in accordance with laws and regulations and disclosing items prescribed in laws and regulations to the public.
〔Anonymously processed information refers to information relating to an individual that can be produced from processing personal information so as neither to be able to identify a specific individual by taking action prescribed in laws and regulations nor to be able to restore the personal information. 〕
Preparation of Pseudonymized Information , etc.
In the case of preparing pseudonymized information or providing it to third parties, JPR will process personal information based on laws and regulations and handle pseudonymized information lawfully such as by disclosing items required by laws and regulations.
〔Pseudonymized information refers to information about an individual obtained by processing personal information in such a way that the individual cannot be identified unless the information is cross-checked with other information by taking measures prescribed by laws and regulations〕
Disclosure, Corrections, Deletions and Suspension of Use, Etc. of Personal Information
JPR will manage personal information it has obtained as accurate and up-to-date as possible and delete personal information when it is no longer necessary for use. Also, when a request regarding personal information is received from the individual concerned or his or her representative, JPR will take measures such as notification, disclosure (including disclosure by way of providing electromagnetic records, etc.), correction, deletion and discontinuation of use of the purpose of use or the retained personal data which identifies the individual in accordance with laws and regulations upon confirming his or her identity as the concerned individual or his or her representative. However, requests for disclosure, correction, discontinuation, etc. may not be met if they violate other laws and regulations. In such cases, JPR will endeavor to explain the reason to the individual concerned. The same applies to disclosure of third-party provision records regarding the transfer of personal data.
Inquiries Relating to Personal Information
For questions as well as requests for disclosure, correction, deletion, suspension of use, etc. of personal information provided to JPR, please contact the following to be informed of the predetermined procedures, etc. necessary for disclosure, correction, deletion, suspension of use, etc. The following contact also receives your complaints.
Contact on Protection of Personal InformationCompliance Office
Tokyo Realty Investment Management, Inc. (the asset management company for JPR)
4-16 Yaesu 1-Chome, Chuo-ku, Tokyo 103-0028, Japan
For matters recorded in the register of unitholders, please contact the following.
Contact of the Transfer Agent for JPRStock Transfer Agency Department
Mizuho Trust & Banking Co., Ltd.
8-4, Izumi 2-chome, Suginami-ku, Tokyo 168-8507, Japan
Phone: Toll Free (in Japan only): 0120-288-324
Japan Prime Realty Investment Corporation