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Privacy Policy

Hulic Reit, Inc. (hereafter referred to as “Hulic Reit”) works to ensure the appropriate management, use, and protection of personal information by implementing the personal information protection policy and related approaches set out below.
In addition, Hulic Reit has also separately established the “Basic Policy on Appropriate Handling of Individual Numbers and Specific Personal Information,” which governs the policies of Hulic Reit on the protection, the purpose of use, acquisition and third-party provision of individual numbers and specific personal information.

Basic Policy

Hulic Reit recognizes the importance of personal information and complies strictly with the Act on the Protection of Personal Information and related regulations, standards, internal corporate regulations, and so on. Hulic Reit will not use personal information other than for the stated purposes, will respond appropriately to related complaints, and so on, and will work to ensure the appropriate handling of personal information and its safe and accurate management.

Purposes of Use

Hulic Reit will use the personal information it obtains only within the scope of the Purposes of Use set out below.

(i) To allow the exercise of unitholders’ rights and perform Hulic Reit’s duties pursuant to the Act on Investment Trusts and Investment Corporations (hereafter referred to as the “Investment Trusts Act”) and other related laws and regulations.
(ii) To manage unitholder information including preparing data for the unitholders’ registry or other items pursuant to the Investment Trusts Act.
(iii) To conduct operations in connection with the issuance of investment units for subscription and the issuance of investment corporation bonds for subscription.
(iv) To conduct operations (e.g., provision of responses, confirmation of content) arising from inquiries, requests for information materials, or similar applications from potential customers who are considering the purchase of securities (investment securities and investment corporation bonds) issued by Hulic Reit.
(v) To conduct surveys, analyses, and investigations concerning the management of assets of Hulic Reit.
(vi) To conduct operations involved in the acquisition, transfer, leasing, and sale of assets and in the management of real estate by Hulic Reit.
(vii) To conduct operations related to Hulic Reit’s investor relations activities, sales activities and general administration, and other activities of Hulic Reit.
(viii) To determine and pay the remuneration of directors, etc. of Hulic Reit, manage human resources and employment (including cases of selection procedures, and correspondence and procedures following retirement), contact employees for work purposes, and conduct other necessary procedures for performing work.
(ix) To provide to a third party within the scope necessary to carry out operations associated with or connected to items (i) to (viii) above or to perform such operations.

Acquisition, Use, Provision, and Entrustment of Personal Information

(1) Acquisition and use of personal information

Hulic Reit will acquire personal information only in approved ways and handle the personal information only within the scope of the stated Purposes of Use.

(2) Provision of personal data including personal information

Where Hulic Reit provides or discloses personal data including personal information to third parties, the consent of the person concerned will in principle be obtained in advance.

However, we may use personal data including personal information or provide it to third parties without the consent of the person concerned in the following cases: (i) where it is prescribed by laws; (ii) where it is necessary for the protection of human life, health, or property and it is difficult to obtain the consent of the person concerned; (iii) where it is specifically necessary for the improvement of public health or the healthy development of children, and it is difficult to obtain the consent of the person concerned; (iv) where it is necessary in order to cooperate in the execution of legally prescribed duties by central or local government organizations or parties working on their behalf and obtaining the consent of the person concerned might interfere with the execution of such duties; and (v) in other cases where provision to third parties is permitted by the Act on the Protection of Personal Information. Furthermore, personal data including personal information may be provided to outside parties other than Hulic Reit where such action does not constitute provision to third parties under the terms of the Act on the Protection of Personal Information, for instance where Hulic Reit has outsourced all or part of its handling operations of personal data including personal information within the scope of the stated Purposes of Use.
In cases where Hulic Reit outsources handling operations of personal data including personal information, it will put in place the appropriate measures in accordance with laws and regulations to ensure the protection of personal data and will select an outsourcing partner that has adequate measures for personal information protection and perform necessary and appropriate supervision, thus, Hulic Reit will seek to ensure a guaranteed level of personal information protection.

Appropriate Management of Personal Information

(1) Hulic Reit will handle the personal information it acquires appropriately and responsibly and will take the greatest care and put in place the necessary and appropriate safety management measures to prevent unauthorized access to the personal information, its loss, destruction, falsification, leaking, and so on.
(2) In the event of an accident, Hulic Reit will take measures to minimize damages and will put in place corrective measures to prevent recurrence.
(3) Hulic Reit will seek to conduct necessary and appropriate supervision to comply with relevant laws and regulations and protect personal information.

Acquisition, Etc., of Sensitive Information

Unless prescribed in the Guidelines on Personal Information Protection in the Financial Industry, in relation to personal information in the finance industry, Hulic Reit will refrain from the acquisition, use, or provision to third parties of sensitive information (i.e., information concerning personal information requiring consideration as prescribed in the Act on the Protection of Personal Information, membership of labor unions, family origin, domicile of origin, healthcare, and sexual orientation (except information that falls within the category of personal information requiring consideration)) except information publicly disclosed by the person concerned, national government agency, local government, or person specified by the Act on the Protection of Personal Information or Ordinance for Enforcement of the Act on the Protection of Personal Information or information that is clear from appearance through observation or filming of the person concerned.

Continuous Improvement

Hulic Reit subjects the contents of this policy to continuous review and amends it appropriately as necessary, and thus work to improve its personal information management systems and related functions.

Inquiries Concerning the Handling, Etc., of Personal Information

If Hulic Reit receives a request for disclosure, amendment, discontinuation of use, or notification of the purposes of use of retained personal data, or a complaint or similar communication regarding the handling of personal information, Hulic Reit will promptly respond to the reasonable extent. If you wish to request disclosure or amendment, discontinuation of its use, or notification of the purposes of its use of the content of retained personal data, or if you have a complaint or similar communication or other questions or comments regarding the handling of personal information, please direct them to each contact shown below.

(1) Contact for inquiries

If you have a question regarding personal information, if you wish to request the disclosure or amendment of personal data or the discontinuation of its provision to third parties, or if you have a complaint or similar communication or other inquiries, please direct them to the contact shown below.

Hulic Reit Management Co., Ltd., Compliance Department

Address 2-26-9 Hatchobori, Chuo-ku, Tokyo 104-0032, Japan
Tel +81-3-6222-7253 
9:00 a.m.-5:00 p.m. (Closed Saturdays, Sundays, holidays, and company holidays)

Note: For amendment, addition, or deletion of entries in the unitholders’ registry, please contact the transfer agent as shown below.

Mizuho Trust & Banking Co., Ltd., Stock Transfer Agency Department

Address 2-8-4 Izumi, Suginami-ku, Tokyo 168-8507, Japan
Tel 0120-288-324 (Toll free in Japan)
9:00 a.m.-5:00 p.m. (Closed Saturdays, Sundays, holidays, and company holidays)

(2) Procedure for requesting disclosure of retained personal data, etc.

For details of the procedure for requesting retained personal data disclosure, and so on, details of the necessary documentation and the various other procedures involved, and details of the methods used for confirmation of identity, the form of response from Hulic Reit, and other procedures, please address your inquiry to the relevant contact as shown above. Please note that in the case of requests for disclosure of retained personal data and requests for notification of the purposes of its use, we may request payment of the designated handling fees.

Amendment

This privacy policy is subject to amendment in response to revision of the laws or other events.

Date of adoption: December 11, 2013
Revision: July 6, 2016
Revision: May 30, 2017

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