Basic Policy on Handling of Specific Personal Information, Etc.
(Basic Policy on Appropriate Handling of Individual Numbers and Specific Personal Information)

Hulic Reit, Inc. (Hulic Reit) hereby sets forth the basic policy for implementing measures as an organization to ensure the appropriate handling of individual numbers and specific personal information (hereinafter referred to as “Specific Personal Information, Etc.” ) Furthermore, Hulic Reit has established as a separate document “Individual Numbers and Specific Personal Information Handling Regulations” that relates to handling of Specific Personal Information, Etc.

Compliance with Relevant Laws, Regulations, and Guidelines, Etc.

Hulic Reit will carry out the appropriate handling of Specific Personal Information, Etc. by complying with the “Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (hereinafter referred to as the “Numbers Act”),” “Act on the Protection of Personal Information,” “Guideline on Appropriate Handling of Specific Personal Information (Contractor’s Edition)” and “(Separate Volume) Guideline on Appropriate Handling of Specific Personal Information for Financial Services.”

Individual Number Related Administrative Tasks that Hulic Reit Handles and Purposes of Use of Specific Personal Information, Etc.

Hulic Reit will use Specific Personal Information, Etc. only within the scope necessary for performing the following administrative tasks relating to individual numbers.

  1. Individual number related administrative tasks for directors of Hulic Reit (including their dependent family members) (This includes administrative tasks relating to the following.)
    [Taxes]
    Administrative tasks relating to withholding tax or individual inhabitants tax
    [Social Insurance]
    Administrative tasks relating to employees’ health insurance (eligibility related, benefit related), administrative tasks relating to employees’ pension insurance (eligibility related), and administrative tasks relating to category III insured persons of the national pension system
  2. Individual number related administrative tasks for individuals other than directors of Hulic Reit. This includes administrative tasks relating to the following:
    ・ preparation of certificates of payment for remuneration, fees, etc.,
    ・ preparation of certificates of payment for dividends, distribution of surplus, and interest on funds.,
    ・ preparation of certificates of payment for real estate usage fees, etc., and
    ・ preparation of certificates of payment for consideration for acceptance of transfer of real estate, etc.

Restrictions on Acquisition, and Provision to Third Parties

Hulic Reit will not acquire Specific Personal Information, Etc. for purposes other than the purposes of use mentioned above. Moreover, except for cases recognized under the Numbers Act, Hulic Reit will not provide Specific Personal Information, Etc. to any third parties.

Matters Relating to Safety Management Measures

Hulic Reit will ensure that any third-party subcontractor, etc. adopts the necessary and appropriate measures in order to prevent the leak, loss, or damage of Specific Personal Information, Etc. and conduct other appropriate management of Specific Personal Information, Etc. In addition, Hulic Reit will ensure that any third-party subcontractor, etc. conducts the necessary and appropriate supervision of its employees who handle Specific Personal Information, Etc. for the purpose of safety management of Specific Personal Information, Etc.

Reporting of leaks, etc.

In the event of leakage, loss, or damage of specified personal information recorded in a specified personal information file, or other events related to ensuring the safety of specified personal information that are specified by the Personal Information Protection Committee Regulations as being highly likely to harm the rights and interests of individuals, Hulic Reit will notify person in question of the occurrence of such a situation in accordance with the Personal Information Protection Committee Regulations. However, this does not apply to cases where it is difficult to notify the person in question and alternative measures are taken as necessary to protect the person's rights and interests.

Continuous Improvement

Hulic Reit will strive to continually improve the handling of Specific Personal Information, Etc.

Contact for Inquiries

For inquiries regarding the measures we have taken for the secure management of personal data pertaining to specified personal information, etc., or for requests or complaints regarding our handling of specified personal information, etc., notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, deletion, or suspension of provision to third parties of Specified Personal Information, etc., please contact us at the following contact point.

(Hulic Reit)

Hulic Reit, Inc.

Address Hulic Ochanomizu Building 2F, 2-3-11 Kandasurugadai, Chiyoda-ku, Tokyo 101-0062, Japan
Executive Officer Kazuaki Chokki

(The management of the assets of Hulic Reit)

Hulic Reit Management Co., Ltd., Compliance and Risk Management Department

Address Hulic Ochanomizu Building 2F, 2-3-11 Kandasurugadai, Chiyoda-ku, Tokyo 101-0062, Japan
Tel +81-3-5244-5583
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 Japan)
9:00 a.m.-5:00 p.m. (Closed Saturdays, Sundays, holidays, and company holidays)

Amendment

This Basic Policy on Handling of Specific Personal Information, Etc. is subject to amendment in response to revision of the laws or other events.

Date of adoption: July 6, 2016
Revision: May 30, 2017
Revision: March 1, 2021
Revision: April 1, 2022
Revision: July 31, 2023

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