The business handling personal information.；Sekisui House Asset Management, Ltd.
President and Representative Director；Toru Abe
Address；4-15-1 Akasaka, Minato-ku, Tokyo, Japan
Basic Policy
In handling personal information, Sekisui House Asset Management, Ltd. (hereinafter “SHAM”) shall comply with the Act on the Protection of Personal Information (hereinafter the “Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (hereinafter the “Number Use Act”), and other relevant laws, guidelines and in-house regulations, and strive for proper and safe management and administration in the handling thereof. Terms used in this Privacy Policy identical to those defined in relevant laws and regulations shall follow the definitions therein.
Purpose of Use
1. Purpose of Use of Personal Information
SHAM shall mainly collect the personal information of the holders of securities issued by Sekisui House Reit, Inc. (hereinafter “SHR”), whose assets SHAM manages on a commissioned basis, the tenants of SHR’s portfolio assets, and SHR’s other business partners.
SHAM may use the personal information described above for the following purposes:
- （1）to fulfill SHR’s obligations to the holders of securities issued by SHR;
- （2）to implement measures for facilitating interaction with SHR’s unitholders;
- （3）to prepare the registry of SHR’s unitholders and the registry of SHR’s investment corporation bond holders, prepare various statutory reports, and manage information about the unitholders and investment corporation bond holders;
- （4）to collect, statistically process and analyze data required to provide certain information to potential purchasers of investment units that were or will be additionally issued by SHR, investment corporation bonds that were or will be issued by SHR, and other securities that were or will be issued by SHR;
- （5）to collect and analyze data related to the acquisition of portfolio assets by SHR, surveys and investigations in connection with the acquisition thereof, and invitations for the buyer thereof, and to smoothly execute selling activities;
- （6）to properly implement leasing operations of SHR's investment assets (including use for questionnaires, etc. conducted to enhance the convenience, etc. for the users of such assets)
- （7）to outsource to such professionals as attorneys, certified public accountants, real estate appraisers, judicial scriveners and land and building inspectors, for the implementation of business by SHR
- （8）to borrow funds, issue investment corporation bonds and additionally issue investment units for asset acquisition and management by SHR; and
- （9）to implement other operations of SHAM or SHR appropriately and smoothly.
2. Purpose of Use of Individual Numbers
Notwithstanding the provisions of “1. Purpose of Use of Personal Information” above, SHAM may use individual numbers for the following purposes:
- （1）Individual numbers of clients, business partners, and shareholders
- (a) to prepare reports on financial instruments transactions, etc.
- (b) to prepare payment reports concerning payments of fees, charges, contract money, awards and other services, or of compensation of rights
- (c) to prepare payment reports concerning payments of compensation for use or transfer of real estate, etc.
- (d) to prepare payment reports concerning payments of cash distributions, surplus or interests, etc., and distribution of other profits
- (e) to prepare reports concerning grant or exercise of unit acquisition rights of SHR's investment units, or allotment of investment units without contribution
- (f) other work related to items (a) through (e) above
- (g) to prepare statutory reports and such that require individual numbers pursuant to laws and regulations
- （2）Individual numbers of the directors and employees of SHAM, and their relatives
- (a) prepare certificates of tax deductions pertaining to employment income and retirement income, prepare salary payment reports, submit reports of exemption (charge) for dependents, etc., submit insurance premium deductions and special tax exemptions for spouses of salary earners, and other work concerning tax withholding, etc.
- (b) to submit reports in connection with matters such as asset-building housing savings and asset-building pension savings;
- (c) to notify and file applications concerning health insurance, employees' pension insurance, employment insurance and other social insurance /labor insurance/corporate pension (including third insured persons under the National Pension Act), and defined contribution plans;
- (d) to perform other work related to items (a) to (c) above.
SHAM shall use personal information within the scope necessary to achieve the purpose of use thereof stated above for the objective of performing operations for managing the assets of SHR. SHAM shall not use personal information for any other purpose. SHAM shall not use sensitive information, except in cases where relevant laws, regulations, guidelines and the like permit the use of such information. Furthermore, SHAM shall not change the purpose of use of personal information beyond the scope reasonably recognized to be related to the purpose of the use thereof prior to the change.
Collection
1.Collection of Personal Information
SHAM shall collect personal information in a lawful and fair manner to the extent necessary to achieve the purposes of its use.
SHAM shall publish the purpose of use of personal information on its website, etc., before acquiring such information independently or from the property management companies and the like that manage SHR's portfolio assets. SHAM shall clearly state the purpose of use of personal information in advance in cases where it obtains such information from individuals stated in contracts and other documents (including records prepared electronically) signed with them or in cases where it gains such information directly from the concerned individuals by means that include documents and electronic communication methods.
However, indication of the purposes of use may be omitted if they are clearly understood from the circumstances in which such information is provided, or if such omission is permitted by laws and regulations.
Additionally, SHAM may receive personally referable information from a third party and acquire such information as personal data. In such a case, the consent of the individual, in principle, shall be obtained in writing, etc.
2.Collection of Sensitive Information
SHAM shall not collect sensitive information unless relevant laws, regulations, guidelines and the like permit otherwise.
3.Collection of Individual Numbers
Notwithstanding the provisions of “1. Purpose of Use of Personal Information” above, SHAM may request the concerned individuals or other persons in charge of work related to individual numbers only in cases where such numbers are necessary for processing work stipulated in Section 2-2 above.
Requests for individual numbers shall be made when necessity for conducting such work arises or when arising of such is anticipated.
4.Identity Confirmation
Upon receiving individual numbers, identity confirmation shall be carried out through methods stipulated under Article 16 of the Number Use Act. In case of receipt from a proxy, the identity of the proxy, the right of representation and the individual number of the person in question shall be confirmed through methods stipulated under the said article.
Provision to Third Parties
1.Provision of Personal Data to Third Parties
SHAM shall not provide personal data to any third party without obtaining consent from the concerned individual in advance, except in cases stated in each of the items in Paragraph 1, Article 27 of the Personal Information Protection Act.
2.Provision of Personally Referable Information to Third Parties
SHAM shall not provide personally referable information to any third party without confirming that the consent from the individual has been obtained in advance, as stated in Article 31, Paragraph 1 of the Personal Information Protection Act.
3.Provision of Sensitive Information to Third Parties
Notwithstanding the provisions of “1. Provision of Personal Data to Third Parties” above, SHAM shall not provide sensitive information to any third party unless relevant laws, regulations, guidelines and the like permit otherwise.
4.Provision of Specific Personal Information to Third Parties
Notwithstanding the provisions of “1. Provision of Personal Data to Third Parties” above, SHAM shall not provide specific personal information to any third party except in cases stipulated in each of the items in Article 19 of the Number Use Act.
5.Provision of Personal Data and Personally Referable Information to Third Parties Located in a Foreign Country
When providing personal data and personally referable information to a third party in a foreign country, SHAM shall comply with the obligations stipulated by relevant laws and regulations, guidelines, etc.
Pseudonymously Processed Information and Anonymously Processed Information
When handling pseudonymously processed information or anonymously processed information, SHAM shall comply with the obligations stipulated by relevant laws and regulations, guidelines, etc.
Securing of Accuracy, etc.
SHAM shall keep personal data accurate and up to date within the scope necessary for achieving the purpose of use of such data, and try to delete such data without delay when its use becomes unnecessary.
Security Management of Personal Information
SHAM shall manage personal data properly and safety, and take appropriate and necessary measures (It includes necessary and appropriate measures to prevent leakage, etc. of personal information that SHAM has obtained or attempts to obtain and that SHAM plans to handle as personal data. The same applies hereinafter.) for preventing problems, such as unauthorized access to personal data by external parties, the abuse of personal data, the loss thereof, the destruction thereof, the falsification thereof, and the leakage thereof.
- （1）In order to ensure the proper handling of personal data, SHAM shall formulate and comply with the "Personal Information Management Regulations" and the "Personal Information Protection Management Rules".
- （2）SHAM shall formulate and comply with the rules for the handling of personal data for each stage including acquisition, use, transfer, storage and deletion, with respect to the handling methods, persons in charge, and their duties.
- （3）SHAM shall appoint a person in charge of the handling of personal data and regularly inspect and audit the status of the handling of personal data. In addition, SHAM will report the results to the person in charge, and establish a system in which they can evaluate, review, and improve safety control measures the secure management of personal information.
- （4）A confidentiality agreement will be concluded with all employees, and safety control measures for the secure management of personal information will be thoroughly disseminated for their education and training.
- （5）In areas where personal data is handled, SHAM shall manage the entry and exit of employees and implement measures to prevent theft, etc.
- （6）Information systems that handle personal data shall be equipped with an identity verification function and access privileges will be set as necessary, in addition to the introduction of a mechanism to protect against unauthorized access or software from the outside.
- （7）When handling personal data in a foreign country, SHAM shall implement the necessary security control measures after understanding the system for the protection of personal information in the country or region where the personal data is to be handled.
Outsourcing of Handling of Personal Data
SHAM may outsource the handling of personal data in its possession to external business operators. By outsourcing the handling thereof in whole or in part, SHAM shall carefully select outsourcees and conclude outsourcing contracts with them on the condition that they have properly built a management system for protecting personal data and are operating such system. Moreover, SHAM shall provide the required and appropriate supervision to the outsourcees in order to ensure sure that personal data is managed safely.
Ongoing Improvements
SHAM shall establish internal regulations on personal information and the like, including this Privacy Policy. At the same time, SHAM shall seek to improve the regulations and other areas by reviewing them continuously. SHAM may revise this Privacy Policy as needed in response to developments, including amendments to laws and regulations.
Responses to Requests for Disclosure, etc.
The following contact office shall be available for requesting SHAM to notify the purpose of use of supplied personal data, to disclose, correct, add or delete such data, to suspend the use or the provision thereof to any third party or to erase such data. The contact office shall respond to the requests described above within a reasonable time frame after confirming the identity of the individuals who made the requests. (The office shall respond to the requests within a reasonable time frame after confirming the identity of a proxy in cases where such party contacted the office on behalf of the requesting individuals.)
For details on procedures concerning disclosure of personal data or for inquiries regarding this Privacy Policy, please contact us at the following:
Please contact the office stated below for all inquiries regarding this Privacy Policy.
Contact office
| Name | General Affairs Department Sekisui House Asset Management, Ltd. |
|---|---|
| Address | 4-15-1 Akasaka, Minato-ku, Tokyo, Japan Zip Code:107-0052 |
| Phone | +81-3-6447-4870 (main) |
| Hours of Operation | 9:00 a.m. – 6:00 p.m. (excluding Saturdays, Sundays, public holidays and year-end and new year holidays) |
SHAM is a business operator that falls under a business category covered by an authorized personal information protection organization. The following contact office shall also be available for complaints, consultations and the like regarding personal information.
Authorized personal information protection organization
| Name | Investors Counseling Office, the Investment Trusts Association Japan |
|---|---|
| Phone | +81-3-5614-8440 |
| Hours of Operation | 9:00 a.m. – 11:30 a.m. and 12:30 p.m. – 5:00 p.m. (excluding Saturdays, Sundays and public holidays) |