Takara Leben Real Estate Investment Corporation (TLR), in recognition of the importance of specific personal information and individual numbers (hereinafter collectively “specific personal information, etc.”) as defined in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter the “My Number Act”), protects specific personal information, etc. with responsibility by promoting the following initiatives for the careful handling of specific personal information, etc.

1. Policies

Recognizing appropriate protection and use of specific personal information, etc. as an important social responsibility, TLR shall strive for proper handling, management and protection of specific personal information, etc. in compliance with the My Number Act, the Act on the Protection of Personal Information and other laws, regulations, the Guideline for Appropriate Handling of Specific Personal Information (for Business Operators), and other guidelines, etc. when TLR carries out business operations of any kind. In addition, TLR shall take appropriate measures with regard to complaints concerning the handling of specific personal information, etc. has been filed.

2. Purposes of Use

TLR shall use specific personal information, etc. it acquires for purposes within the following scope of administrative operations related to individual numbers.

1. Individual number-related administrative operations (including those related to the following administrative operations) related to corporate officers (including dependents of corporate officers)
   Withholding tax-related operations conducted by an employer in accordance with the Income Tax Act, individual residence tax-related operations conducted by an employer in accordance with the Local Tax Act, employment insurance-related operations conducted by an employer in accordance with the Employment Insurance Act, health insurance-related operations conducted by an employer in accordance with the Health Insurance Act (application-related and payment-related), and employees’ pension insurance-related operations conducted by an employer in accordance with the Employees' Pension Insurance Act (application-related)
2. Individual number-related administrative operations (including those related to the following administrative operations) related to individuals other than corporate officers
   Payment report preparation operations for remuneration and fees, etc. in accordance with the Income Tax Act, payment report preparation operations for dividend of surplus, dividend of profit, distribution of surplus or interest on funds in accordance with the Income Tax Act, payment report preparation operations for usage fees, etc. for real estate in accordance with the Income Tax Act and payment report preparation operations for consideration for the transfer of real estate, etc. in accordance with the Income Tax Act

3. Acquisition of Specific Personal Information, Etc.

TLR may request the provision of an individual number from the relevant person or another person in charge of processes related to individual numbers or a person in charge of processes using individual numbers only in cases where it is necessary for conducting the operations set forth in the preceding paragraph. Furthermore, TLR shall not request the provision of specific personal information except in cases where it is allowed to receive provision of specific personal information in accordance with the My Number Act.

4. Proper Use

TLR shall not use specific personal information, etc. in any way that could assist or induce illegal or unjust activities.

5. Security Control Measures

TLR shall take organizational, personal, physical and technical safety management measures and ascertain the external environment to ensure preventative measures against leakage, loss, or damage of specific personal information, etc. and other necessary and appropriate measures to manage the specific personal information, etc. are in place. Furthermore, TLR shall exercise necessary and appropriate supervision of employees and contractors (including subcontractors) that handle specific personal information, etc. to ensure that specific personal information, etc. is securely managed. For details regarding TLR’s personal data safety management measures related to specific personal information, etc., please make inquiries to the contact listed below.

6. Reporting, Etc. of Leakage, Etc.

In the event of an incident such as leakage, loss, damage, or other incident related to ensuring the safety of specific personal information recorded in a specific personal information file handled by TLR that is deemed to have a significant risk of harming the rights and benefits of individuals as set forth in the Personal Information Protection Commission Rules, TLR shall report the incident to the Personal Information Protection Commission as stipulated in the Personal Information Protection Commission Rules.

Moreover, when applicable, TLR shall notify the person of the incident as stipulated in the Personal Information Protection Commission Rules. However, TLR may opt not to do so in cases where it is difficult to notify the person, subject to TLR taking alternative measures needed to protect the rights and benefits of the person.

7. Continual Review of Structure for Personal Information Protection

TLR shall continually review and improve this basic policy and other rules concerning the handling of specific personal information, etc. of TLR so as to ensure sustainably effective and proper management.

8. Requests, Etc. for Disclosure, Etc. of Retained Personal Data Pursuant to the Act on the Protection of Personal Information

Concerning the retained personal data related to specific personal information, etc. left in the hands of TLR, prompt response shall be taken pursuant to laws, regulations, etc. in cases where the person requests to be informed of the purposes of use of the retained personal data related to specific personal information, etc. or requests for disclosure, correction/addition/deletion of the contents, cessation of use, erasure or cessation of provision to any third party of the retained personal data related to specific personal information, etc. pursuant to the Act on the Protection of Personal Information (hereinafter, “requests, etc. for disclosure, etc.”). The procedures for requests, etc. for disclosure, etc. shall be subject to verification of the identity of the person. Please note that the procedures for requests, etc. for notification or disclosure of purpose of use incur fees prescribed by TLR.

[Contact for inquiries concerning personal data safety management measures related to specific personal information, etc. and handling of specific personal information, etc.]

information, etc. and handling of specific personal information, etc.] The contacts below are available to take questions about details of the measures taken by TLR to manage the safety of personal data related to specific personal information, etc., handling of specific personal information, etc. by TLR in general or the provided specific personal information, etc., inquiries concerning requests, etc. for disclosure, etc. of the retained personal data related to specific personal information, etc. in accordance with the Act on the Protection of Personal Information, or filing of complaints on the handling of specific personal information, etc.

・Contact for inquiries concerning specific personal information, etc. of unitholders

Stock Transfer Agency Business Planning Department, Sumitomo Mitsui Trust Bank, Limited
Address	2-8-4 Izumi, Suginami-ku, Tokyo
TEL	0120-782-031 (toll free in Japan only)
URL	http://www.smtb.jp/personal/agency/
Hours of operation	From 9:00 a.m. to 5:00 p.m. (Japan Standard Time) (excluding Saturdays, Sundays, national holidays and year-end through New Year holidays)

・Contact for other inquiries concerning specific personal information, etc.

Finance and Planning Department, MIRARTH Real Estate Advisory Inc.
Address	2-2-1 Otemachi, Chiyoda-ku, Tokyo
TEL	+81-3-6435-5264
Hours of operation	From 9:00 a.m. to 5:00 p.m. (Japan Standard Time) (excluding Saturdays, Sundays, national holidays and year-end through New Year holidays)

9. Name, address, and name of representative of business operator

Name	Takara Leben Real Estate Investment Corporation
Address	2-7-17 Hamamatsucho, Minato-ku, Tokyo
Name of representative	Tetsuo Saida, Executive Director

Supplementary Provisions

1. Establishment, revision and abolition of the basic policy shall be made by resolution of the board of directors

End

Established on April 5, 2018
Comprehensive revision in accordance with the amendment to the Act on the Protection of Personal Information, effective April 1, 2022
Change of company name of the Asset Manager on March 29, 2024
Change of Address on November 5, 2024