Takara Leben Real Estate Investment Corporation (TLR) protects personal information with responsibility by promoting the following initiatives for the careful handling of personal information in recognition of the importance of personal information. With regard to the individual numbers and specific personal information (each as defined in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures), TLR shall comply with the basic policy on proper handling of specific personal information, etc. established separately.

1. Policies

Recognizing appropriate protection and use of personal information as an important social responsibility, TLR shall strive for proper handling, management and protection of personal information in compliance with the Act on the Protection of Personal Information and other relevant laws, regulations, 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 personal information has been filed.

2. Proper Acquisition

In cases where TLR is to acquire personal information, the acquisition shall be by proper and legal means and also with the purposes of use specified, and shall be within the scope necessary to achieve those purposes of use. In addition, unless otherwise provided for in laws and regulations, TLR shall not acquire special care required personal information (as defined in the Act on the Protection of Personal Information; the same shall apply hereinafter) without obtaining the person’s consent in advance.

3. Purposes of Use

When TLR is to use personal information, personal information shall be used only within the scope of the purposes of use stated below under [Purposes of use of personal information] and, unless otherwise provided for in laws and regulations, not handled beyond the scope of those purposes of use without obtaining the person’s consent in advance.

4. Proper Use

TLR shall not use customers’ personal information in any way that could assist or induce illegal or unjust activities.

5. Restriction on Provision to Third Parties

Unless otherwise provided for in laws and regulations, TLR shall not provide personal data to any third party without obtaining the person’s consent in advance.

6. Acquisition, Etc. of Sensitive Information

Concerning personal information in the financial field, unless otherwise provided for in the Guidelines for Personal Information Protection in the Financial Field, TLR shall not acquire, use or provide to any third party any sensitive information (special care required personal information, and information concerning participation in union activities, family origin, registered domicile, healthcare and sex life (of these, excluding those falling under the category of special care required personal information), except those disclosed by parties set forth in the Act on the Protection of Personal Information or the Enforcement Rules for the Act on the Protection of Personal Information (hereinafter the “Personal Information Protection Act Enforcement Rules”), including the person, national government organs, local governments, and academic research institutions, or those seemingly clear from acquiring by visual observation, filming or photographing of the person).

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

Concerning the retained personal data 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 or requests for disclosure, correction/addition/deletion of the contents, cessation of use, erasure or cessation of provision to any third party, or disclosure of records of provision to a third party of the retained personal data 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.

8. Security Control Measures

TLR shall strive to strictly manage personal data on the person so as to keep it accurate and up to date and to erase the personal data without delay when use is no longer necessary. TLR shall take organizational, personal, physical and technical safety management measures and ascertain the external environment to ensure preventative measures and security countermeasures against leakage, loss, or damage and other necessary and appropriate measures to securely manage the personal data are in place.
For details regarding TLR’s personal data safety management measures, please make inquiries to the contact listed below.

9. 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 personal data 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 Act Enforcement Rules, TLR shall report the incident to the supervising authority as stipulated in the Personal Information Protection Act Enforcement Rules.
Moreover, when applicable, TLR shall notify the person of the incident as stipulated in the Personal Information Protection Act Enforcement 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.

10. Continual Review of Structure for Personal Information Protection

TLR shall continually review and improve the Policy and other rules concerning the handling of personal information of TLR so as to ensure sustainably effective and proper management.

[Purposes of use of personal information]

TLR shall use the acquired personal information in accordance with the following purposes of use:

1. For handling of exercise of unitholder rights and performance of the obligations of TLR pursuant to the Act on Investment Trusts and Investment Corporations, the Financial Instruments and Exchange Act and other relevant laws, regulations, etc. (hereinafter, the “Investment Trusts Act, etc.”)
2. For preparation, etc. of various written notifications and reports, the unitholder register, etc. pursuant to the Investment Trusts Act, etc. and other laws and regulations applicable to TLR
   
3. For business operations on asset acquisition, sale, leasing, maintenance, management, etc. and the survey analysis, collection of materials, various guides, marketing activities, etc. necessary for such business operations
   
4. For issuance of investment units and investment corporation bonds, debt financing and other fund procurement
   
5. For management of information on unitholders
   
6. For provision of the concerned unitholders’ transaction status, TLR’s business conditions and other various information to unitholders
   
7. For handling of various inquiries, requests for materials, etc. from unitholders and persons considering purchasing securities issued by TLR
   
8. For verification of the identity of unitholders or proxy of unitholders
   
9. For verification at the time of transaction, etc. of the parties stated on forms, contracts, etc. for the carrying out of business conducted by TLR
   
10. For appropriate and smooth carrying out of other business operations that TLR may be engaged in (including business operations permitted to handle in the future)
    
11. For carrying out of the business operations incidental or related to any of the business operations listed in ① through ⑩ above
    
12. For disclosure or provision of personal information to any third party within the scope necessary for the purposes of use listed in ① through ⑪ above

[Contact for inquiries concerning personal data safety management measures, disclosure, correction, cessation of use, etc. of personal information, and personal information]

The contacts below are available to take questions about details of the measures taken by TLR to manage the safety of personal data, handling of personal information by TLR in general or the provided personal information, inquiries concerning requests, etc. for disclosure, etc. of the retained personal data or filing of complaints on the handling of personal information.

・Contact for inquiries concerning unitholder register entries

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)

・ Contact for other inquiries concerning personal information

Finance and Planning Department, MIRARTH Real Estate Advisory Ltd.
Address:	1-14-15 Akasaka, Minato-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)

11. Name, address, and name of representative of personal information handling business operator

Name	Takara Leben Real Estate Investment Corporation
Address	1-14-15 Akasaka, Minato-ku, Tokyo
Name of representative	Tetsuo Saida, Executive Director

Supplementary Provisions

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

End

Established on April 5, 2018
Revised on April 1, 2022