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Privacy Policy

Privacy Policy

SIA REIT, Inc. (hereafter referred to as “SIA REIT”) has formulated and published the following “Privacy Policy” (hereafter referred to as the “Policy”) as its engagement policy concerning protection of personal information and philosophy concerning handling of personal information.

1. Engagement Policy

Recognizing appropriate protection and use of personal information as an important social responsibility, SIA REIT strives to appropriately protect and use personal information of the data subject (the person) by complying with various rules of SIA REIT including the Policy together with the “Act on the Protection of Personal Information” (Act No. 57 of 2003) and other related laws and regulations, etc.

2. Appropriate Obtainment

SIA REIT obtains personal information of the data subject (the person) within the scope necessary to perform tasks by using lawful and appropriate means.

3. Purposes of Use

SIA REIT determines the purposes of use of personal information of the data subject (the person) and handles the information within the scope necessary to achieve the purposes of use, and does not use personal information beyond that scope.
For the purposes of use concerning handling of personal information of the data subject (the person), please refer to SIA REIT’s website (http://www.sia-reit.com/en/).

4. Restrictions on Provision of Personal Data to Third Parties

As a principle, SIA REIT does not provide personal information of the data subject (the person) to a third party excluding cases when the prior consent of the data subject (the person) has been gained, when required by laws and regulations, etc. However, in case of entrusting handling of personal information within the scope necessary to achieve the purposes of use, merger, etc. and in case of using jointly with the specified parties prescribed in Item 5, SIA REIT may provide personal information of the data subject (the person) to the parties other than SIA REIT without obtaining consent of the data subject (the person).
Furthermore, regardless of the above, SIA REIT may provide personal information to third parties in cases as described below. SIA REIT will cease the concerned provision if requested by the data subject (the person), so please ask “Finance & Administration Division (Tel: +81-3-3242-7153)” of Simplex REIT Partners Inc. (This is the asset management company to which SIA REIT entrusts the management of its assets.)

(1) Third Parties to which Personal Information are Provided
1) Counterparties of contracts for transactions of real estate, etc. and other related parties (including parties expected to be such)
2) Financial Instruments Business Operator and Building Lots and Buildings Transaction Business Operator
3) Financial institutions, non-life insurance companies, non-life insurance agencies, lawyers, certified public accountants, tax accountants, judicial scriveners, land and building investigators, property managers, real estate appraisers, real estate investigation firms, etc. involved in the asset management tasks conducted by Simplex REIT Partners Inc.
4) Companies that provide software or services related to operation and management of real estate, etc.
(2) Components of Personal Information to be Provided
Names, addresses, telephone numbers, e-mail addresses, items indicated in rent-roll (list of lease conditions) and other components that fall within the scope necessary to achieve the purposes of use mentioned above
(3) Means or Method of Provision
Delivery through paper, electric or other media

5. Joint Use within the Group

SIA REIT may, limited to when necessary within the scope below, jointly use personal data it possesses among following joint users.

(1) Components of Personal Data to be Jointly Used
1) The data subject's (the person's) names, birth dates, addresses, telephone numbers, e-mail addresses and other contact information, information regarding family members, information regarding place of employment, information regarding assets and liabilities, information regarding transaction needs and publicly available information
2) Types of respective instrument, service, etc. under transaction, contracted date, transacted amount, balance, due date and other information regarding contents of respective transaction
3) Management numbers such as transaction numbers, transaction history information, information regarding transaction judgement and other information necessary for management of transactions
(2) Scope of Joint Users
Mizuho Financial Group, Inc. and its consolidated subsidiaries indicated in the Securities Report, etc. and its affiliated companies accounted for by the equity-method (in case joint use is restricted by the Financial Instruments and Exchange Act and other relevant laws and regulations, handling what should be compliant with such laws and regulations, etc.)
(3) Purposes of Joint Use
1) To make proposals and give guidance on various instruments, services, etc. and for research and development
2) To make judgement when providing various instruments, services, etc.
3) To appropriately implement business management tasks as a group, including understanding and managing various risks
(4) Responsible Party for the Management
Simplex REIT Partners Inc.

6. Handling of Sensitive Information

SIA REIT will not acquire, use and provide to any third party sensitive information (information regarding political views, religion, participation in labor union, race, ethnic group, family origin, legal address on family registry, medical information, etc.) of the data subject (the person) unless authorized by laws and regulations, etc. or except when obtaining consent of the data subject (the person) within the scope necessary to conduct business, etc.

7. Security Measures / Safeguards

SIA REIT takes the necessary and appropriate security measures/safeguards to prevent the leakage, etc., of personal information of the data subject (the person) as well as attempting to store and manage the personal information at accurate and up–to–date status. Moreover, it conducts necessary and appropriate supervision of employees and service providers (including subcontractors, etc.) of who handle personal information of the data subject (the person).

8. Continuous Improvement

SIA REIT reviews the Policy in a timely manner according to the development of information technologies, the changes in social demand, etc. and strives to continuously improve the handling of personal information of the data subject (the person).

9. Procedures to Request Disclosure, etc.

SIA REIT strives to conduct appropriate and prompt responses regarding request to notify purposes of use of personal data it possesses concerning the data subject (the person), request to disclose the contents, requests to correct/add/delete in case the contents of personal data it possess differ from the fact, etc., request to cease of use/erase/cease of provision to a third party, etc.
Please direct requests for the disclosure, etc., of personal information regarding the data subject (the person) SIA REIT possesses to the “Finance & Administration Division (Tel: +81-3-3242-7153)” of Simplex REIT Partners Inc.

10. Comments & Requests

SIA REIT strives to deal with comments and requests for the handling of personal information sincerely and promptly.
Please direct comments and requests concerning SIA REIT’s handling of personal information to the “Finance & Administration Division (Tel: +81-3-3242-7153)” of Simplex REIT Partners Inc.
Opening hours 9:00 a.m. -5:30 p.m. (Closed Saturdays, Sundays, holidays, and company holidays)

Simplex REIT Partners, Inc. is a member of the Investment Trusts Association, Japan (JITA; http://www.toushin.or.jp/english/), a certified personal information protection organization. The JITA also accepts inquiries, complaints, etc. concerning the handling of personal information by its members at its Investor Consultation Office.

Investment Trusts Association, Japan
Investor Consultation Office
Tel: +81-3-5614-8440
Opening hours 9:00 a.m. -11:30 a.m. and 0:30 p.m. -5:00 p.m. (Closed Saturdays, Sundays, holidays, and company holidays)

11. Revision of the Policy

Contents of the Policy will be applied from the date it is posted on its website. Furthermore, the Policy may be revised without prior notice in case requested by laws and regulations, etc. or when SIA REIT believes such is necessary.

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