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Privacy Policy

Kenedix, Inc. (hereafter, "the Company") and each entity of our corporate group (hereafter, "the Company's Group") believes the secure protection of customers' privacy and personal information (customers' Individual Number and personal information that contains the Individual Number (collectively, "Specific Personal Information")) is both a fundamental element of its business activities and an important social responsibility. The Company's Group has consequently established the Privacy Policy, set out below, to enable it to consistently fulfill this responsibility.
However, if a privacy policy is established individually by an entity of the Company's Group, the said policy shall prevail.

1. Basic policies

The Company's Group shall recognize the importance of personal information, use through strict compliance with applicable laws and regulations set by the Japanese government, ensure its appropriate handling as well as strive for its safe and secure management. Furthermore, we shall endeavor to improve our structure for protecting personal information on a continuous basis through timely reviews of the related framework.

2. Acquisition, use and provision of personal information

The Company's Group will acquire personal information by appropriate means and make a disclosure, notification or statement of the purposes of use. The Company's Group will not use any personal information for any purpose other than the purposes of use without the consent of the information owner. The Company's Group will follow the statutory procedures to provide or disclose personal information to third parties. The Company's Group will not provide Specific Personal Information to any third party except in cases clearly permitted under the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure.

3. Purposes of use of personal information

3-1 Personal information that the Company acquires, such as name, home address, date of birth, business address, annual income, phone numbers and e-mail address, etc.; his or her Individual Number is not included, will be used for the following purposes:

  1. Implementation of contracts and provision of information and services concerning acquisition, asset-management and disposition of real estate including beneficial interests in trust (collectively "real estate").
  2. Implementation of contracts and provision of information and services concerning transactions such as the sale, purchase, brokerage, leasing and property-management of real estate.
  3. Implementation of contracts and provision of information and services concerning transactions such as the sale, purchase, brokerage and management of loans.
  4. Implementation of contracts and provision of information and services concerning advisory operations for real estate or loans.
  5. Implementation of contracts and provision of information and services concerning due diligence operations (appraisal of real estate or loans).
  6. Management for the shareholders of the Company's Group.
  7. Management for the business partner of the Company's Group.
  8. Management for the officers, employees, contracted staff of the Company's Group.
  9. Invitation and selection of officers and employees to be appointed or hired by the Company's Group.
  10. Communication by documents, postal matter, telephone, facsimile, electronic mail and so on within the scope necessary to achieve the purposes described above.
  11. Provision of personal information to third parties within the scope necessary to achieve the purposes described in 1 to 5 above.

3-2 Specific Personal Information (including Individual Number) that the Company collects will be used for the following purposes:

  1. Affairs related to the Individual Number (including relevant tasks listed below) for employees and officers (including dependents) of the Company
    • (a) Tasks related to withholding tax, preparation of salary payment report, and preparation of salaried employees' transfer notification forms in relation to salary payment special tax collection, etc.
    • (b) Preparation of application for (change in) dependent deduction, application for deduction of insurance premium & salaried employees' special exemption for spouse, and preparation of application for change to special tax collection, etc.
    • (c) Preparation of payment report for a person receiving retirement allowance, etc. and preparation of application relating to retirement income, etc.
    • (d) Notification related to health insurance, employee pension and corporate pension, application and claim for health insurance, employee pension and corporate pension, and notification of category III of national pension, etc.
    • (e) Notification, application and claim for employment insurance, etc.
    • (f) Preparation and provision of statutory documents pertaining to financial instruments exchange related to stock option systems, etc.
  2. Affairs related to Individual Number for individuals who are not employees and officers of the Company (including relevant tasks listed below):
    • (a) Preparation of payment report on remuneration/fee, etc.
    • (b) Preparation of distribution report on dividend and surplus, and payment report on interest from funds, etc.
    • (c) Preparation of payment report on real estate usage fees, etc.
    • (d) Preparation of payment report on remuneration for acquisition of real estate, etc.

4. Providing personal information to third parties

Apart from the case of providing personal information pursuant to statutory provisions, necessary items such as real estate information, name and address of an information owner or his or her family from among personal information (excluding Individual Number) collected by the Company may be provided to third parties to the extent necessary to attain the purpose of use, as well as by means of written documents, postal matter, telephone, facsimile, electronic mail, advertising media and similar.
This provision of information will be discontinued at the request of the information owner. However, this shall not apply to any personal information that the Company has collected with the individual consent of the information owner to the provision of that personal information to third parties.

[Examples of third parties to which personal information may be provided] *Listed below are some examples. Note, however, that third parties shall not be limited to those listed below.

  1. Parties with which the Company has entered into or may enter into contracts or transactions.
  2. Other Second Financial Instruments Business agencies or real estate agencies.
  3. Operators and organizations engaged in online or other advertising.
  4. Designated distribution organizations (registration of properties, notification of contract conclusion, business activities using data owned by the organizations, price appraisal, etc.)
  5. Judicial scriveners and land and house investigators involved in property registration.
  6. Financial institutions, Financial instruments firms, money-lenders involved in financing.
  7. Management operators, financial institutions administering the bank accounts to which payments are transferred, officials of the management association, etc. in connection with real estate management.
  8. Attorneys (including registered foreign lawyer), certified public accountants, licensed tax accountants, real estate appraisers and public consultant on social and labor insurance and so on offering expert advice and services.
  9. Credit information organizations, real estate research institutions, etc.
  10. Government, local public agency, or a private sector to whom the government or local public agency entrusted their work.
  11. Business partners of member companies in the Company's Group

5. Joint use of personal information

In the event of inviting applications for employment and appointment as officers in the Company's Group, personal information (excluding Individual Number) obtained by the Company will be jointly used.

  1. Items of personal information subject to joint use: Personal information concerning a person and his or her family, such as name and address, obtained at the time of inviting applications for employment or appointment as officers in the Company's Group
  2. Eligible joint users: Subsidiaries and affiliated companies in the Company's Group
  3. Purpose of use: Selection of officers and employees to be appointment or hired by the Company's Group
  4. Responsible administrator: Kenedix, Inc.

6. Actions for safety control of personal information

The Company's Group will take the necessary and appropriate actions to ensure the proper and careful control of personal information owned by the Company's Group and to protect personal information from unauthorized access, loss, falsification, leakage and suchlike.

7. Outsourced handling of personal information

The Company's Group may contract with an external service provider to handle personal information owned by the Company's Group. In this event, the Company's Group will choose a service provider that takes appropriate measures to protect personal information and will exercise the necessary and appropriate supervision.

8. Procedures for disclosure, correction, etc. of personal information

The Company will immediately respond to any request received from any information owner for the disclosure, correction, discontinuation of use or similar of that information owner's personal information owned by the Company's Group. The response will follow procedures defined separately.

9. Inquiries about personal information

Please address any inquiries, comments and requests concerning the Company's handling of personal information to the following:

Contact for inquiries Compliance Division Kenedix, Inc.
Address KDX Nihonbashi Kabutocho Building, 6-5 Nihombashi Kabutocho, Chuo-ku, Tokyo
103-0026
Phone 03-5623-8400 (opening hours : weekdays10 a.m.-5 p.m.)

The Company is a member of the Japan Investment Advisers Association, which is an authorized personal information protection organization. The Association receives complaints and provides consultations concerning the handling of personal information by its members.

Contact for inquiries Complaint and Consultation Office of the Japan Investment
Advisers Association (in charge of personal information)
Address Tokyo Shoken Kaikan 7th floor, 1-5-8 Nihonbashi Kayabacho, Chuo-ku, Tokyo
103-0025
Phone 03-3663-0505 (Opening hours : Monday through Friday (excluding national holidays), 9 a.m.-5 p.m.)

10. Revisions of this policy

The Company will, from time to time, review and revise this policy in order to comply with related laws and regulations and improve the processes of protecting personal information.