Privacy Policy
Nippon Hotel & Residential Investment Corporation (the "Investment Corporation") has established this Privacy Policy (this "Policy") to ensure the proper management, use and protection of personal information.
1. Purpose
The Investment Corporation recognizes the importance of personal information (including specific personal information defined under the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the "Number Use Act"), and shall handle personal information in accordance with the Act on the Protection of Personal Information (the "Personal Information Protection Act") and other relevant laws and guidelines, use personal information only for the purposes of use thereof, and respond to complaints properly to ensure the proper management, use and protection of personal information.
2. Basic Policy
With the understanding that personal information is an important information asset and in the awareness that the proper obtaining, management and use of obtained personal information to the extent necessary for the business is not only a legal requirement but also the Investment Corporation's social responsibility, the Investment Corporation shall comply with the following basic policy:
| （1） | The Investment Corporation shall obtain personal information in a lawful and proper manner to the extent necessary for the business as prescribed by the Investment Corporation, and shall not obtain personal information by fraud or other wrongful means. |
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| （2） | The Investment Corporation shall not acquire personal information by a method that will or may encourage or induce an illegal or unjust act. |
| （3） | The Investment Corporation shall strive to maintain and keep obtained personal information accurate and current at all times. The Investment Corporation shall take necessary and appropriate measures to develop the information security management system to prevent unauthorized access to, leakage, loss, destruction or alteration of personal information. |
| （4） | The Investment Corporation shall not use obtained personal information beyond the scope of the purposes of use prescribed by it without prior consent of the relevant individual or unless permitted by law or regulation. The Investment Corporation shall use obtained personal information to the minimum necessary extent in accordance with the purposes of use. |
3. Purposes of Use
Except for exceptional cases where the Investment Corporation has obtained prior consent of the relevant individual or where it is permitted by law or regulation, the Investment Corporation shall handle personal information only to the extent necessary to achieve the following purposes of use:
| （1） | For the Investment Corporation's unitholders (the "Unitholders") to exercise their rights or for the Investment Corporation to perform its obligations to the Unitholders under the Act on Investment Trusts and Investment Corporations (the "Investment Trust Act") and other relevant laws and regulations, such as sending asset management reports, convocation notices of general meetings of unitholders or dividend payment notices to the Unitholders. |
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| （2） | To prepare various data and manage information related to the Unitholders under the Investment Trust Act and other relevant laws and regulations, such as preparation of the Unitholders' Registry for the purpose of informing them of convocation of the Investment Corporation's results briefing and investment performance briefing. |
| （3） | To deal with the preparation and submission of various statements, reports or the like of the Investment Corporation or its Asset Manager, APA Investment Management Co., Ltd. (the "Asset Manager") under the Investment Trust Act and other related laws and regulations. |
| （4） | To carry out acquisition, brokerage, sale, transfer, lease or real estate management of any of the assets under management on behalf of the Investment Corporation, or other asset management activities under the Investment Trust Act (including funding activities conducted as part of asset management) or various business activities such as information collection, research and analysis and review relating to any of the aforementioned activities. |
| （5） | To carry out business activities related to the issuance of the Investment Corporation's investment units, investment corporate bonds and new unit acquisition rights as well as borrowing and other financing activities; |
| （6） | To carry out business activities such as the Investment Corporation's IR activities or general clerical work. |
| （7） | To respond to inquiries or requests for materials to the Investment Corporation. |
| （8） | To carry out business activities incidental or related to any of (1) to (7) above. |
| （9） | To seek advice from or retain a lawyer, public certified accountant, tax accountant, real estate appraiser, judicial scrivener or other external professional to achieve any of the purposes (1) to (8) above. |
4. Procedures for Notice or Announcement of Purposes of Use of Personal Information
| 1. | Except where the purposes of use are published in advance, the Investment Corporation shall explicitly notify the relevant individuals of the purposes of use described in the preceding Article by promptly displaying or keeping the document describing them at its offices, posting them on the Investment Corporation's website or giving notice in writing or by post or email. |
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| 2. | In the event of any change to the purposes of use of personal information, the Investment Corporation shall notify the relevant individuals of or publish the changed purposes of use. |
5. Obtaining of Personal Information and Social Security and Tax Numbers
| 1. | The Investment Corporation shall obtain personal information in a lawful and proper manner only to the extent necessary to achieve the purposes of use. |
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| 2. | The Investment Corporation shall not obtain personal information by fraud or other wrongful means, or has not obtained personal information from a third party who engages in unlawful conduct such as unlawful obtaining of personal information, with knowledge that the information it obtains is leaked personal information. |
| 3. | The Investment Corporation shall explicitly indicate the purposes of use described in Article 3 to the relevant individuals in advance if the Investment Corporation obtains personal information included in the agreement, contract or other documents directly from the relevant individuals. However, this may be omitted if the purposes of use are obvious from the circumstances at the time such personal information is obtained or if permitted by law. |
6. Provision of Personal Information to Third Parties
| 1. | The Investment Corporation shall not provide personal information to any third party without prior consent of the relevant individuals except as the cases described in the following items: | ||||||||||
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7. Outsourcing and Supervision of Contractors
If the Investment Corporation outsources handling of all or part of obtained personal information to a service provider, the Investment Corporation shall take appropriate measures to protect personal information under applicable law or regulation, and supervise the contractor as necessary and appropriate to ensure the secure management of the personal information.
8. Notice of Purposes, Disclosure, Correction, Suspension, Suspension of disclosure to third parties, etc., of Use of Personal Information
| 1. | The Investment Corporation shall strive to keep retained personal information accurate and current to the extent necessary to achieve the purposes of use. If the Investment Corporation receives requests from the relevant individuals regarding retained personal information, it shall, after verifying the identity of the relevant individual or his/her agent, respond to the request by giving notice of purposes, disclosing, correcting, suspending or suspending of disclosure to third parties use of personal information under applicable law and relevant rules. The same shall apply to disclosure of the record of provision to third parties in conjunction with the transfer of personal data. |
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| 2. | The Investment Corporation may charge the relevant individuals a fixed fee for requesting notice of purposes, disclosure, correction or suspension of use of retained personal information. |
9. Continuous Improvements
In response to amendments to laws and regulations or increased or changing social demand, the Investment Corporation shall amend this Policy from time to time and strive to improve the management system for and security of personal information.
10. Contact for Inquiries about Handling of Personal Information
For comments, inquiries and complaints regarding the Investment Corporation's handling of personal information, please contact the following:
| Trade name | Planning and Administration Department, APA Investment Management Co., Ltd. |
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| Tel. | +81-3-6262-5200 |
| Address | 3-3-4 Nihonbashi-Honcho, Chuo-ku, Tokyo 103-0023, Japan |
| Office Hours | 9:00 a.m. to 6:00 p.m. (excluding Saturdays, Sundays, public holidays and other holidays designated by the Asset Manager) |
For inquiries regarding matters recorded in the Unitholders' Registry, please contact Sumitomo Mitsui Trust Holdings, Inc., which acts as Administrator, using the following details:
| Trade name | Stock Transfer Agency Business Planning Dept., Sumitomo Mitsui Trust Holdings, Inc. |
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| Tel. | 0120-782-031 (toll free in Japan only) |
| Address | 2-8-4 Izumi, Suginami-ku, Tokyo 168-0063, Japan |
| Office Hours | 9:00 a.m. to 5:00 p.m. (excluding Saturdays, Sundays, public holidays and other holidays designated by the Administrator) |