Mitsui Fudosan Frontier REIT Management Inc. (hereinafter "MFF") shall comply with all applicable laws and regulations, including the Act on the Protection of Personal Information, and shall endeavor to carefully handle the personal information acquired in the course of its asset management business on behalf of Frontier Real Estate Investment Corporation (hereinafter "FRI") in accordance with the following policy:
1. Basic Policy Concerning the Handling of Personal Information
MFF regards personal information as a vital business asset and the proper handling of personal information not only as a legal requirement but also as a social responsibility to customers, clients and society as a whole. In this light, MFF takes the initiative in protecting personal information in line with the following basic framework:
- MFF shall not acquire any personal information by wrongful means;
- MFF shall only acquire personal information which is necessary in the course of its business operations;
- MFF shall not use any personal information or provide it to any other third party beyond the scope of the purposes stated in the following section headed "Purpose of Using Personal Information" (hereinafter "Purpose of Use"), except as otherwise required by laws and regulations;
- MFF shall endeavor to maintain retained the personal data as accurate and up-to-date as possible, and to delete personal data that is no longer necessary and take strict security and control measures in order to prevent possible loss, misuse, alteration or any other security violation of personal information, within the scope deemed necessary to achieve the Purpose of Use;
- MFF shall continue to monitor the methods for acquiring and maintaining personal information, and from time to time review the protection measures of personal information when necessary.
2. Purpose of Using Personal Information
MFF shall use the personal information and retained personal data only in the couse of its asset management business and other ancillary or related business and within the scope of the Purpose of Use stated below, except as otherwise required by laws:
- To allow unitholders to exercise their rights, and to carry out FRI's obligations in accordance with the regulations of the Act on Investment Trusts and Investment Corporations (hereinafter the "Investment Fund Act") and other applicable laws and regulations;
- To maintain the information related to unitholders;
- To assist FRI in issuing investment units and corporate bonds;
- To perform business activities including confirmation of and correspondences to the inquiries and requests for information material from the unitholders as well as from prospective purchasers of investment units and corporate bonds issued or to be issued by FRI;
- To conduct research, analysis and inspection related to MFF's asset management services outsourced by FRI;
- To perform business activities related to acquisition, transfer and borrowing/lending of property, and outsourcing of property management services on behalf of FRI;
- To perform business activities related to the IR activities and general administrative services outsourced to MFF; and
- To perform any other business activities ancillary to or related to the activities stated in a. through g. above.
3. Acquisition of Personal Information
MFF shall acquire personal information only within the scope deemed necessary to achieve the Purpose of Use and by appropriate means. MFF shall not acquire sensitive information without the consent of the individual except in cases designated by the Act on the Protection of Personal Information and related guidelines.
- When acquiring the personal information in writing directly from an individual, MFF shall clearly state the Purpose of Use to the individual in advance; and
- When acquiring the personal information in a way other than a. above, MFF shall notify or disclose the Purpose of Use to the individual in a prompt and appropriate manner, except in cases where MFF has already disclosed the Purpose of Use in advance.
However, the paragraphs a. and b. above do not apply to the cases where any other treatment is permitted under the laws and regulations (including the Act on the Protection of Personal Information).
4. Provision and Disclosure of Personal Data to Third Parties
MFF shall not provide or disclose any retained personal data to any other third party, except in cases where:
- The individual gives prior written consent;
- MFF provides or discloses the personal information or retained personal data, as statistics or similar to them, on an anonymous basis;
- MFF is equired to provide or disclose the personal information or retained personal data by laws and regulations;
- It is necessary to provide or disclose the personal information or retained personal data for the purposes of protecting life, body, and property of persons, and it is difficult to obtain the individual's consent;
- It is particularly necessary for the purposes of improving public health or promoting the sound growth of children, and it is difficult to obtain the individual's consent;
- It is necessary to cooperate with a state body or local government or its delegate which performs the affairs stipulated by laws and regulations, and obtaining the individual's consent is likely to impede the performance of the affairs; or
- It is otherwise required by laws and regulations (including the Act on the Protection of Personal Information).
5. Disclosure, Alteration and Termination of Use of Retained Personal Data
When MFF receives a request from an individual regarding retained personal data, upon confirmation of the identity of the individual, or the identity of his/her agent, MFF shall take appropriate actions with respect to the disclosure (hereinafter, the "Disclosure"), alteration/addition/removal (hereinafter, the "Alteration"), and/or termination of use/deletion (hereinafter, the "Termination of Use") of such personal data, in accordance with the applicable laws and regulations. For details, please see Contact Information in Section 7 below.
6. Measures for Security and Control
MFF takes strict security and control measures in order to protect the retained personal data from loss, misuse, alteration or any other security violation in accordance with the guidelines regarding the protection of personal information as set forth by the Investment Trust Association, Japan.
7. Contact Information
For inquiries or complaints regarding personal information, requests for the Disclosure, Alteration and/or Termination of Use of retained personal data, or for any other inquiries, please contact:
- Mitsui Fudosan Frontier REIT Management Inc., Planning and Administration Division
In addition, MFF is a Full-Member of the Investment Trust Association, Japan, an authorized personal information protection organization. The Association accepts inquiries/complaints regarding its Full-Members’ handling of personal information:
- Investment Trusts Association, Japan, Investors Inquiries Division
MFF shall continue to review and improve the system, rules and regulations, measures for security and control and other programs regarding the protection of personal information when necessary.
Enacted: April 1, 2005
Last Revised: May 30, 2017