Tokyo Tatemono Investment Advisors

I. Basic Policies

In view of the importance of protecting personal information in the digital society, Tokyo Tatemono Investment Advisors Co., Ltd. (hereinafter referred to as "we," "us" and "our") complies with the Act on the Protection of Personal Information and other related laws and regulations, and is committed to protecting personal information based on the following policy (hereinafter referred to as "this Policy").
We are also committed to protecting individual numbers and specific personal information prescribed in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures in accordance with the separately formulated Basic Policy on the Appropriate Handling of Specific Personal Information and other arrangements as well.

1. Our Name, Location and Representative Tokyo Tatemono Investment Advisors Co., Ltd.
   Mainichi Nihombashi Bldg. 7F 2-5 Nihonbashi 3-chome Chuo-ku, Tokyo 103-0027
   President and Representative Director
   Kazuki Sugise
2. Formulate and continuously improve rules, etc. for handling personal information We remind executives and employees of the importance of privacy protection, formulating rules, etc. (including this policy, rules for handling personal information, and other rules and manuals) to handle personal information appropriately, and continuously improve their content.
3. Handle personal information appropriately following the rules, etc. Following the rules for handling personal information and other rules and manuals, we establish a management system with consideration for the service and scale of each department, obtain, use, and provide personal information appropriately as well as properly respond to requests from the information subject (principal) such as disclosure or correction of personal information.
4. Ensure accuracy and safety of personal information We make efforts to keep personal information accurate and up to date to ensure the accuracy and safety of personal information, and take appropriate safety control measures in systematic, personnel, and technical ways to prevent leakage, loss of, or damage to personal information.
5. Purposes of Use of Personal Information We make proper use of personal information within the scope necessary for the fulfillment of the purposes of use prescribed in II. Handling of Personal Information set out below. In the case where we give a notice to the principal or clearly state purposes of use that differ from those set out below at the time of acquiring personal information, the purposes of use mentioned above will take precedence to those set out below.
6. Commissioning We may commission a third party to handle personal information within the scope necessary to fulfill the purposes of use. In this event, we will implement necessary and appropriate supervision over the commissioned third party in accordance with laws and regulations.
7. Disclosure, Correction and Other Treatment When the principal requests disclosure, correction, suspension of use or other treatment of personal information we own, we will swiftly respond in compliance with laws and regulations after verifying their identity.
8. Contact for Inquiries The contact for inquiries specified in II. Handling of Personal Information below will deal with inquiries about our handling of personal information.
9. Revision of the Policies In the event of revising this Policy for complying with laws and regulations and for enhancing protection of personal information, we publish details of the revision on our website.

II. Handling of Personal Information

1. Purposes of Use of Personal Information We make proper use of personal information we have acquired within the scope necessary to operation of our businesses as set out below. In the case where we give a notice to the principal or clearly state purposes of use that differ from those set out below at the time of acquiring personal information, the purposes of use mentioned above will take precedence to those set out below.
   1. Our businesses We engage in the businesses specified below.
      (i) Real estate trading, leasing and management
      (ii) Real estate investment advisory services
      (iii) Financial instruments services (Type II financial instruments, investment advisory and agency, and investment management services)
      (iv) Consulting on investment in real estate, real estate trust beneficiary interests and suchlike
      (v) Services incidental or related to the businesses mentioned above
   2. Purposes of use (i) Analysis of customer trends and research and analysis for product development and others
      (ii) Determination of stakeholders necessary to business operation and various notices associated with business operation (*)
      (iii) Identification and credit check regarding applications, contract conclusions and suchlike in business operation
      (iv) Various notices associated with sales activities, implementation of applications and contracts, surveys on customer satisfaction and others (*)
      (v) Public relations activities including provision of company information (*) and notices of events, surveys and others (*)
      (vi) Verification of visitors, customers and business partners and records of details about actions taken to visitors, customers and business partners
      (vii) Activities for recruiting our personnel (executives, employees, temporary workers, dispatched workers and others), including screening and provision of job offer information (*)
      * Notices and different information mentioned above are given by visit, by sending direct mail (in forms of postcards, letters and others), by telephone, by electronic mail and by other means.
2. Disclosure and Provision of Personal Information to Third Parties We may offer personal information we have acquired to third parties on conditions that it is necessary to fulfillment of the purposes of use and that any of the cases specified below applies. We will suspend offering to third parties upon request from the principal, but we may not fulfill the request depending on circumstances if the case specified in (2) below applies.
   For filing a request for suspension of offering to third parties and questions, refer to 4. Inquiry Contacts below.
   1. We have obtained consent from the principal.
   2. It is possible to offer to third parties without consent from the principal under laws and regulations.
      1. a) The act of offering to third parties is conducted on the basis of laws and regulations.
         b) Offering to third parties is necessary to protection of human life, health or property, and it is difficult to obtain consent from the principal.
         c) Offering to third party is particularly necessary to public health improvement or children's sound development, and it is difficult to obtain consent from the principal.
         d) It is necessary to cooperate with the national government, a local government, or a party commissioned by them in performing affairs prescribed by laws and regulations, and it is possible that acquisition of consent from the principal would interfere with the performance of the said affairs.
      2. The event is not treated as offering to third parties according to laws and regulations.
         a) Handling of personal data is outsourced within the scope necessary to fulfillment of the purposes of use.
         b) Personal data is offered in connection with transfer of business.
3. Security Management Measures In line with the Practical Guidance on Safety Management Measures for the Guidelines on Personal Information Protection in the Financial Industry (Public Notice of the Personal Information Protection Commission and the Financial Service Agency No. 2 of February 28, 2017), we have instituted regulations for implementing security management measures necessary and appropriate to prevention and control of leakage, loss or damage of personal data. Its provisions have been designed to suit the risks arising from characteristics of our businesses, our state of handling of personal data and qualities of media storing personal data in consideration of the scale of infringement of rights and interests suffered by the principal that would result from the leakage, loss or damage.
   
   
4. Inquiry Contacts For inquiries on personal information offered to us or filing a request for disclosure (including disclosure of records of offering to third parties), correction, suspension of use or other treatment or suspension of offering to third parties, please contact the Personal Information Team in the Corporate Planning Department of Tokyo Tatemono Investment Advisors Co., Ltd. (Phone 03-3548-3351). When you request disclosure, correction, suspension of use or other treatment or suspension of offering to third parties, we will inform you of predetermined procedures that need to be taken, including identification, necessary documents and fees

Revised on April 1, 2022

Regarding Requests and Other Inquiries About Disclosure, etc.

If you have any inquiries about requests for disclosure, correction, suspension of use, etc. of personal information you have provided, please contact the following.

[Contact Information]
Tokyo Tatemono Investment Advisors Co., Ltd.
Corporate Planning Department (officer for personal information)
Tel.: +81-03-3548-Regarding Requests and Other Inquiries About Disclosure, etc.3351
E-mail:

[Request for Disclosure, etc.]

1. Request for disclosure, etc.
   The department described in the Contact Information above will accept the request for disclosure, etc. Upon receiving the request, the request form will be sent to the requester by mail, so the requester will be required to provide his or her name, address, and contact information.
2. The documents to be provided under the procedures for disclosure, etc.
   The Company will send the “Request Form for Disclosure, Etc. of Personal Data Held” by mail. The requester is required to fill in the form and send it back to the Company with the document for identity verification enclosed.
   For details, refer to the instructions stated on the request form.
3. Request by an agent
   (1) Privately appointed agent
   (2) Statutory agent
   In the case of a request by an agent described above, in addition to “2. The Documents to Be Provided Under the Procedures for Disclosure, Etc.,” above, the document to confirm the authority/capacity to represent the requester and the document for identity verification of the agent should be enclosed. For details, refer to the instructions stated on the request form.
4. Fees
   No fees will be charged, other than the postage to return the request form, for which the requester will be responsible.
5. Response method
   We will respond using the disclosure method you nominated in the request form.
6. Purpose of use of personal information obtained upon request for disclosure, etc.
   The personal information obtained upon request for disclosure, etc. will be handled only to the extent necessary at the time of the request for disclosure, etc.

TTIA is the member of the following authorized personal information protection organizations. Both of these organizations accept the submission of queries and complaints regarding the handling by their member firms of personal information.

1. ・Japan Investment Advisers Association, Complaints & Consultation Section
   (officer for personal information)
   Phone: +81-3-3663-0505
   Hours: Mon. – Fri. (exc. National Holidays) 9:00 – 5:00 p.m.


2. ・Member Audit Survey Office, The Investment Trusts Association, Japan
   Phone: +81-3-5614-8440
   Hours: Mon. – Fri. (exc. National Holidays) 9:00 – 11:30 a.m. & 12:30 – 5:00 p.m.