XYMAX REIT Investment Corporation

JAPANESE

Privacy Policy

XYMAX REIT Investment Corporation
Nobuhito Inatsuki, Executive Director

XYMAX REIT Investment Corporation (hereinafter, “XYMAX REIT”) has established the following policy on the handling of personal information to comply with the Act on the Protection of Personal Information (Act No. 57 of 2003, as amended), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of 2013, as amended; hereinafter, the “Number Act”), other laws, regulations and guidelines and this policy in the handling of personal information and specific personal information (hereinafter, “personal information, etc.”).

1.Compliance with Laws and Regulations

Recognizing the importance of personal information, etc., XYMAX REIT shall strive for proper handling and protection of personal information, etc. by respecting and complying with laws, regulations, etc. on the protection of personal information, etc.

2.Name of Personal Information Handling Business Operator

XYMAX REIT Investment Corporation

3.Acquisition of Personal Information

XYMAX REIT shall acquire personal information, etc. by legal and proper means. Similarly, in cases where personal information is to be acquired via third parties, the personal information shall not be acquired when there is a possibility that the personal information was illegally or improperly acquired by the third parties.

4.Purposes of Use of Personal Information, Etc.

Unless otherwise provided for in laws and regulations, XYMAX REIT may use personal information within the scope necessary for achievement of the following purposes of use:

(1) Identity verification and credit check of the person stated on application forms, contracts or other written documents, website pages, etc. acquired concerning businesses conducted by investment corporations
(2) Various business activities accompanying fulfillment of contractual relationships concerning businesses conducted by investment corporations
(3) Survey analysis, data collection, marketing activities and various information provision (postal delivery, phoning, electronic mail transmission, etc.) necessary for execution of businesses conducted by investment corporations
(4) General administrative affairs or other related or incidental business activities (communication and inquiry with unitholders, and other general administrative communication and inquiry) concerning businesses conducted by investment corporations
(5) Verification of visitors to XYMAX REIT and record of how the visitors were served
(6) Disclosure or provision of personal information to third parties pursuant to laws and regulations within the scope necessary for achievement of the purposes of use listed in (1) through (5) above

5.Provision of Personal Information to Third Parties

XYMAX REIT shall not provide collected personal information to third parties without obtaining the person’s consent in advance, except in the following cases:

(1) Cases pursuant to laws and regulations
(2) Cases where necessary for protection of human life, body or fortune, and it is difficult to obtain the person’s consent
(3) Cases where particularly necessary for improvement of public health or promotion of the sound growth of children, and it is difficult to obtain the person’s consent
(4) Cases where there is a need to cooperate with a national government organ or a local government, or a party entrusted by one, in performing affairs prescribed by laws and regulations, and there is a possibility that obtaining the person’s consent would interfere with the performance of the affairs

Furthermore, regardless of whether or not the person’s consent is obtained, XYMAX REIT shall not provide individual number and specific personal information collected, used or kept for specific purposes pursuant to the Number Act to third parties, except in cases pursuant to laws and regulations.

6.Security Control Measures for Personal Information

XYMAX REIT shall manage personal information by properly and carefully managing retained personal data and taking appropriate security control measures from the organizational, human resources, physical or technical aspects in accordance with laws, regulations, etc. for prevention of unauthorized access to and loss, alteration, divulgence, etc. of personal data.

7.Outsourcing of Handling of Personal Information

XYMAX REIT may outsource the handling of personal information, in whole or in part, within the scope necessary for achievement of the purposes of use. In such cases, XYMAX REIT shall exercise necessary and appropriate management and supervision, such as entering into agreements necessary for protection of personal data with the parties so entrusted.

Revision History
Version 1: Established on November 29, 2017

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