Personal Information Protection Policy

The Company shall comply with the Act on the Protection of Personal Information, the Order for Enforcement of the Act on the Protection of Personal Information and other relevant laws and regulations, establish this Policy, and endeavor to protect personal information.

Company name, address, and name of the representative

・Star Asia Investment Management Co., Ltd.
・Atago Green Hills Mori Tower 18F, 2-5-1, Atago, Minato-ku, Tokyo 105-6218
・President and CEO Atsushi Kato

Policy

Recognizing the extreme importance of honoring individual privacy, the Company shall strive to properly handle and safely and reliably manage/use personal information in addition to ensuring using such for only predetermined purposes and appropriately handling complaints, etc. of such, by adhering to the Act on the Protection of Personal Information and other related laws and regulations as well as norms and internal rules among others.

Purposes of Use of Personal Information

Purposes of use of personal information collected by the Company are as follows.

1.To analyze customer trends related to the Company’s businesses (*1) and conduct surveys and analyses for product development, etc.
2.To identify the interested parties related to the Company’s businesses (*1) and deliver various notices (*2) in accordance with the business implementation
3.To conduct marketing activities (*2) related to the Company’s businesses (*1)
4.To identify the individuals and investigate their credits with regard to applications, contracts and other matters related to the Company’s businesses (*1)
5.To deliver various notices (2*) in accordance with implementation of applications, contracts and other matters related to the Company’s businesses (*1)
6.To deliver notices (*2) on questionnaires for customer satisfaction, etc. related to the Company’s businesses (*1)
7.To conduct public relations activities of the Company (provide corporate information (*2) and deliver notices (*2) on events and questionnaire surveys, etc.)
8.To identify the Company’s shareholders and deliver various notices (*2) as share-issuing company to the shareholders
9.To identify the visitors to the Company and record interactions with visitors
10. To conduct recruiting activities (select and provide employment information (*2)) for people to be engaged in the Company’s businesses (officers, employees, temporary dispatch workers, seconded staff, etc.), pay remunerations, conduct labor management, provide welfare and benefits
11. To disclose and provide personal information to third parties to the extent necessary for implementing the Company’s businesses (*1) and for achieving the purposes of use from (1) through (10)

However, when upon provision of personal information, a purpose of use other than the above is notified or clearly specified to the information provider (the individual) the purpose of use shall prevail over the above purposes of use. No change to the purpose of use of personal information will be made beyond the scope reasonably recognized as having relevance to the purpose of use prior to such change.

Prohibition of Improper Use

The Company will not use personal information by methods which could possibly facilitate or induce illegal or unjust acts.

Disclosure/Provision of Personal Information to Third Parties

Required items of personal information collected by the Company, such as address, name, real estate information or details of interactions with visitors or callers, may be provided to a third party by person, mail, phone, internet, e-mail, advertising medium, etc. in the following cases. Disclosure/provision will be halted if such request is made by the information provider (the individual). However, there may be cases where requests cannot be complied with, depending on the specifics of such requests.

1.Where consent has been obtained from the relevant individuals
2.Where disclosure or provision is based on laws and regulations
3.Where it is necessary to do so for protecting people’s lives, bodies or estates, in cases when it is difficult to obtain consent from the relevant individuals for disclosure/provision of the personal information
4.Where it is necessary to do so particularly for improvement in public health or sound development of children, and it is difficult to obtain consent from the relevant individuals
5.Where it is necessary to cooperate with national administrative agencies, local governments or parties entrusted by such entities in conducting administrative operations designated by laws and regulations, and obtaining consent from relevant individuals for disclosure/provision of the personal information may cause problems in conducting such operations
6.Disclosure/provision of personal information to third parties to the extent necessary for implementing the Company’s businesses (*1) and achieving the purposes of use of such information
7.Any other cases which are permitted under the Act on Protection of Personal Information

Examples of third parties to which personal information may be disclosed/provided

National administrative agencies, local governments or parties entrusted by such entities
Parties entrusted to conduct services to the extent necessary for achieving the purposes of use of personal information
Parties entrusted to conduct services within the scope of the Company’s businesses (*1)
Counterparties and potential counterparties of contracts to be concluded in accordance with the implementation of the Company’s businesses (*1)
Advertising agencies and groups for advertisements, etc. to be published in newspapers and magazines or on the Internet, etc. in accordance with the implementation of the Company’s businesses (*1)
Judicial scriveners, etc. for registration, etc. required in accordance with the implementation of the Company’s businesses (*1)
Financial institutions, etc. for lending, etc. required in accordance with the implementation of the Company’s businesses (*1)
Building lots and buildings business operators engaged in brokerage, etc. of real estate and the Real Estate Information Network System (REINS) organizations (organizations designated by the Minister of Land, Infrastructure, Transport and Tourism under the Building Lots and Buildings Transaction Act)

*	When requested to broker real estate or conduct similar services, the building lots and buildings business operators or the REINS may provide the real estate information, etc. they receive in accordance with such requests to other building lots and buildings business operators or other REINS organizations in order to look for the counterparties of the contracts. Moreover, the real estate information, etc. they receive from other building lots and buildings business operators or other REINS may be provided to the parties wishing to conduct real estate transactions or to other building lots and buildings business operators. For more details of the REINS, please refer to the website of Real Estate Information Network for East Japan (REINS TOWER), etc.

When requested to broker real estate or conduct similar services, the building lots and buildings business operators or the REINS may provide the real estate information, etc. they receive in accordance with such requests to other building lots and buildings business operators or other REINS organizations in order to look for the counterparties of the contracts. Moreover, the real estate information, etc. they receive from other building lots and buildings business operators or other REINS may be provided to the parties wishing to conduct real estate transactions or to other building lots and buildings business operators.
For more details of the REINS, please refer to the website of Real Estate Information Network for East Japan (REINS TOWER), etc.

Matters concerning Security Control Measures

Regarding personal data, the Company will take necessary and appropriate security control measures to manage such personal data, including prevention of leakage, loss, or damage. Furthermore, the Company will conduct necessary and appropriate supervision towards employees and entrusted parties (including subcontracted parties etc.). The Company has separately and specifically provided for security control measures for personal data in the “Personal Information Handling Rules”, and the main contents are as follows.

Establishment of Personal Information Protection Policy

In order to secure proper handling of personal data, this Policy (Personal Information Protection Policy) has been established regarding “compliance with relevant laws and regulations and guidelines” and “contact information for inquiries and handling of complaints” etc.

Development of rules regarding the handling of personal data

“Personal Information Handling Rules” have been established which prescribes handling methods, responsible persons and other persons in charge and their responsibilities, in accordance with each stage from acquisition, use, storage, provision, to deletion and abolishment etc.

Institutional security control measures

In addition to appointing an information management supervisory manager regarding the handling of personal information, the scope of employees handling personal data and the scope of personal data to be handled by such employees have been clearly determined, and a whistle-blowing system has been developed for reporting to the information management supervisory manager for when the fact of violation of the Act on the Protection of Personal Information or the Personal Information Handling Rules, or an indication of such violation, is found.
Regarding the handling status of personal data, in addition to conducting periodic voluntary inspections, audits are conducted by other departments or external parties.

Human security control measures

Regarding points of concern regarding the handling of personal information, periodic training is conducted towards employees.
The rules of employment stipulate matters related to confidentiality of personal data.

Physical security control measures

In areas which handle personal data, measures have been taken to prevent the browsing of personal data by persons not authorized to do so.
Measures have been taken to prevent the theft or loss etc. of equipment, electronic media and documents etc. which handles personal data. Furthermore, security control measures have been taken to prevent the leakage etc. of personal data when such equipment, electronic media, etc. is carried around, including moving within the business office, and when such equipment and electronic media, etc. handling personal data is disposed of.

Technological security control measures

Access control is implemented, and the persons in charge as well as the scope of the personal information database etc. to be handled are limited.
A system has been installed to protect information systems which handle personal data from unauthorized access from the outside or malicious software.

Understanding the external environment

Security control measures are taken, after grasping the systems for protection of personal information in EU countries, the U.K. or U.S.A, where personal data is being stored or are planned to be stored.

Inquiries Relating to Personal Information

For questions concerning the general handling of personal information or questions regarding provided personal information; inquiries related to request for notice of the purpose of use, the disclosure, corrections, addition, deletion, or suspension of use, etc. of held personal data; or complaints on handling of personal information, please contact the contact stated below. However, there may be cases where requests cannot be complied with, depending on the specifics of such requests. Furthermore, upon sending notice of or disclosing the purpose of use of held personal data, or upon disclosing records provided by third parties, the requesting party may be asked to bear prescribed fees.

Star Asia Investment Management Co., Ltd. Financial Management Department

Phone	+81-3-5425-1340
Open hours	9:30-11:30, 12:30-17:30. Mondays through Fridays (excluding Saturdays, Sundays, holidays, and non-work days prescribed by the Company)

The Company is a subject business operator of the Investment Trust Association Japan, a certified personal information protection entity. The Association is receiving consultations and complaints etc. related to the handling of personal information by subject business operators.

The Investment Trust Association Japan, Investment Counselling Room

Phone	03-5614-8440
Open hours	9:00–11:30, 12:30-17:00 (excluding Saturdays, Sundays, holidays, and non-work days prescribed by the Company)

(*1)	The Company’s businesses refer to 1) transaction, exchange and lease of real estate and agency or brokerage services for these, 2) transaction of beneficiary interests in trust for real estate, 3) holding, administration, management and disposal of real estate and beneficiary interests in trust for real estate, etc., and 4) investment management and consulting for investment corporations that invest in real estate and beneficiary interests in trust for real estate, etc.
(*2)	Conduct of marketing activities and provision of various notices and various pieces of information are implemented through visits, sending of postcards and direct mails, phone calls, transmission of e-mails and other measures.

(*1)

The Company’s businesses refer to 1) transaction, exchange and lease of real estate and agency or brokerage services for these, 2) transaction of beneficiary interests in trust for real estate, 3) holding, administration, management and disposal of real estate and beneficiary interests in trust for real estate, etc., and 4) investment management and consulting for investment corporations that invest in real estate and beneficiary interests in trust for real estate, etc.

(*2)

Conduct of marketing activities and provision of various notices and various pieces of information are implemented through visits, sending of postcards and direct mails, phone calls, transmission of e-mails and other measures.

Established on October 13, 2015
Revised on July 22, 2016
Revised on April 1, 2022