Personal Information Protection Policy in Brokerage Services, etc., for Purchase and Sale of Real Estate Trust Beneficiary Interests

Important notice：This English translation is prepared solely for your reference purposes.

As to personal information related to the brokerage of purchase and sale and private placement of real estate trust beneficiary interests, (hereinafter “brokerage services, etc. for purchase and sale of real estate trust beneficiary interests”), the Mitsui Fudosan Realty Group has established policies and system for the protection of personal information protection as follows and hereby declares them as the Personal Information Protection Policy in Brokerage Services, etc., for Purchase and Sale of Real Estate Trust Beneficiary Interests.

Basic Policy

The Mitsui Fudosan Realty Group recognizes the importance of each client’s personal information and is fully committed to the appropriate handling and secure management of personal information including its anonymized data (hereinafter ’Personal Information etc.’) ensuring all of our officers and employees who are engaged in the brokerage services, etc. for purchase and sale of real estate trust beneficiary interests comply with laws, regulations, company rules, etc., concerning the protection of personal information.
In addition, we strive to further refine and improve the policy by performing reviews continuously.

Handling of Personal Information

1. Acquisition, use, and provision of personal information

We acquire the personal information of our clients by lawful and fair means, and either concurrently clarify the purpose of its use and other necessary matters concerning personal information or post them on our website or its equivalents. We handle personal information pursuant to appropriate procedures and within the scope of the purposes of its use.
Further, when we furnish or disclose personal information to any third party, we do so in accordance with procedures stipulated by laws and regulations.

2. Purposes of use of personal information

The personal information of each client is used for the following purposes:

1. The brokerage of purchase and sale and private placement of real estate trust beneficiary interests and other incidental services thereto
2. Business activities conducted by post, e-mail, telephone, etc., related to the above services, customer trend analysis, and survey analysis for products and sales-method development
3. Providing personal information to third parties within the scope necessary to achieve the purposes stated in 1 above.

3. Provision of personal information to third parties

In addition to cases provided for by laws and regulations, a client’s personal information might be provided to third parties in writing, by post, by telephone, or via such means as the Internet, e-mail, an information system, and an advertising medium, within the scope necessary to achieve purposes shown above. We will, however, discontinue providing a client’s personal information to third parties at the client’s request.

1. Examples of parties to whom personal information may be provided
   • Counterparties, prospective counterparties, applicants to a purchase and sale agreement, and other financial instruments business operators involved in the brokerage services, etc. for purchase and sale of real estate trust beneficiary interests
   • Financial institutions, judicial scriveners, registered land and building investigators, real estate management service providers for trust properties involved in duties incidental to the brokerage services, etc. for purchase and sale of real estate trust beneficiary interests
2. Items of personal information to be provided
   • Items within the scope necessary for the purposes of use above, such as names, addresses, telephone numbers, and property information etc.

4. Subcontracting the handling of personal information

We might subcontract the handling of personal information of clients to an outside contractor.
In the case of subcontracting, we guarantee a certain level of protection for personal information by selecting a contractor that takes sufficient measures to protect personal information and by conducting the necessary and appropriate supervision of such contractor.

5. Inquiry contact for personal information

If you would like to request disclosure, correction, discontinuance of the use of your own personal information or retained personal data, or if you have a question, opinion, etc., regarding personal information, please contact the inquiry contact below or a business unit in charge of your account.

How to request disclosure of personal information

If you would like to request disclosure of your own personal information, please fill in necessary items in the prescribed disclosure-request form and either send it by mail or bring it to the inquiry contact above together with attachments required. There is a predetermined fee for disclosure of personal information to be borne by an applicant.
Please refer to the following link at the website for more details of the procedures.

Concerning procedures for disclosure, etc. of personal information

6. Handling anonymized information

1. When we prepare or provide anonymized information, necessary matters required by laws, regulations, and other norms shall be posted on our website or its equivalent.
2. We shall take safety management measures stipulated by company rules pertaining to anonymized information.

System for the protection of personal information

1. Strict and appropriate management of personal information

1. We appropriately and prudently manage each client’s personal information etc., and take the utmost care and necessary and appropriate safety management measures to prevent unauthorized access to, and loss, falsification, leakage, etc., of personal information etc.
2. We provide education and training for all officers and employees of Mitsui Fudosan Realty Group companies in accordance with company rules to comply with relevant laws and regulations, and understand and share the importance and necessity of system for the protection of personal information, and exercise the necessary and appropriate supervision.

2. Administrative structure for the protection of personal information

1. The chief information security management officer appointed by the representative director of Mitsui Fudosan Realty Co., Ltd. serves as the chief officer responsible for the protection of personal information within the Mitsui Fudosan Realty Group.
2. At Mitsui Fudosan Realty Co., Ltd., the protection of personal information is practiced in each division where a head of a division serves as an information security manager.

Mitsui Fudosan Realty Group	Chief information security management officer Executive officer in charge of general administration
Mitsui Fudosan Realty Co., Ltd.	Information security officer Managing officer in charge of general administration

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3-2-5, Kasumigaseki, Chiyoda-ku, Tokyo
(Personal Information Handling Business Operator) Mitsui Fudosan Realty Co., Ltd.

Instituted on September 30, 2007
Revised on May 30, 2017