Handling Personal Information
Mitsui Fudosan Logistics Park Inc. (hereinafter, the "Investment Corporation") handles customers' personal information.
The Investment Corporation with relevant laws, regulations and guidelines, and takes necessary and appropriate measures (hereinafter, "safety management measures") as follows to prevent leaks, loss or damage of personal information handled and to otherwise safely manage personal information.
Formulation of Basic Policy
The Investment Corporation has formulated a basic policy to ensure the appropriate handling of personal information.
Establishment of Regulations for Handling of Personal Information
Mitsui Fudosan Logistics REIT Management Inc. (hereinafter, the "Company"), to which The Investment Corporation entrusts asset management, formulates internal regulations with stipulations regarding how personal information is handled, who is responsible and in charge, and their duties.
Organizational Safety Management Measures
The Company, to which The Investment Corporation entrusts asset management, has designated the head of the Finance Division as Chief Privacy Officer, the heads of each division and Chief Compliance Officer as Privacy Managers and the Chief Compliance Officer as Audit Manager in charge of implementing and operating the personal information protection system.
With the Chief Privacy Officer in charge of company-wide matters and division heads in charge of their divisions, these personnel are responsible for the necessary and appropriate supervision of their employees in handling personal data to ensure its safe management.
In the event that the Company leaks personal information or becomes aware of the possibility of such a leak, it will immediately report the situation to the division's Privacy Manager, who will immediately report it to the Chief Privacy Officer, who will report to the President, and then, depending on the nature of the problem, either personally or through the problematic division's Privacy Manager, promptly investigate the cause, take measures to prevent recurrence and formulate measures to deal with the problem outside of the Company.
If the Chief Privacy Officer determines that an incident such as a personal information leak has occurred, he or she will have employees promptly notify those who were the subject of the leak and immediately report the incident to the Financial Services Agency and The Investment Trusts Association, Japan. If the leaked personal information relates to the Company’s employment management, he or she will report it to the Privacy Committee.
Personnel Safety Management Measures
The Company’s Chief Privacy Officer, in cooperation with the Chief Compliance Officer, has established an internal education program for personal information protection and regularly provides education and training to the Company's officers and employees on proper handling.
Physical and Technical Safety Management Measures
The Investment Corporation’s personal data is stored in the Company’s lockable cabinet and keys are controlled by the Privacy Managers or other persons authorized by the Chief Privacy Officer in accordance with his or her instructions.
The Chief Privacy Officer limits the scope of stored/saved personal data to that necessary for business purposes, and when personal electronic information is stored on information system equipment, it is saved in folders with restricted access.
When personal electronic information is stored on external recording media, a password is assigned and this media is stored in a lockable cabinet designated by the Chief Privacy Officer, to be opened only when the information is used.
Monitoring the External Environment
Personal information held by the Investment Corporation is stored in Japan.
Inquiries/Complaints regarding the Handling of Personal Information
For questions or complaints regarding personal information, requests for disclosure, correction, discontinuation of use of retained personal data or other inquiries, please contact Mitsui Fudosan Logistics REIT Management Inc.
Mitsui Fudosan Logistics Park Inc. (hereinafter, the "Investment Corporation") shall comply with the Act on the Protection of Personal Information and other applicable laws and regulations, and rules, and shall endeavor to carefully handle personal information provided in accordance with the following policy.
1. Basic Policy Concerning the Handling of Personal Information
The Investment Corporation believes personal information is a vital business asset and as an entity trusted by not only customers, clients and society as a whole, the proper handling of personal information is not only a legal requirement but also as a social responsibility. In light of this, the Investment Corporation promotes initiatives to protect personal information under the following basic framework:
|The Investment Corporation shall not collect any personal information by wrongful means;
|The Investment Corporation shall only collect personal information which is necessary in the course of its business operations;
|The Investment Corporation shall not use any personal information or provide it to any third party beyond the scope of the purposes stated in the following section entitled "Purpose of Use of Personal Information" (hereinafter, "Purpose of Use"), unless otherwise required by laws and regulations;
|The Investment Corporation shall endeavor to manage personal information as accurately and as up-to-date to the extent necessary to achieve the Purpose of Use, and shall take strict security and control measures in order to prevent leakage, loss, damage of personal information; and
|The Investment Corporation shall continuously monitor the status of collection and management of personal information, and shall review the protection measures of personal information as needed.
2. Purpose of Use of Personal Information
The Investment Corporation shall use collected personal information and retained personal data to the extent of the following Purpose of Use, unless otherwise required by laws and regulations:
|To allow unitholders to exercise their rights, and to carry out the Investment Corporation's obligations in accordance with the regulations of the Act on Investment Trust and Investment Corporations (hereinafter, the "Investment Trusts Act") and other applicable laws and regulations;
|To manage information related to unitholders;
|To perform operations related to the issuance of investment units to be offered and issuance of investment corporation bonds by the Investment Corporation;
|To perform operations including responding to inquiries of investment units to be offered and investment corporation bonds by the Investment Corporation by prospective purchasers or confirmation and response to requests of materials;
|To conduct research, analysis or review related to management of assets of the Investment Corporation;
|To perform operations related to the acquisition, transfer or leasing of property, as well as property management for the Investment Corporation;
|To perform operations related to IR activities and general administration for the Investment Corporation; and
|To perform any other operations incidental to or related to the operations stated in (1) through (7) above.
3. Acquisition of Personal Information
The Investment Corporation shall collect personal information in appropriate manners to the extent necessary to achieve the Purpose of Use. When collecting personal information in writing directly from an individual (hereinafter, the "Individual"), (i) the Investment Corporation shall clearly state the Purpose of Use to the Individual in advance; and when collecting personal information in a way other than above, (ii) the Investment Corporation shall notify or disclose the Purpose of Use to the Individual in prompt and appropriate manners, except in cases where the Investment Corporation has already disclosed the Purpose of Use in advance. However, paragraphs (i) and (ii) above do not apply to cases where any other treatment is permitted by the laws and regulations (including the Act on the Protection of Personal Information).
4. Provision or Disclosure of Personal Information to Third Parties
The Investment Corporation shall not provide or disclose any personal information or retained personal data to any third party, except in the following cases:
|Where the Individual gives prior written consent;
|Where the Investment Corporation is required to provide or disclose the personal information or retained personal data by laws and regulations;
|Where it is necessary for the purposes of protecting the life, body or property of an individual, and it is difficult to obtain the Individual's consent;
|Where 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;
|Where it is necessary to cooperate with a national organ or local government or its delegate which performs affairs stipulated by laws and regulations, and obtaining the Individual's consent is likely to impede the performance of the affairs; or
|Where it is otherwise required by laws and regulations (including the Act on the Protection of Personal Information).
5. Disclosure, Correction and Suspension of Use of Personal Information
The Investment Corporation shall endeavor to manage personal information as accurately and as up-to-date to the extent necessary to achieve the Purpose of Use. When the Investment Corporation receives a request from the Individual regarding retained personal data, upon confirmation of the identity of the Individual or the proxy, the Investment Corporation shall take appropriate measures to the disclosure, alteration/addition/removal, and/or suspension of use/deletion (hereinafter, the "Disclosure, Correction and Suspension of Use") of such personal data, in accordance with the applicable laws and regulations, and related rules. For details, please see Contact Information in the below.
6. Strict Management
While the Investment Corporation, as a registered investment corporation, outsources its asset management and other general administration under the Investment Trusts Act, the Investment Corporation requires outsourcing to establish strict security and control measures in order to protect the retained personal data from leakage, loss, or damage.
The Investment Corporation shall continue to review and improve the system, rules and regulations, security and control measures and other programs regarding the protection of personal information as needed.
For inquiries or complaints regarding personal information, requests for the Disclose, Correction and Suspension of Use of retained personal data, or for any other inquiries, please contact the following:
Mitsui Fudosan Logistics REIT Management Co., Ltd.
|8-7, Ginza 6-chome, Chuo-ku, Tokyo 104-0061, Japan
|Monday to Friday, except public holidays, 9:00a.m. to 5:00p.m.
For inquiries regarding the unitholder register, please contact the following corporate agency:
Sumitomo Mitsui Trust Bank, Limited, Stock Transfer Agency Business Planning Dept.
|2-8-4, Izumi, Suginami-ku, Tokyo 168-0063, Japan
|0120-782-031 (toll-free within Japan)
|Monday to Friday, except public holidays, 9:00 a.m. to 5:00 p.m.