Hankyu REIT
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Privacy Policy

[Oath]

Recognizing the importance of the proper handling of personal information, etc. (refers to personal information, and specific personal information (refers to personal information containing the Individual Number; the same shall apply hereafter); the same shall apply hereafter), Hankyu REIT, Inc. (hereafter "Hankyu REIT") complies with the "Act on the Protection of Personal Information" (hereafter the "Personal Information Protection Act"), the "Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure" (hereafter the "Number Act"), and other relevant laws and regulations, cabinet orders and competent government agencies' guidelines in the handling of personal information, etc., and thereby strives for proper handling, management and protection of personal information, etc.

[Handling of personal information, etc.]

1. Compliance with laws and regulations, etc.

Hankyu REIT shall comply with relevant laws and regulations, cabinet orders and competent government agencies' guidelines in handling personal information, etc.

2. Acquisition of personal information, etc.

(1) Acquisition of personal information
Hankyu REIT shall acquire personal information by legal and proper means. In addition, in cases where personal information is to be acquired directly from the person in writing, etc., Hankyu REIT shall clearly indicate the purposes of use thereof to the person in advance. However, there may be cases where the clear indication of the purposes of use is omitted in cases where the purposes of use are found to be clear in light of the circumstances of the acquisition or otherwise permitted by laws and regulations.

(2) Acquisition of the Individual Number
Hankyu REIT's right to request that the person or another person in charge of affairs related to the Individual Number provide the Individual Number shall be limited to cases where necessary for processing the affairs set forth in 3.(2) later in this privacy policy. In addition, the request for provision of the Individual Number shall be made at the point in time when the need arises for processing the concerned affairs or at the point in time when it becomes foreseeable that the concerned affairs will take place.

(3) Identity verification
In being provided with the Individual Number, Hankyu REIT shall perform identity verification by the methods provided in Article 16 of the Number Act. In addition, in the case of an agent, Hankyu REIT shall perform confirmation of the agent's identity, confirmation of the authority of representation and confirmation of the person's Individual Number by the methods provided in said Article.

3. Purposes of use of personal information, etc.

(1) Purposes of use of personal information
In the use of personal information, unless otherwise provided for in laws and regulations, Hankyu REIT shall handle personal information within the scope necessary for achievement of the following purposes of use:

  1. For exercise of rights of the holders of securities issued by Hankyu REIT and performance of obligations of Hankyu REIT pursuant to the "Act on Investment Trusts and Investment Corporations" (hereafter the "Investment Trusts Act") and other laws and regulations
  2. For IR activities concerning Hankyu REIT
  3. For preparation and submission of various reports, etc., as well as preparation of various data for management of unitholders' register and other unitholder information, of Hankyu REIT pursuant to the Investment Trusts Act, other laws and regulations, and rules of Tokyo Stock Exchange, Inc., etc.
  4. For responding to inquiries, etc. to Hankyu REIT
  5. For Hankyu REIT's debt financing, and issuance of investment corporation bonds for subscription, investment units for subscription and other securities issued by Hankyu REIT
  6. For Hankyu REIT's acquisition and sale of assets under management and leasing of assets under management, as well as survey and consideration, collection and provision of information and execution of various other business operations involved in management of assets conducted under the Investment Trusts Act required for these
  7. For appropriate and smooth execution of other business operations of Hankyu REIT

(2) Purposes of use of the Individual Number
Hankyu REIT's purposes of use of the Individual Number shall be as follows:

  1. For affairs of preparing records of financial instruments transactions, etc.
  2. For affairs of preparing payment records concerning payment of compensation, fees, signing bonuses, bonuses and other remuneration for services or rights
  3. For affairs of preparing payment records concerning payment of remuneration for use or incoming transfer of real estate, etc.
  4. For affairs of preparing payment records concerning payment of distributions, surplus or interest, etc. and other distribution of income
  5. For affairs of preparing records concerning granting or exercise of subscription rights to investment units or allotment of investment units without contribution of Hankyu REIT investment units
  6. For other affairs of preparing statutory records, etc. required by the provisions of laws and regulations for the Individual Number to be stated

4. Restrictions on provision of personal information, etc. to third parties

(1) Restrictions on provision of personal information to third parties
Hankyu REIT shall not provide personal information to third parties except in the following cases:

  1. Cases where the person has consented
  2. Cases where pursuant to laws and regulations
  3. Cases where necessary for the protection of the life, body or property of an individual, and it is difficult to obtain the consent of the person
  4. Cases where particularly necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the consent of the person
  5. Cases where necessary for cooperating with a state organ or a local government, or an individual or a business operator entrusted by a state organ or a local government in executing the affairs prescribed by laws and regulations, and obtaining the consent of the person is likely to impede the execution of the affairs
  6. Cases where provision and disclosure is in a statistical data form or other state that cannot identify the person

(2) Restrictions on provision of specific personal information to third parties
Hankyu REIT shall not provide specific personal information to third parties except in the cases listed in the items of Article 19 of the Number Act.

5. Ensuring of accuracy

Hankyu REIT shall strive to keep the content of personal information, etc. accurate and up-to-date within the scope necessary for achievement of the purposes of use.

6. Ensuring of security

Hankyu REIT shall take necessary and appropriate security control measures for the prevention of unauthorized access to personal information, etc., and loss, damage, falsification, divulgation, etc. of personal information, etc.

7. Supervision of parties entrusted with handling of personal information, etc.

In the entrustment of the handling of personal information, etc., Hankyu REIT shall carry out the necessary and appropriate supervision over the party so entrusted in order to ensure the party's safe management of personal information, etc.

8. Disclosure, correction, etc. of personal information, etc.

Concerning procedures for disclosure, correction, addition or deletion of personal information, etc. of the person, please inquire with the contact below for appropriate response in accordance with prescribed procedures for the personal information, etc.

9. Inquiries regarding personal information, etc.

Hankyu REIT shall respond sincerely to questions, complaints, etc. regarding the handling of personal information, etc. Please inquire to the contact below for any questions, complaints, etc. regarding personal information, etc.

Hankyu REIT Asset Management, Inc.
Corporate Administration and Supervision Department
Address: 19-19 Chayamachi, Kita-ku, Osaka
TEL: 06-6376-6821
Business hours: 9 a.m. to 5 p.m.
(except Saturdays, Sundays, national holidays,
and holidays designated by the Company)

Please inquire with the administrator of unitholders' register below regarding correction, addition, deletion, etc. of matters stated on the unitholders' register.

Mitsubishi UFJ Trust and Banking Corporation
Osaka Corporate Agency Division
Address: 3-6-3 Fushimimachi, Chuo-ku, Osaka
TEL: 0120-094-777 (toll free)
Business hours: 9 a.m. to 5 p.m.
(except Saturdays, Sundays, national holidays,
and holidays designated by the Bank)

10. Continuous improvement

Hankyu REIT shall strive to continuously review and thereby improve this privacy policy and other frameworks for the protection of personal information, etc. to ensure the appropriate protection of personal information, etc.

Established on March 23, 2010

Last rivision on December 22, 2015