Frontier Real Estate Investment Corporation (hereinafter, "FRI") shall comply with all applicable laws and regulations, including the Act on the Protection of Personal Information, and shall endeavor to carefully handle personal information in accordance with the following policy.
1. Basic Policy Concerning the Handling of Personal Information
FRI regards personal information as a vital business asset and the proper handling of personal information not only as a legal requirement but also as a social responsibility to customers, clients and society as a whole. In this light, FRI takes the initiative in protecting personal information in line with the following basic framework:
- FRI shall not acquire any personal information by wrongful means;
- FRI shall only acquire personal information which is necessary in the course of its business operations;
- FRI shall not use any personal information or provide it to any other third party beyond the scope of the purposes stated in the following section entitled "Purposes for Using Personal Information" (hereinafter, "Purposes of Use"), except as otherwise required by laws and regulations;
- FRI shall endeavor to maintain retained personal data as accurate and up-to-date as possible and to delete personal data that is no longer necessary and shall take strict security and control measures in order to prevent possible loss, misuse, alteration or any other security violation of personal information, within the scope deemed necessary to achieve the Purposes of Use; and
- FRI shall continue to monitor the methods for acquiring and maintaining personal information, and from time to time shall review the protection measures of personal information when necessary.
2. Purposes for Using Personal Information
FRI shall use personal information only within the scope of the following Purposes of Use, except as otherwise required by laws:
- To allow unitholders to exercise their rights, and to carry out FRI's obligations in accordance with the regulations of the Act on Investment Trusts and Investment Corporations of Japan (hereinafter, the "Investment Trust Act") and other applicable laws and regulations;
- To maintain information related to unitholders, including data for the register of unitholders, in accordance with the Investment Trust Act;
- To perform business activities related to the investment units and corporate bonds issued or to be issued by FRI;
- To perform business activities, including the confirmation of and correspondence concerning inquiries and requests for information or materials from unitholders as well as from prospective purchasers of investment units and corporate bonds issued or to be issued by FRI;
- To conduct research, analysis or inspections related to asset management on behalf of FRI;
- To perform business activities related to the acquisition, transfer or borrowing/lending of property, as well as property management, on behalf of FRI;
- To perform business activities related to IR activities and general administrative services for the benefit of FRI; and
- To perform any other business activities ancillary to or related to the activities stated in 1 through 7 above.
3. Acquisition of Personal Information
FRI shall acquire personal information only within the scope deemed necessary to achieve the Purposes of Use and by appropriate means. FRI shall not acquire sensitive information without the consent of the individual except in cases designated by the Act on the Protection of Personal Information and related guidelines.
- When acquiring personal information in writing directly from an individual, FRI shall clearly state the Purposes of Use to the individual in advance; and
- When acquiring personal information in a way other than 1 above, FRI shall notify or disclose the Purposes of Use to the individual in a prompt and appropriate manner, except in cases where FRI has already disclosed the Purposes of Use in advance.
However, paragraphs 1 and 2 above do not apply to cases where any other treatment is permitted under the laws and regulations (including the Act on the Protection of Personal Information).
4. Provision and Disclosure of Personal Data to Third Parties
FRI shall not provide or disclose any retained personal data to any other third party, except in cases where:
- The individual gives prior written consent;
- FRI provides or discloses the personal information or retained personal data as statistics or in a similar form to such on an anonymous basis;
- FRI is required to provide or disclose the personal information or retained personal data by laws and regulations;
- It is necessary for the purposes of protecting the life, body or property of persons, and it is difficult to obtain the individual's consent;
- 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;
- It is necessary to cooperate with a state body 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
- It is otherwise required by laws and regulations (including the Act on the Protection of Personal Information).
5. Disclosure, Alteration and Termination of Use of Retained Personal Data
When FRI receives a request from an individual regarding retained personal data, upon confirmation of the identity of the individual, or the identity of his/her agent, FRI shall take appropriate actions with respect to the disclosure (hereinafter, the "Disclosure"), alteration/addition/removal (hereinafter, the "Alteration"), and/or termination of use/deletion (hereinafter, the "Termination of Use") of such personal data, in accordance with the applicable laws and regulations. For details, please see Contact Information in Section 7 below.
6. Measures for Security and Control
While FRI, as a registered investment corporation, outsources its asset management and other general administrative services under the Investment Trust Act, FRI requires the outsourcees to establish strict security and control measures as below in order to protect the personal data from loss, misuse, alteration or any other security violation.
- In order to ensure the proper handling of personal data, the outsourcees shall establish and comply with personal information management guidelines.
- Depending on the method of acquisition and the content of the information, the outsourcees shall establish and comply with personal information management guidelines regarding the handling method, responsible persons and persons in charge and their duties, etc. at each stage of use, storage, management, saving, disposal, etc.
- The outsourcees shall appoint a person responsible for the handling of personal data, clarify who are the employees who handle personal data and the scope of the personal data handled by such employees, and establish a system for reporting to and communicating with the responsible person in the event that any fact or sign of violation of laws or handling regulations is detected.
- The outsourcees shall provide training to employees on matters requiring attention with regard to the handling of personal data, and conclude an agreement with them on the confidentiality of personal data.
- The outsourcees shall take measures to prevent theft or loss, etc. of devices, electronic media and documents, etc. that are used when handling personal data.
- The outsourcees shall maintain a personal information management ledger, take security management measures according to the type of personal data, and carefully manage passwords.
7. Contact Information
For inquiries or complaints regarding personal information, requests for the Disclosure, Alteration and/or Termination of Use of retained personal data, requests for the Disclosure of records on the third-party provision of retained personal data or for any other inquiries, please contact the following:
Mitsui Fudosan Frontier REIT Management Inc.
Planning and Administration Division
Address: 6-8-7 Ginza, Chuo-City, Tokyo
Personal Information Handling Business Operator: Frontier Real Estate Investment Corporation
Representative: Executive Officer Takao Iwadou
Address: Kojun Building, 6th Floor, 6-8-7 Ginza, Chuo City, Tokyo
Enacted: April 1, 2005
Last Revised: April 1, 2022