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Privacy Policy

Privacy Policy

Activia Properties Inc. (hereinafter the “Investment Corporation”) recognizes the importance of personal information (including Individual Numbers and Specific Personal Information; the same shall apply hereinafter) of unitholders (including registered pledgees of investment units, etc.; the same shall apply hereinafter in this privacy policy), people considering acquiring investment units, business partners of the Investment Corporation or the asset manager, tenants of properties, or people considering leasing properties, etc. (hereinafter collectively “Customers”), and will handle the personal information it obtains carefully. To provide better products and services, the Investment Corporation will implement the policy below and will responsibly protect Customers' personal information.

1. Policy on handling of personal information

The Investment Corporation considers the appropriate protection and use of personal information to be its social responsibility. The Investment Corporation will perform operations in compliance with the Act on the Protection of Personal Information (hereinafter the “Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter the “My Number Act”) and other applicable laws, regulations, and guidelines.

2. Proper obtainment of personal information

When the Investment Corporation directly or indirectly obtains Customers' personal information, it will obtain the personal information by fair and legitimate means (including, but not limited to, the case where personal information is directly provided through documents, etc. that Customers fill out and submit, such as agreements) and, unless otherwise specified in laws and regulations, upon notice or announcement of the purposes of use, to the extent necessary to accomplish such purposes of use. Furthermore, the Investment Corporation will not obtain Customers' special care-required personal information (as defined in the Personal Information Protection Act; the same shall apply hereinafter) without prior consent of Customers, unless otherwise specified in laws and regulations.

3. Purposes of use

The Investment Corporation will handle Customers' personal information only within the scope of the purposes that are described in the Purposes of Use of Personal Information below. The Investment Corporation will not handle personal information beyond the scope of the purposes unless otherwise specified in laws and regulations or approved by the Customers in advance. Furthermore, with the exception of cases based on laws and regulations, the Investment Corporation will not use Individual Numbers or Specific Personal Information, which it collects, uses or keeps for specific purposes based on the My Number Act, beyond the scope of the purposes, regardless of whether customer’s consent is obtained or not.

4. Appropriate use

The Investment Corporation will not use Customers' personal information using a method that has the possibility of fomenting or prompting unlawful or unfair act.

5. Restriction on providing personal information to third parties

The Investment Corporation will not provide Customers' personal data to any third parties without the consent of Customers or unless otherwise specified in laws and regulations. Furthermore, with the exception of cases based on laws and regulations, the Investment Corporation will never provide Individual Numbers or Specific Personal Information, which it collects, uses or keeps for specific purposes based on the My Number Act, to third parties, regardless of whether customer's consent is obtained or not.

6. Acquisition of sensitive information, etc.

The Investment Corporation will not obtain, use or provide to any third parties, unless stipulated in the “Guidelines for Personal Information Protection in the Finance Sector”, special care-required personal information or information relating to membership in labor unions, family origin, registered domicile, healthcare, and sex life (excluding those falling under special care-required personal information) (excluding any information made public by the person themselves or by national government organs, local public entities, academic research institutions, or those listed in the Personal Information Protection Act or the Ordinance for Enforcement of the Act on the Protection of Personal Information or seemingly-clear information acquired by visual observation, filming or photographing of the person).

7. Request for Disclosure, etc. based on the Personal Information Protection Act

If a Customer requests the notice of purpose of use of the retained personal data that is held by the Investment Corporation, the asset manager, the general administrator, the custodian, etc., to which the Investment Corporation entrusts its business affairs, or its disclosure, corrections, additions to or deletion of its contents, the suspension of its use, its elimination, cessation of its disclosure to third parties, or the disclosure of record on a third-party provision (hereinafter collectively “Request for Disclosure, etc.”), the Investment Corporation will respond to the Request for Disclosure, etc. pursuant to laws and regulations. In each procedure, the Investment Corporation will verify that the person making the Request for Disclosure, etc. is the principal. The Investment Corporation may receive prescribed fees for procedures for requested notification of purpose of use of retained personal data or disclosure of retained personal data. In case of informing a principal to the effect that, as regards a whole or part of action requested by the principal, the action will not be taken, or to the effect that different action from the said action will be taken, the Investment Corporation will endeavor to explain a reason therefor to the said principal.

8. Complaints, etc. regarding personal information

The Investment Corporation will endeavor to properly and expeditiously process any complaints, etc. on the handling of personal information within a reasonable period.
For contact information regarding any complaints, etc. about our handling of personal information, please see below.

9. Security control measures

The Investment Corporation will keep Customers' personal data accurate and up to date, strictly manage Customers' personal data, and take institutional security control measures, human security control measures, physical security control measures, and technological security control measures against any leakage, loss or damage (hereinafter collectively “Leakage, etc.”) (in the event where the Investment Corporation handles personal data in a foreign country, the Investment Corporation will take such security control measures after having understood the legal system, etc. related to protection of personal information in such foreign country), and endeavor to delete such personal data without delay when it is no longer needed. If the Investment Corporation outsources the handling of personal data to a third party, the Investment Corporation will oversee the handling of such personal data, for example by obligating the third party to strictly manage the personal data. For contact information regarding details of security control measures of the Investment Corporation, please see below.

10. Continuous review of the Investment Corporation's internal system

The Investment Corporation will continuously review and improve its internal rules regarding handling of personal information and its internal system to implement it in order to ensure a continuous, proper and effective operation.

11. Disclaimer

The website that the Investment Corporation operates or manages includes links to external websites. However, the Investment Corporation will not assume any responsibility for the contents such as protection of personal information on the external websites the website is linked to.

Name, Address, and Name of Representative of Personal Information Handling Business Operator

Name	Activia Properties Inc.
Address	21-1 Dogenzaka 1-chome, Shibuya-ku, Tokyo
Name of Representative	Nobuhide Kashiwagi, Executive Director

Purposes of Use of Personal Information (except Individual Numbers and Specific Personal Information)

The Investment Corporation will use the personal information it has obtained (except Individual Numbers and Specific Personal Information) for the following purposes:

(1)	To manage information on the Investment Corporation's unitholders, analyze their attributes, and disclose their data (the Investment Corporation will not disclose any information in such method as allows personal identification, except for major (top ten) unitholders, which are posted on the website, etc. of the Investment Corporation)
(2)	To perform tasks related to the unitholders' exercise of their rights and the Investment Corporation's fulfillment of its obligations to the unitholders under provisions of laws and regulations, including the dispatch of asset management reports, convocation notice of unitholders' meetings, and payment of distributions
(3)	To perform tasks related to research and analysis (including, but not limited to, identity verification, credit research, and rights research) that are necessary for the Investment Corporation to consider the acquisitions and sales of real properties, trust beneficiary interests in real properties as trust assets (hereinafter “real property trust beneficiary interests”, and real properties as trust assets for real property trust beneficiary interests are hereinafter referred to as “real properties in trust”), and other assets, and the performance of agreements (including communications, inquiries, and registration) related to such acquisitions and sales
(4)	To perform tasks related to research (including, but not limited to, identity verification and credit research) that are necessary for considering the leasing of real properties, real properties in trust, and other assets owned by the Investment Corporation (hereinafter “Properties Owned”), and the performance of agreements (including communications, inquiries, and registration) related to such leasing
(5)	To provide notification or communications to tenants regarding constructions, etc. for repairs, renovations of and additions to Properties Owned
(6)	To solicit purchases of Properties Owned
(7)	To conclude casualty insurance agreements related to Properties Owned
(8)	To perform tasks other than the above in relation to the management of Properties Owned
(9)	To perform tasks including communicating with Customers, responding to Customer inquiries and document requests, and preparing response records, etc.
(10)	To raise funds by issuing investment corporation bonds and additional investment units and borrowing funds, and through other means
(11)	To perform operations related to the settlement of accounts and other operations related to accounting and tax affairs of the Investment Corporation
(12)	To perform operations related to the steps taken to facilitate relations with unitholders and potential unitholders of the Investment Corporation (including providing information)
(13)	To verify the identities of the counterparties of transactions according to the Act on Prevention of Transfer of Criminal Proceeds
(14)	To use personal information for market analysis, customer satisfaction surveys, or research and analysis for product development in association with the items above
(15)	To request advice from experts (including lawyers, certified public accountants, certified public tax accountants, real-property appraisers, and judicial scriveners)
(16)	To perform obligations of the Investment Corporation, exercise rights of the Investment Corporation, and perform tasks incidental to these tasks
(17)	To provide personal information to third parties to the extent necessary for the appropriate execution of operations by the Investment Corporation
(18)	To perform other operations incidental or related to the items above

Contact for Inquiries about Request for Disclosure, etc. of Retained Personal Data, Measures Taken by the Investment Corporation for Security Control of Personal Data, and Other Inquiries about Personal Information

(1) Request for Disclosure, etc. of retained personal data, inquiries about measures taken by the Investment Corporation for security control of personal data and other inquiries about personal information

Name	Activia Management Division of TLC REIT Management Inc. (TLC REIT Management Inc. is the asset manager for the Investment Corporation)
Address	21-1 Dogenzaka 1-chome, Shibuya-ku, Tokyo
Main telephone number	+81-3-6455-3377 Please say, “Contact for inquiries about personal information.”
Business hours	9:30 a.m. to 6:00 p.m. (except for Saturdays, Sundays, public holidays, and year-end and New Year holidays, etc.)

(2) Contact for inquiries about corrections, additions to or deletions of matters included in the unitholders’ registry

Name	Stock Transfer Agency Business Planning Dept. of Sumitomo Mitsui Trust Bank, Limited (Sumitomo Mitsui Trust Bank, Limited is the administrator of the unitholders' registry, etc. of the Investment Corporation)
Tel	0120-782-031 (toll-free, available within Japan only)
Business hours	9:00 a.m. to 5:00 p.m. (except for Saturdays, Sundays, public holidays, and year-end and New Year holidays, etc.)

This privacy policy may be revised when applicable laws, regulations, etc. and guidelines are amended, when the Investment Corporation's internal rules are amended, or when the Investment Corporation otherwise considers such revisions necessary.