Established on December 12, 2012
Revised on December 22, 2015
Revised on May 30, 2017
Revised on August 14, 2017
Revised on April 1, 2022
Revised on December 12, 2022
1. Basic Policy
The Investment Corporation shall comply with rules such as the Act on the Protection of Personal Information (the "Personal Information Protection Act"), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the "My Number Act"), other related laws and regulations, guidelines issued by the controlling public agencies, and other applicable rules. Also, the Investment Corporation shall appropriately address complaints regarding the handling of personal information.
2. Acquisition of Personal Information
- The Investment Corporation shall acquire personal information by legitimate and appropriate methods to the extent necessary to achieve the purpose of use stated in Article 3 below. In addition, the Investment Corporation shall not acquire personal information by deception or other improper means.
- The Investment Corporation shall, upon acquiring personal information, publicly announce the purpose of use in advance, or notify the person of the purpose of use or publicly announce the purpose of use promptly after acquiring such information. Furthermore, when the Investment Corporation acquires personal information written on documents directly from a person, the Investment Corporation will expressly notify the person of the purposes of its use in advance. However, the notification, the public announcement or the express notification of the purpose of use may be omitted in the event that the purpose of use is apparent considering the circumstances of the acquisition of the information or if it is otherwise permitted to do so under the laws and regulations.
- Notwithstanding the above, the Investment Corporation shall acquire no "special care-required personal information" as defined under the Personal Information Protection Act without the prior consent of the person related to such information unless such acquisition is treated as an exception by laws and regulations. The Investment Corporation shall acquire no "sensitive information" as defined in the Guideline on Protection of Personal Information in the Financial Industry unless such acquisition is treated as an exception under the Guideline.
3. Purpose of Use of Personal Information
- The Investment Corporation shall, excluding those cases where prior consent has been obtained from the relevant person or where it is treated as an exception by the laws and regulations, etc., use personal information only to the extent necessary to achieve the purpose of use provided below. In addition, the Investment Corporation shall not use personal information in a way that may promote or induce illegal or unjust acts.
- Exercise of rights of unitholders and performance of obligations of the Investment Corporation under the Act on Investment Trusts and Investment Corporations (the "Investment Trust Act") and other rules and regulations, etc.
- Management of unitholders' information, including generating data, such as the list of unitholders that is prepared in accordance with the Investment Trust Act and other laws and regulations, etc.
- Borrowing of funds, issuance of investment corporation bonds and additional issuance of investment units, etc. of the Investment Corporation.
- Response to inquiries or requests for information materials, etc.
- Research analyses and studies, etc., for the management of the assets of the Investment Corporation.
- The acquisition and disposition of the assets by the Investment Corporation and the performance of the operations in relation to the lease and management of real estate.
- Performance of IR activities and of operations relating to general business matters etc., of the Investment Corporation.
- Performance of appropriate and smooth operations of the Investment Corporation.
- Implementation of businesses incidental or relating to each of the preceding items above.
- Notwithstanding the above, the Investment Corporation shall use any "Specific Personal Information, including the Individual Number of said Person" as defined in the My Number Act only to the extent necessary to achieve the purpose of use provided below:
- For creating legal statements and other documents on which the individual number of a person is required to be indicated by laws and regulations; or
- For administering withholding taxes, making reports, requests and any other documents in relation to social insurance programs, labor insurance programs, company pension plans or any other similar program.
4. Restriction on Provision of Acquired Personal Information to Third Parties
- The Investment Corporation will not provide or disclose personal data to any third parties without obtaining the prior consent of the relevant person, except in the following cases:
- Cases where disclosure is conducted in accordance with applicable laws and regulations
- Cases where the provision of personal data is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the relevant person
- Cases where the provision of personal data is specially necessary for improving public health or promoting the healthy growth of children and in which it is difficult to obtain the consent of the relevant person
- Cases where the provision of personal data is necessary for cooperating with a governmental organization, a local government, or someone acting at their request in conducting matters prescribed by laws and regulations, and there is a risk that obtaining the consent of the relevant person may become an obstacle to conducting such matters
- Cases where the Investment Corporation outsources the handling of personal data to a third party in accordance with Article 6 below
- Cases where the provision or disclosure of the personal data is permitted by the Personal Information Protection Act
- Notwithstanding the provisions above, if the Investment Corporation provides personal data to any third party outside Japan, the Investment Corporation shall obtain prior consent from the person related to such personal data unless such provision is permitted by law. The Investment Corporation will never provide the Personal Number and the Specific Personal Information to a third party, whether the relevant person provides his/her consent or not, with the exception of instances stipulated in laws and regulations.
5. Safe Management Measures
The Investment Corporation shall implement necessary and appropriate safe management measures (organizational safety management measures, human safety management measures, physical safety management measures, technical safety management measures and measures to understand the external environment) and manage personal information in compliance with laws and ordinances, guidelines, etc. in order to prevent divulgement, loss or damage of the personal data it handles and to otherwise safely manage the personal data. For specific details of safe management measures, please contact the inquiry desk listed in Article 9 below.
6. Outsourcing the Handling of Personal Data
The Investment Corporation may outsource the handling of personal data to third parties within the necessary scope to achieve the purposes of use. In that case, the Investment Corporation shall take the measures necessary to exercise appropriate management and supervision over such third parties.
7. Reporting of Leaks
The Investment Corporation shall report to the Personal Information Protection Commission in the event of any occurrence of the leaking, loss, impairment or the like of personal data handled by the Investment Corporation having a high risk of harming the rights and interests of an individual, as stipulated in the Enforcement Rules for the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Law Enforcement Rules”) pursuant to the provisions of the Personal Information Protection Law Enforcement Rules. However, when the Investment Corporation is entrusted with all or part of the handling of personal data by another business operator handling personal information and gives notice of such occurrence to the business operator handling the personal information pursuant to the provisions of the Personal Information Protection Law Enforcement Rules, this shall not apply.
In the above cases (except when the above notice is given), the Investment Corporation shall notify the person involved pursuant to the provisions of the Personal Information Protection Law Enforcement Rules. However, this shall not apply when it is difficult to notify the person and if necessary alternative measures are taken to protect the rights and interests of the person.
8. Procedures for Disclosure, etc. of Retained Personal Data
With respect to the personal data retained by the Investment Corporation, in the event of a request being received for notification of the purpose of use of the retained personal data, disclosure of the retained personal data, the making of corrections, additions or deletions to the retained personal data, discontinuance of use or destruction of the personal data, or suspension of provision of retained personal data to third parties or disclosure of records provided to third parties (hereinafter collectively referred to as “disclosure, etc.”), the Investment Corporation shall endeavour to provide an appropriate and speedy response in accordance with the laws and regulations, upon confirming that the request is made by the relevant person. Please direct any inquiries regarding this matter to the inquiry desk provided in Article 9 below. Please note that a request for disclosure of personal information may require payment of an actual fee.
9. Contact Information for Inquiries or Complaints regarding the Handling of Personal Information
Inquiries regarding the handling of personal information or the details of measures taken by the Investment Corporation for the safe management of retained personal data, requests for disclosure of retained personal data and complaints, etc. can be made as follows:
Please contact the inquiry desk below. You will be provided with information on the necessary procedures.
|GLP Japan Advisors Inc.
2-2-1, Yaesu, Chuo-ku, Tokyo 104-0028, Japan
Operating Hours：9:00 a.m. - 6:00 p.m.（except for Saturdays, Sundays, public holidays, and year-end and New Year's holidays）
For inquiries regarding information indicated in the shareholder register, please contact the following desk:
|137-8081 Shin-TOKYO Post Office post office box No.290
Telephone Center, Securities Agency Division
|Phone||+81-(0)42-204-0303 (only in Japanese)
Operating Hours: 9:00 a.m. - 5:00 p.m. (JST)
(except for Saturdays, Sundays and public holidays)
10. Name, address and name of representative of business operator handling personal information
|Address||2-2-1, Yaesu, Chuo-ku, Tokyo, Japan|
|Executive Director||Yoshiyuki Miura|
The Investment Corporation shall revise this Policy to continuously improve its content. This policy may also be revised due to amendments to the laws and regulations or other reasons.