Personal Information Protection Policy

Asia Pacific Land (Japan) Limited, Japan Branch
Yoshinobu Takahara and Yasuhiro Hayashi,
Representatives in Japan
Akasaka Tameike Tower 9th Fl.
2-17-7 Akasaka, Minato-ku, Tokyo

Article 1 (Personal Information Protection Policy)

As a corporation engaged in the financial instruments business, real estate business, and real estate asset management and investment business, Asia Pacific Land (Japan) Ltd. (“APL” or the “Company” or “we”) recognizes that the protection of personal information is an important social responsibility of the Company. In all of APL’s business operations that involve personal information, protection of such information is considered as one of the top-priority issues. To protect personal information in a proper and reliable manner, APL specifies the following policy and all employees of APL shall abide by this policy to properly handle and manage personal information both inside and outside the Company.

1. Matters Relating to Collection, Use and Disclosure of Personal Information.

If personal information is collected, it must be done in accordance with appropriate procedures and if such information is to be maintained or used in any way beyond what is needed to achieve the specified purposes (as set forth in Article 2) unless otherwise permitted by law, such information must only be used after consent is obtained from the owner of such information (or from the requester with the owner’s consent). Subject to certain disclosures described in Articles 3 and 4 below, consent must also be obtained when collected personal information is disclosed to a third party unless such disclosure is otherwise permitted by law.
If, with respect to the personal information collected, the owner (or the requester with the owner’s consent) requests notice concerning the purposes of use of retained personal information, disclosure of retained personal information, disclosure of records on third party provision of retained personal information, correction, addition, or deletion (collectively, “Amendments etc.”) of retained personal information, suspension of use or erasure of retained personal information (“Suspension of Usage etc.”), or suspension of third party provision of retained personal information, the Company shall act in accordance with the provisions of Article 6.
With respect to “Specified Personal Information” (i.e., personal information which includes individual numbers (the so-called “My Number”) in its contents) handled by the Company, the same protections set forth below shall apply and internal rules shall be established in relation thereto; such individual numbers must be obtained and managed in accordance with the appropriate purposes of use and through appropriate methods.

2. Matters Relating to Security of Personal Information

The Company takes the following security management measures.

(1) Organizational security management measures

The Company shall designate a Personal Information Manager and limit the number of persons handling personal information to the required minimum. The Company has also established a system for employees to report on incidents of leakages, etc. of personal information whenever they become aware of such incidents.

(2) Human security management measures

The Company’s Internal Control & Compliance Department periodically and at all times whenever necessary provides information and host training sessions for the Company’s employees concerning matters to be noted when handling personal information. The employees are also required to assume confidential obligations towards other employees pursuant to work rules and other provisions.

(3) Physical security management measures

The Company controls access to the Company’s offices by IC cards and prohibits those to whom IC cards are not issued from entering our offices. The devices, etc. that may be brought into the Company’s offices will be restricted by a policy to be separately formulated which will, in particular, strictly restrict the use of devices, etc. brought in to our offices by external parties.

(4) Technical security management measures

The Company restricts access to personal information database, etc. in the information system by allowing access only to responsible personnel and certain employees to prevent unspecified persons from accessing the same. Furthermore, to prevent unauthorized access by external parties, the Company uses appropriate firewalls, anti-virus software, and automatic update functions to maintain and manage our personal information database, etc. The Company shall also undertake to prevent or correct leakage, loss or damage of personal information and implement the necessary and appropriate security management measures.

(5) Updates on legislations in foreign countries

The “APL Group”, which consists of Asia Pacific Land Ltd. (which is located in Hong Kong), APL (New York) Corporation (which is located in New York), the Company and other affiliates of the foregoing companies may handle personal information retained by the Company at the APL Group’s Hong Kong and U.S. locations (in, for example, the States of California and New York). Therefore, the Company takes security management measures to maintain a good grasp of the personal information protection systems of these two countries such as by receiving information from the local APL Group member companies.

3. Matters Relating to Complaint or Consultation from the Owner

If the owner lodges a complaint or request to or consults APL as to what we are doing to protect personal information, the Personal Information Desk will explain the details to the owner and attend to the matter diligently, while the Manager will take appropriate action.

4. Matters Relating to Laws, National Guidelines and Other Standards on Handling Personal Information

In addition to abiding by the applicable laws, national guidelines, ordinances or other standards on handling personal information, we shall also set forth internal regulations to abide by the foregoing, review these regulations as necessary and make continuous improvement thereof, and implement the regulations properly.

5. Matters Relating to Continuous Improvement of Personal Information Protection/Management System

The Company shall conduct regular internal audits on the implementation conditions of 1, 2, 3 and 4 above. Should any noncompliance occur, we will identify and implement corrective measures as necessary as part of our effort to improve the system continuously.

This policy is posted in the Company and communicated to all employees including officers. We shall also work to educate and edify employees and raise their awareness of the need to protect personal information.

Article 2 (Purposes of Use of Personal Information)

The purposes of use of personal information are as follows:

Business relating to execution of contracts relating to acquisition, management and disposition of real estate etc. (including trust beneficial interests etc.) and provision of services and information in connection therewith
Business relating to execution of contracts related to sales, brokerage, financing and maintenance of real estate etc. and provision of services and information in connection therewith
Business relating to execution of contracts relating to consulting and advisory services and the provision of services and information in connection therewith
Business relating to execution of contracts relating to provision of due diligence services (real estate and loan valuations or pricing analysis) and the provision of services and information in connection therewith
Marketing activities to enhance the value of real estate that is the subject of asset management agreements executed by the Company
Grasp the contents of business conducted by the companies, etc. in which the Company invests in
Administration of the shareholders of the Company and other group companies of the APL Group.
Administration of counterparties of the APL Group on behalf of the APL Group
Administration relating to the APL Group directors, officers, employees and contract employees
Administration related to recruitment and hiring of directors, officers and employees
Communications and contact through written documentation, mail, telephone, fax or electronic mail in connection with all of the above
To provide third parties with personal information if necessary to achieve the above purposes (as stated in Article 3; provided, however, that Specified Personal Information shall be excluded)

The information used is as follows:

Proprietary information of the owner concerned (Name, address, telephone number, gender, date of birth, place of employment, etc.)
Information relating to loan claims (date of contract, loan claims principal, agreed amount of repayment, history of deposits, etc.)
Information relating to real estate-related contracts or agreements (date of contract, terms and conditions, status of enforcement of Lease Agreements, Purchase and Sale Agreements for Real Estate, finance documents related to real estate, etc.)
The owner’s appearance, history of visits made to stores, history of their movements inside the stores and products that they showed interest in, history of purchases, and presumed appellation (gender and age, etc.) (Video records of the insides of commercial facilities, accommodations, logistic centers, and other facilities relating to investments made by the Company.)
Information concerning the contents of business of companies, etc. in which the Company invests in ( information of (a) to (d) above, etc.)
Other information concomitant with (a) to (e) above (real-estate evaluation information/other assets-held information, etc.)

Notwithstanding the purposes for utilizing personal information as stated in the preceding items, the purpose of using Specific Personal Information is to manage administrative matters related to our employees, our employees’ spouses and dependents, and persons other than employees related to the administration of real estate etc. within the scope of applicable laws and regulations.

Article 3 (Disclosure of Personal Data to Third Parties)

There are circumstances from time to time where Personal Data, other than Specified Personal Information, such as real estate information, names, addresses and related family information, will be disclosed to third parties through written documentation, mail, telephone, fax, electronic mail, advertisement, or by other means, as may be permitted by applicable laws and regulations and to the extent necessary to achieve the purposes outlined above.

APL will refrain from any such disclosure upon request or application via a telephone call to the contact person described in Article 6 from the persons related to such Personal Data to the extent such person has not separately agreed to permit such disclosure to third parties.

Examples of Third Party Disclosure * Please note that this list of examples is not intended to be exhaustive or comprehensive and is for illustrative purposes only

Disclosure to a transaction or contractual party, or someone likely to become such party
Other Type 2 Financial Instruments and Exchange Act license holders and real estate brokerage license holders
Internet advertisements and other industry-related and group bulletin boards
Designated distribution systems (real estate registrations, notice, etc.)
Judicial scriveners and specialists in connection with registration matters
Trusts, trust banks, financial institutions, financial instruments license holders, money lending license holders, etc.
Property managers in connection with property management, financial institutions receiving fund transfers, administrative personnel
Professional advisors such as lawyers, public accountants, tax advisers, appraisers, insurances providers, etc.
Real estate information and survey providers
National and local governments and other service providers
APL Group counterparties and business partners

Article 4 (Shared Use of Personal Data)

Personal Data collected in connection with recruiting and hiring APL Group directors and officers may be shared; provided that Specified Personal Information shall be excluded.

Personal Information subject to Shared Use
APL Group director and employee information collected in connection with recruiting and hiring including name, address, telephone number, e-mail address and family information
Extent of Shared Use
APL Group subsidiaries, affiliates and related companies
Purpose of Shared Use
Employee screening and review for purposes of APL Group recruiting and hiring
Responsible Person, Address, and Representative
Responsible Person:
Asia Pacific Land (Japan) Limited, Japan Branch
Yasuhiro Hayashi, a Representative in Japan
Akasaka Tameike Tower 9th Fl.
2-17-7 Akasaka, Minato-ku, Tokyo

Article 5 (Provision to a Third Party in a Foreign Country)

When sharing Personal Data within the APL Group, the Company may transfer Personal Data to Asia Pacific Land Ltd. in Hong Kong, APL America Investments Ltd. (California, U.S.A.), and APL (New York) Corporation (New York U.S.A.). Please refer to the webpages below set up by the Personal Information Protection Commission in Japan on the systems to protect personal information in the aforesaid regions.

Hong Kong: https://www.ppc.go.jp/files/pdf/hongkong_report.pdf
U.S.A.: https://www.ppc.go.jp/files/pdf/USA_report.pdf
State of California: https://www.ppc.go.jp/files/pdf/california_report.pdf
State of New York: https://www.ppc.go.jp/files/pdf/newyork_report.pdf

The Company acquires information from the above three companies in accordance with the applicable personal information protection legislations in Hong Kong and the U.S.A. (federal, State of California, and the State of New York). The Company will explain to owners separately in writing before we acquire personal information concerning changes, if any, to the said personal information protection legislations from the contents publicized on the above webpages, and the contents of safety management measures that are taken by the companies to whom Personal Data are transferred to.

Furthermore, Asia Pacific Land Ltd., APL American Investments Ltd., and APL (New York) Corporation to whom Personal Data is transferred, shall take measures to comply with the eight principles of OECD’s privacy guidelines, including measures to respond to requests based on owner’s rights.

Article 6 (Requests for Disclosure, Amendments etc., Suspension of Usage etc.)

In cases where the owner concerned requests such actions such as notice on the purposes of use of retained Personal Data, disclosure, Amendment etc., or Suspension of Usage etc. of retained Personal Data, or disclosure of records on third party provision of retained Personal Data, or suspension of third party provision of retained Personal Data, the identity of the said owner shall be confirmed and, unless there is a specific reason not to do so, the requested action shall be taken promptly in full compliance with the law.

Applications for such procedure must be submitted in the format prescribed by the Company.

All other inquiries regarding personal information should be directed as detailed hereunder.

Please also note that the requested information disclosure shall, as a basic rule, be forwarded by postal mail. However, we may disclose information by electronic means.

In addition, we cannot disclose personal information because we have assumed confidentiality obligations towards the provider of the same.

Article 7 (Contact for Personal Information Related Matters)

The administrator of personal information within the company and contact information is detailed below.

Hotline for complaints and consultation regarding personal information:

Asia Pacific Land (Japan) Limited, Japan Branch
Internal Control & Compliance Department
03-4560-7000 (Reception Time 10:00 to 17:00, Business Day)

Supplementary provision:
This policy was established on September 1, 2008.

Supplementary provision:
This policy was amended on May 30, 2017.

Supplementary provision:
This policy was amended on April 1, 2022.