1. Declaration of Compliance with the Related Laws and Regulations

This Company, recognizing the importance of its corporate social responsibility to properly handle our customers’ personal information and to protect each customer’s privacy, hereby promises that it shall comply with the Act on the Protection of Personal Information (the “Law”) and any other related laws and regulations, as well as complying with contractual confidentiality obligations.

2. Definitions of the Terms in this Policy

The following terms in this Policy shall have the meanings as described below:

（1） Personal Information

“Personal Information” is the information handled by this Company about our customers, such as their names, addresses, telephone numbers, e-mail addresses, places of employment, details of inquiry histories, or any such information which can be used independently or in combination to specify or identify any specific individual customer.

（2） Personal Data

“Personal Data” is systematically organized Personal Information which enables to search for or specify any individual customer through computer programs or other methods.

（3） Retained Personal Data

“Retained Personal Data” is the Personal Data over which this Company has the authority to comply with requests for disclosure, to correct, to add to or delete the content, to suspend its use, to erase, or to terminate its disclosure to third parties, excluding any data retained by this Company for a period less than six (6) months and any data specified in the laws and regulations as data which will be excluded from the definition of retained personal data under Article 2, Paragraph 5 of the Law.

3. Purposes of Use of Personal Information

This Company shall handle Personal Information for the purposes (the “Purposes of Use”) described below and shall not handle Personal Information beyond the scope necessary to achieve the Purposes of Use:

• To perform duties for a customer, to communicate with a customer for business purposes or to perform customer management, in relation to the investment advisory and discretionary investment management businesses under investment advisory agreements, or discretionary investment agreements;
• To solicit, to market, to sell and to purchase securities, financial products and other transactions, and to make reports and announcements regarding the services offered by this Company;
• To execute a customer’s rights or obligations provided for under the law or any agreements, with respect to dividends and/or redemption proceeds from the securities and/or financial products handled by this Company;
• To verify the identity of any customers, including verification of the person(s)-in-charge of corporate customers and the agents thereof;
• To properly perform services entrusted by any special purpose companies (tokutei mokuteki kaisha etc.,) managed by this Company;
• To perform due diligence services with regard to the real properties/ trust beneficiary interests for real properties obtained by any special purpose companies (tokutei mokuteki kaisha etc.,) managed by this Company;
• To perform property management services/leasing services with regard to the real properties/ trust beneficiary interests for real properties retained by any special purpose companies (tokutei mokuteki kaisha etc.,) managed by this Company;
• To perform the internal duties of this company such as market research, research and development of financial products, securities and services;
• To perform the internal management duties of this company;
• To perform the duties required by the shareholders of this Company;
• To manage the employees of this Company and its affiliated companies; and
• To properly and smoothly perform transactions with our customers, in addition to the above.

4. Providing Personal Data to Third Parties

Except in the following cases, this Company shall not provide Personal Data to any third party without obtaining the prior consent of the customer.

• Cases in which the disclosure to any third parties is set forth in the Purposes of Use;
• Cases in which this Company entrusts the handling of Personal Data to any third parties within the scope necessary to achieve the Purposes of Use;
• Cases in which Personal Data is provided as a result of the take-over of business in a merger, absorption-type company split or otherwise;
• Cases in which Personal Data is used jointly between specific individuals or entities;
• Cases in which this Company cooperates with an inquiry or investigation made by a governmental authority, such as the tax office, the police, courts, etc.;
• Cases in which Personal Data is provided to a third party in a condition where identification of a specific individual has been disabled; and
• Cases in which such a provision is permitted under related laws and regulations, in addition to the above.

5. Sharing of Use within the Group

Any Personal Data, such as names, addresses, telephone numbers, etc., may be shared by and among this Company’s group companies described below, within the scope necessary to achieve the objectives set forth in the above Section 3. In this case, such shared customer information shall be protected by and among the relevant group companies in the same manner as by this Company. Any customer information provided to the group company(ies) for the purpose of joint use shall be managed at the responsibility of the group company(ies) to which the relevant information is provided; and that this Company shall bear the ultimate management responsibility therefor.

Group Companies:
Simplex Investment Advisors Inc.
SIA Solutions Inc.
Simplex REIT Partners Inc.

6. Notice or Announcement of the Purposes of Use of Personal Information

This Company shall announce the Purposes of Use of Personal Information retained by this Company by posting on its Home Page, by maintaining documents at its Head Quarters, and other such methods to ensure the Purposes of Use of Personal Information is in an accessible condition.

7. Acquisition of Personal Information

This Company shall not employ fraudulent or otherwise dishonest methods to acquire Personal Information.

8. Sensitive Information

This Company shall not acquire, use or provide to third parties any information regarding a customer’s political opinions, beliefs (including religious, ideological and principle), labor union membership, race, ethnicity, lineage, legal domicile, medical records, sexual orientation, and criminal history (collectively, the “Sensitive Information”), except for the cases described below:

• Cases in which the handling of such information is based on laws and regulations;
• Cases in which handling the Sensitive Information is necessary for the protection of the life, body or property of an individual;
• Cases in which handling the Sensitive Information is specifically necessary for improving public hygiene or promoting the sound growth of children;
• Cases in which handling the Sensitive Information is necessary for cooperating with a governmental institution, a local public body or an individual or entity entrusted by the government of the local public body to perform the duties provided for under the laws;
• Cases in which the acquisition, use or disclosure to any third party of the Sensitive Information regarding any employee(s)’ membership in any political or religious organization or labor union is within the scope necessary for performing such duties as tax withholding, etc.;
• Cases in which acquisition, use or disclosure to any third party of the Sensitive Information is within the scope necessary to carry out inheritance procedures, such as transfers of rights and obligations;
• Cases in which acquisition, use or disclosure to any third party of the Sensitive Information is necessary to secure this Company’s proper business operations, within the scope necessary for the business execution and with the consent of the relevant customer;
• Cases in which handling any biometrics authentication information that falls under the Sensitive Information is used to identify a customer, with the consent of the relevant customer; and
• Cases in which handling the Sensitive Information is required for the management of the employees of this Company and/or any of its affiliated companies.

9. Ensuring Accuracy of Personal Data

This Company shall endeavor to maintain accurate and up to date Personal Data within the scope necessary to achieve the Purposes of Use thereof. Furthermore, this Company shall establish a preservation period of Personal Data in accordance with the Purposes of Use thereof, and delete any Retained Personal Data after such relevant preservation period elapses unless otherwise provided for in the applicable laws and regulations.

10. Declaration of Secure Management of Personal Data

To prevent leakage, loss or damage of Personal Data, and for other security controls for the Retained Personal Data, this Company shall take any and all necessary and appropriate measures, such as the preparation of handling rules for Personal Data and a system of security controls for the Retained Personal Data, etc., in addition to the establishment of this Policy.

11. Disclosure, Correction, and Stopping the Use of the Retained Personal Data,.

This Company recognizes that a customer who has provided Personal Information has the right to request this Company to disclose, correct, stop use of, delete, etc. the Retained Personal Data with respect to him/her, and this Company shall promptly respond to such customers’ requests for disclosure, correction, stopping of use, deletion, etc., in compliance with the relevant laws and regulations.

12. Providing Retained Personal Data to an entrusted Contractor(s)

This Company may entrust a third party(ies) with the handling of the whole or a part of the Personal Data, within the scope necessary to achieve the Purposes of Use. In the event of such entrustment in whole or in part of the Personal Data, this Company shall exercise the necessary and appropriate supervision over the relevant entrusted party(ies), to ensure the control of security of the Personal Data entrusted to such party(ies).

13. Inquiries about Personal Information

Please contact the address below if you would like to request a disclosure or correction of Personal Information or to make any comment or inquiry with regard to the handling of Personal Information outlined in this policy:

Information Security Office
Simplex Real Estate Management Inc.　　　Tel.: +81-3-5218-8321

14. Changes to this Policy

The contents of this Policy shall be deemed effective as of the date of posting of this Policy on this website. This Policy is subject to change without notice, being in compliance with laws and regulations or upon recognition of such necessity by this Company.

This Company has adopted this Policy on the Protection of Personal Information as above.

Entity Handling Personal Information
Simplex Real Estate Management Inc.