Privacy Policy

I. Basic Policy

In handling personal information, Sekisui House Reit, Inc. (“Sekisui House Reit”) shall comply with the Act on the Protection of Personal Information (hereinafter, the “Personal Information Protection Act”), Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (hereinafter, the “Number Use Act”) and other relevant laws and regulations as well as guidelines, and strive for proper and safe management and administration in the handling of personal information. Out of the terms used in this Privacy Policy, those shared with relevant laws and regulations shall follow the definitions thereof.

II. Purpose of Use

1. Purpose of Use of Personal Information

The personal information Sekisui House Reit collects mainly relates to the holders of the securities it issues, the tenants of its investment assets, and its business partners.

Sekisui House Reit may use personal information for the following purposes:

  1. to exercise rights of unitholders and investment corporation bond holders, fulfil obligations of Sekisui House Reit and conduct other arrangements for the unitholders and the investment corporation bond holders;
  2. to implement measures to facilitate interaction with unitholders and investment corporation bond holders;
  3. to prepare the unitholders registry and the registry of investment corporation bond holders, prepare and file various statutory reports, and manage unitholders' and investment corporation bond holders' information;
  4. to collect, tally and analyze data in order to provide certain information to potential purchasers of investment units, investment corporation bonds and other securities that were or will be issued by Sekisui House Reit;
  5. to collect and analyze data related to acquisition of investment assets by Sekisui House Reit, conduct surveys and investigations related to the acquisition and solicitation of potential buyers of such assets, and to smoothly execute selling activities;
  6. to properly implement leasing operations of Sekisui House Reit's investment assets (including use for questionnaire surveys, etc. conducted to enhance the convenience, etc. for the users of such assets);
  7. to outsource to such professionals as attorneys, certified public accountants, real estate appraisers, judicial scriveners and land and building inspectors, for the implementation of business by Sekisui House Reit;
  8. to conduct borrowing of funds, issuance of investment corporation bonds and issuance of investment units for the acquisition and management of assets by Sekisui House Reit;
  9. to appropriately and smoothly implement other operations of Sekisui House Reit

2. Purpose of Use of Individual Numbers

Notwithstanding the provisions of 1. above, Sekisui House Reit may use individual numbers for the following purpose:

  1. 1. Individual numbers of clients, business partners and unitholders
  2. (a) to prepare reports on financial instruments transactions, etc.;
  3. (b) to prepare payment reports concerning payments of fees, charges, contract money, awards and other services, or of compensation of rights;
  4. (c) to prepare payment reports concerning payments of compensation for use or transfer of real estate;
  5. (d) to prepare payment reports concerning payments of cash distributions, surplus or interests, etc., and distribution of other profits;
  6. (e) to prepare reports concerning grant or exercise of unit acquisition rights of Sekisui House Reit’s investment units, or allotment of investment units without contribution;
  7. (f) other work related to items (a) through (e) above;
  8. (g) to prepare statutory reports and such that require individual numbers pursuant to laws and regulations
  9. 2. Individual numbers of Sekisui House Reit’s executive officers and their relatives
  10. (a) to prepare certificates of tax deductions pertaining to employment income and retirement income, prepare salary payment reports, submit reports of exemption (charge) for dependents, etc., submit insurance premium deductions and special tax exemptions for spouses of salary earners, and other work concerning tax withholding, etc.;
  11. (b) to notify and file applications concerning health insurance, employees' pension insurance, employment insurance and other social insurance and labor insurance, or corporate pension (including third insured persons under the National Pension Act);
  12. (c) Other work related to items (a) and (b) above

Furthermore, Sekisui House Reit shall use personal information to the extent necessary to achieve the above purposes of use, and shall not use it for any other purposes. In addition, Sekisui House Reit will not revise the purposes of using personal information beyond the scope reasonably acceptable and for the initial purpose of use.

III. Collection

1. Collection of Personal Information

Sekisui House Reit shall collect personal information in a lawful and fair manner to the extent necessary to achieve the purposes of its use. In addition, Sekisui House Reit shall disclose the purposes of use on its website before independently obtaining personal information, or acquiring such information from the property management companies that manage its investment assets. Sekisui House Reit shall also clearly indicate the purposes of use in advance in the event that it obtains personal information of individuals described in contracts or other documents (including electronically prepared records) upon executing such contracts with the said individuals, or when it directly collects personal information from individuals in writing or through electronic means, etc. However, indication of the purposes of use may be omitted if they are clearly understood from the circumstances in which such information is provided, or if such omission is permitted by laws and regulations. Sekisui House Reit shall not collect, use or provide to any third party sensitive information unless otherwise permitted by relevant laws and regulations, guidelines, etc.

2. Collection of Individual Numbers

Notwithstanding the provisions of 1. above, Sekisui House Reit may request individual numbers from individuals or other persons in charge of affairs related to the individual number only when it is necessary to conduct work stipulated in II-2. Requests for individual numbers shall be made when necessity for conducting such work arises or when arising of such is anticipated.

3. Identity Confirmation

Upon receiving individual numbers, identity confirmation shall be carried out through methods stipulated under Article 16 of the Number Use Act. In case of receipt from a proxy, the identity of the proxy, the right of representation and his/her individual number shall be confirmed through methods stipulated under the said article.

IV. Provision to Third Parties

1. Provision of Personal Data to Third Parties

Sekisui House Reit shall not provide any personal data to any third party without obtaining consent from the individual in advance, except for cases stated in items under Article 23, Paragraph 1 of the Personal Information Protection Act.

2. Provision of Specific Personal Information to Third Parties

Sekisui House Reit shall not provide specific personal information to any third party except for cases stated in items under Article 19 of the Number Use Act.

V. Securing of Accuracy, etc.

Sekisui House Reit strives to keep personal data both accurate and updated to the extent necessary to achieve the above purposes of use, and to delete such data without delay when its use is no longer necessary.

VI. Security Management of Personal Information

Sekisui House Reit will take necessary and appropriate measures to secure proper and safe management of personal data and to prevent unauthorized external access to personal data and unauthorized use, loss, destruction, falsification and leakage, etc.

VII. Outsourcing of Handling of Personal Data

Sekisui House Reit may outsource the handling of personal data it retains to external operators. When outsourcing handling of personal data in whole or in part, Sekisui House Reit will carefully select and enter into outsourcing contracts with such external operators on the condition that they have established and are implementing a management system to appropriately protect personal data. In addition, Sekisui House Reit will conduct necessary and appropriate supervision over such external operators to ensure safety management of personal data.

VIII. Ongoing Improvements

Sekisui House Reit shall establish internal regulations related to personal information, including this Privacy Policy, and strive to improve them through ongoing revisions. Moreover, Sekisui House Reit may revise this Privacy Policy, as necessary, in response to amendments to laws and regulations and other changes.

IX. Responses to Requests for Disclosure, etc.

For requests for notification of purpose of use, disclosure, correction, addition or deletions of personal data retained by Sekisui House Reit, or for suspension of use, provision to any third party or erasing of such data by Sekisui House Reit, relevant individuals may contact and request at the following. Upon such requests, appropriate actions shall be taken within a reasonable time frame after confirming the identity of the individuals who made the request (In the case of contact via a proxy, appropriate actions shall be taken within a reasonable time frame after confirming the proxy's identity.). For inquiries regarding this Privacy Policy, please also contact the following.

Contact

Name General Affairs and Accounting Department, Management Division
Sekisui House Investment Advisors, Ltd.
(Asset management company for Sekisui House Reit)
Address 1-6-6 Motoakasaka, Minato-ku, Tokyo
Zip Code:107-0051
Phone +81-3-6447-4870 (business hours: 9:00 a.m. – 6.00 p.m. on weekdays)

For inquiries regarding matters recorded in the unitholders registry and personal information regarding administrative services, please contact the following:

Contact

Name Stock Transfer Agency Department
Mizuho Trust & Banking Co., Ltd.
Address 1-2–1, Yaesu, Chuo–ku, Tokyo, Japan
Zip code: 103-8670
Phone 0120–288–324 (Toll Free only in Japan)
Hours of Operation 9:00 a.m. – 5:00 p.m. (excluding Saturdays and Sundays, public holidays, year-end and new year holidays, etc.)