Basic Policy

In handling personal information, Sekisui House Reit, Inc. (“SHR”) 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. Terms used in this Privacy Policy that are defined with relevant laws, regulations and guidelines shall follow those definitions.

Purpose of Use

1. Purpose of Use of Personal Information

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

SHR may use personal information for the following purposes:

1. to exercise rights of unitholders and investment corporation bond holders, fulfill obligations of SHR 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 SHR;
5. to collect and analyze data related to acquisition of investment assets by SHR, 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 SHR'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 SHR;
8. to conduct borrowing of funds, issuance of investment corporation bonds and issuance of investment units for the acquisition and management of assets by SHR;
9. to appropriately and smoothly implement other operations of SHR

2. Purpose of Use of Individual Numbers

Notwithstanding Section 1 above, SHR may use individual numbers for the following purpose:

1. Individual numbers of clients, business partners and unitholders
   1. to prepare reports on financial instruments transactions, etc.;
   2. to prepare payment reports concerning payments of fees, charges, contract money, awards and other services, or of compensation of rights;
   3. to prepare payment reports concerning payments of compensation for use or transfer of real estate;
   4. to prepare payment reports concerning payments of cash distributions, surplus or interests, etc., and distribution of other profits;
   5. to prepare reports concerning grant or exercise of unit acquisition rights of SHR’s investment units, or allotment of investment units without contribution;
   6. other work related to items (a) through (e) above;
   7. to prepare statutory reports and such that require individual numbers pursuant to laws and regulations
2. Individual numbers of SHR’s executive officers and their relatives
   1. 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.;
   2. to notify and file applications concerning health insurance, employees' pension insurance, employment insurance and other social insurance/labor insurance/corporate pension (including third insured persons under the National Pension Act), and defined contribution plans;
   3. Other work related to items (a) and (b) above

SHR shall use personal information to the extent necessary to achieve the above purposes of use, and shall not use it for any other purposes. Furthermore, SHR shall not use sensitive information unless otherwise permitted by relevant laws and regulations, guidelines, etc.

Collection

1. Collection of Personal Information

SHR shall collect personal information in a lawful and fair manner to the extent necessary to achieve the purposes of its use. SHR 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. SHR 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.
Additionally, SHR may receive personally referable information from a third party and acquire such information as personal data. In such a case, the consent of the individual, in principle, shall be obtained in writing, etc.

2. Collection of Sensitive Information

Notwithstanding Section 1 above, SHR shall not collect sensitive information unless otherwise permitted by relevant laws and regulations, guidelines, etc.

3. Collection of Individual Numbers

Notwithstanding Section 1 above, SHR 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 Section 2 of “Purpose of Use”. Requests for individual numbers shall be made when necessity for conducting such work arises or when arising of such is anticipated.

4. Identity Confirmation

Upon receiving individual numbers, identity confirmation shall be carried out through methods permitted under the Number Use Act and other applicable laws and regulations. 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.

Provision to Third Parties

1. Provision of Personal Data to Third Parties

SHR shall not provide any personal data to any third party without obtaining consent from the individual in advance, except for cases permitted under the Personal Information Protection Act and other laws and regulations.

2. Provision of Personally Referable Information to Third Parties

SHR shall not provide personally referable information to any third party without confirming that the individual’s consent has been obtained in advance.

3. Provision of Sensitive Information to Third Parties

Notwithstanding Section 1 above, SHR shall not provide sensitive information to any third party unless otherwise permitted by relevant laws or regulations, guidelines and other applicable rules.

4. Provision of Specific Personal Information to Third Parties

Notwithstanding Section 1 above, SHR shall not provide specific personal information to any third party except for cases permitted under the Number Use Act and other laws and regulations.

5. Provision of Personal Data and Personally Referable Information to Third Parties Located in a Foreign Country

When providing personal data or personally referable information to a third party in a foreign country, SHR shall comply with the obligations stipulated by relevant laws and regulations, guidelines and other applicable rules.

Securing of Accuracy, etc.

SHR 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.

Pseudonymously Processed Information and Anonymously Processed Information

When handling pseudonymously processed information or anonymously processed information, SHR shall comply with the obligations stipulated by relevant laws and regulations, guidelines, etc.

Secure Management of Personal Information

SHR has established the “Personal Information Management Regulations” and has taken all necessary and appropriate measures to prevent the leakage, loss or damage of personal information it handles, and to ensure the secure management of such information. In addition, pursuant to these regulations, SHR has entrusted the handling of all personal data to Sekisui House Asset Management Ltd. (“SHA”). SHA shall appropriately and securely manage personal data and take the necessary measures (It includes necessary and appropriate measures to prevent leakage, etc. of personal information that SHR has obtained or attempts to obtain and that SHR plans to handle as personal data. The same applies hereinafter.) as follows to prevent unauthorized outside access to personal data and unauthorized use, loss, destruction, alteration, and leakage thereof.

1. In order to ensure the proper handling of personal data, SHA shall formulate and comply with the “Personal Information Protection Regulations” and “Personal Information Protection Rules”.
2. SHA shall formulate and comply with the rules for the handling of personal data for each stage including acquisition, use, transfer, storage and deletion, with respect to the handling methods, persons in charge, and their duties.
3. SHA shall appoint a person in charge of the handling of personal data and regularly inspect and audit the status of the handling of personal data. In addition, SHA will report the results to the person in charge, and establish a system in which they can evaluate, review, and improve the secure management of personal information.
4. A confidentiality agreement will be concluded with all employees, and measures for the secure management of personal information will be thoroughly disseminated for their education and training.
5. In areas where personal data is handled, SHA shall manage the entry and exit of employees and implement measures to prevent theft, etc.
6. Information systems that handle personal data shall be equipped with an identity verification function and access privileges will be set as necessary, in addition to the introduction of a mechanism to protect against unauthorized access or software from the outside.
7. When handling personal data in a foreign country, SHA shall implement the necessary security control measures after understanding the system for the protection of personal information in the country or region where the personal data is to be handled.

Additionally, in accordance with the Personal Information Protection Act, SHR shall provide individuals with information regarding the security measures implemented by SHA upon request.

Outsourcing of Handling of Personal Data

SHR may outsource the handling of personal data it retains to SHA or other third parties. When outsourcing handling of personal data in whole or in part, SHR 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, SHR will conduct necessary and appropriate supervision over such external operators to ensure safety management of personal data.

Ongoing Improvements

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

Responses to Requests for Disclosure, etc.

Requests to SHR for notification of the purpose of use of personal data; disclosure, correction, addition, or deletion of such data; suspension of use; suspension of provision to third parties; erasure of such data; or disclosure of records regarding the provision of personal data to third parties may be submitted to the contact point listed below. 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 details on procedures concerning disclosure of personal data or for inquiries regarding this Privacy Policy, please contact us at the following:

Contact Information

Contact	General Affairs Department Sekisui House Asset Management, Ltd. (Asset management company of SHR)
Address	4-15-1, Akasaka, Minato-ku, Tokyo, Japan Zip Code:107-0052
Phone	+81-3-6447-4870 (main)
Hours of Operation	9:00 a.m. – 5:00 p.m. (excluding Saturdays, Sundays, public holidays and year-end and new year holidays)

Inquiries on Matters Recorded in the Unitholders Registry and Personal Information regarding Administrative Services, etc.

Contact	Stock Transfer Agency Department Mizuho Trust & Banking Co., Ltd.
Address	2-8-4, Izumi, Suginami-ku, Tokyo, Japan Zip code: 168-8507
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)