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:
- 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;
- to implement measures to facilitate interaction with unitholders and investment corporation bond holders;
- 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;
- 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;
- 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;
- 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);
- 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;
- to conduct borrowing of funds, issuance of investment corporation bonds and issuance of investment units for the acquisition and management of assets by SHR;
- to appropriately and smoothly implement other operations of SHR
2. Purpose of Use of Individual Numbers
Notwithstanding the provisions of "1. Purpose of Use of Personal Information" above, SHR may use individual numbers for the following purpose:
- Individual numbers of clients, business partners and unitholders
- to prepare reports on financial instruments transactions, etc.;
- to prepare payment reports concerning payments of fees, charges, contract money, awards and other services, or of compensation of rights;
- to prepare payment reports concerning payments of compensation for use or transfer of real estate;
- to prepare payment reports concerning payments of cash distributions, surplus or interests, etc., and distribution of other profits;
- to prepare reports concerning grant or exercise of unit acquisition rights of SHR’s investment units, or allotment of investment units without contribution;
- other work related to items (a) through (e) above;
- to prepare statutory reports and such that require individual numbers pursuant to laws and regulations
- Individual numbers of SHR’s executive officers and their relatives
- 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.;
- 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;
- 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.
In addition, SHR will not revise the purposes of using personal information beyond the scope reasonably acceptable and for the initial purpose of use.
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 the provision of “1. Collection of Personal Information” above, SHR shall not collect sensitive information unless otherwise permitted by relevant laws and regulations, guidelines, etc.
3. Collection of Individual Numbers
Notwithstanding the provisions of “1. Collection of Personal Information” 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 “Purpose of Use; 2. Purpose of Use of Individual Numbers”. 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 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.
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 stated in items under Article 27, Paragraph 1 of the Personal Information Protection Act.
2. Provision of Personally Referable Information to Third Parties
SHR shall not provide personally referable information to any third party without confirming that the consent from the individual has been obtained in advance, as stated in Article 31, Paragraph 1 of the Personal Information Protection Act.
3. Provision of Sensitive Information to Third Parties
Notwithstanding the provision of “1. Provision of Personal Data to Third Parties” above, SHR shall not provide sensitive information to any third party unless otherwise permitted by relevant laws and regulations, guidelines, etc.
4. Provision of Specific Personal Information to Third Parties
Notwithstanding the provision of “1. Provision of Personal Data to Third Parties” above, SHR shall not provide specific personal information to any third party except for cases stated in items under Article 19 of the Number Use Act.
5. Provision of Personal Data and Personally Referable Information to Third Parties Located in a Foreign Country
When providing personal data and personally referable information to a third party in a foreign country, SHR shall comply with the obligations stipulated by relevant laws and regulations, guidelines, etc.
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 entrusts the handling of personal data to Sekisui House Asset Management Ltd. ("SHAM") in accordance with these regulations. SHAM shall appropriately and securely manage personal data and take the necessary measures as follows to prevent unauthorized outside access to personal data and unauthorized use, loss, destruction, alteration, and leakage thereof.
- In order to ensure the proper handling of personal data, SHAM shall formulate and comply with the "Personal Information Management Regulations" and the "Personal Information Protection Management Rules".
- SHAM 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.
- SHAM 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, SHAM 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.
- 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.
- In areas where personal data is handled, SHAM shall manage the entry and exit of employees and implement measures to prevent theft, etc.
- 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.
- When handling personal data in a foreign country, SHAM 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.
Outsourcing of Handling of Personal Data
SHR may outsource the handling of personal data it retains to external operators. 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.
Responses to Requests for Disclosure, etc.
|Contact||General Affairs Department
Sekisui House Asset Management, Ltd.
(Asset management company of SHR)
|Address||4-15-1, Akasaka, Minato-ku, Tokyo, Japan
|Hours of Operation||9:00 a.m. – 6:00 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)