Hankyu Hanshin REIT, Inc.

Privacy Statement

  1. Scope

    This privacy statement applies to personal data used by Hankyu Hanshin REIT, Inc. (hereafter “Hankyu Hanshin REIT”) at its offices within the European Economic Area (EEA).

  2. General Principles of Processing Personal Data

    Hankyu Hanshin REIT shall process personal data in accordance with the following general principles:

    • Process personal data lawfully, fairly and in a transparent manner in relation to a data subject.
    • Process personal data only to the extent necessary for achieving the purpose of use specified in advance.
    • Store personal data for the period necessary for achieving the purpose of use.
    • Maintain personal data accurately and update data to the extent necessary for the purpose of use.
    • Process personal data by implementing appropriate technical and organizational measures.
  3. Purpose of Use of Personal Information
    • Purpose of Use of Personal Information

      Unless otherwise provided by laws and regulations, Hankyu Hanshin REIT shall handle personal information solely within the scope necessary to achieve the following purpose of use. Furthermore, Hankyu Hanshin REIT shall not revise the purpose of use of personal information beyond the scope reasonably acceptable relevant to the purpose of use before the revision.

      1. to exercise rights of the holders of securities issued by Hankyu Hanshin REIT and performance of obligations of Hankyu Hanshin REIT pursuant to the "Act on Investment Trusts and Investment Corporations" (hereinafter the "Investment Trusts Act") and other laws and regulations;
      2. to conduct IR activities concerning Hankyu Hanshin REIT;
      3. to prepare and submit various reports, etc., as well as prepare various data for management of unitholders' register and other unitholders' information of Hankyu Hanshin REIT pursuant to the Investment Trusts Act, other laws and regulations, and rules of Tokyo Stock Exchange, Inc., etc.;
      4. to respond to inquiries, etc., to Hankyu Hanshin REIT;
      5. to conduct debt financing by Hankyu Hanshin REIT, and issuance of investment corporation bonds for subscription, investment units for subscription and other securities issued by Hankyu Hanshin REIT;
      6. for Hankyu Hanshin REIT to acquire and sell assets under management and lease assets under management, as well as survey and review, collect and provide information required for such acquisition, sale and lease, and execute various other business operations involved in management of assets conducted under the Investment Trusts Act;
      7. to appropriately and smoothly execute other business operations of Hankyu Hanshin REIT;
      8. to conduct affairs of preparing records of financial instruments transactions, etc.;
      9. to prepare payment records concerning payment of compensation, fees, signing bonuses, awards and other remuneration for services or rights;
      10. to prepare payment records concerning payment of remuneration for use or incoming transfer of real estate, etc.;
      11. to prepare payment records concerning payment of dividends, surplus or interest, etc., and other distribution of income;
      12. to prepare records concerning granting or exercise of subscription rights to investment units or allotment of investment units without contribution of Hankyu Hanshin REIT investment units;
      13. to prepare statutory records, etc., required by the provisions of laws and regulations for Individual Number to be stated.
  4. Legal Basis of Processing Personal Data

    Hankyu Hanshin REIT shall process personal data based on one of the following legal bases.

    • When Hankyu Hanshin REIT has obtained the consent of the data subject, or when notices of necessary matters are made to the data subject.
    • The processing is necessary to execute a contract with the data subject.
    • The processing is necessary for Hankyu Hanshin REIT to fulfil its legal obligations.
    • The processing is necessary to secure legitimate interests pursued by Hankyu Hanshin REIT.
  5. Providing Personal Data to a Third Party
    • If Hankyu Hanshin REIT provides personal data to a third party as part of the processing of personal data based on the applicable legal basis, it shall communicate the information of the recipient to the data subject.
    • If Hankyu Hanshin REIT transfers personal data from the territory of EEA to outside the EEA, it shall implement safeguards required under applicable laws and regulations.
  6. Taking Action on the Rights of Data Subjects

    Hankyu Hanshin REIT shall take appropriate actions on the data subject’s requests on the processing of personal data concerning him or her in accordance with applicable laws and regulations. These shall include:

    • Access to the personal data
    • Rectification or erasure of the personal data
    • Restriction on the processing of the personal data
    • Lodging a complaint against the processing of the personal data
      The data subject may lodge a complaint with the supervisory authority.
    • Data portability of the personal data
    • Withdrawal of consent on the processing of the personal data
    • Contest against the processing of the personal data
  7. Measures for the Protection of Personal Data
    • Hankyu Hanshin REIT shall implement appropriate, necessary measures including measures against, including but not limited to, illegal access, computer viruses to prevent incidents such as loss, destruction, manipulation or leakage of personal data. Hankyu Hanshin REIT shall also provide appropriate and necessary supervision over its employees, contracted processors, etc. to ensure the protection of personal data.
  8. Inquiry Contacts

    Hankyu Hanshin REIT shall respond sincerely to questions, complaints, etc., regarding the handling of personal information. Please inquire to the contact below for any questions, requests for notification of purpose of use, requests for disclosure, correction, discontinuance of use, discontinuance of provision to any third party, complaints, etc., regarding personal information.

    Hankyu Hanshin REIT Asset Management, Inc., Corporate Administration and Supervision Department
    Address 19-19 Chayamachi, Kita-ku, Osaka
    Email +81-6-6376-6821
    Business hours 9 a.m. to 5 p.m.
    (except Saturdays, Sundays, national holidays, and company-designated holidays)

    Please inquire with the administrator of the unitholders' register below regarding correction, addition, deletion, etc., of matters stated on the unitholders' register.

    Mitsubishi UFJ Trust and Banking Corporation, Osaka Corporate Agency Division
    Address 3-6-3 Fushimimachi, Chuo-ku, Osaka
    TEL +81-42-204-0303
    Business hours 9 a.m. to 5 p.m.
    (except Saturdays, Sundays, national holidays, and company-designated holidays)

Enacted June 19, 2019