Hankyu Hanshin REIT, Inc.

Privacy Policy

Oath

Recognizing the importance of the proper handling of personal information (including specific personal information (referring to personal information containing Individual Number; the same shall apply hereinafter); the same shall apply hereinafter), Hankyu Hanshin REIT, Inc. (hereinafter "Hankyu Hanshin REIT") complies with the "Act on the Protection of Personal Information" (hereinafter the "Personal Information Protection Act"), the "Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure" (hereinafter the "Number Act"), and other relevant laws and regulations and competent government agencies' guidelines in the handling of personal information, and thereby strives for proper handling, management and protection of personal information.

Handling of personal information

  1. Compliance with Laws and Regulations, etc.
    Hankyu Hanshin REIT shall comply with relevant laws and regulations and competent government agencies' guidelines in handling personal information.
  2. Collection of Personal Information
    1. Collection of personal information
      Hankyu Hanshin REIT shall collect personal information in a lawful and fair manner. In addition, in cases where personal information is to be collected directly from the person in writing, etc., Hankyu Hanshin REIT shall clearly indicate the purpose of use thereof to the person in advance. However, there may be cases where the clear indication of the purpose of use is omitted in cases where the purpose of use is found to be clear in light of the circumstances of the collection or otherwise permitted by laws and regulations.
    2. Collection of individual number
      Notwithstanding the provisions of the preceding section, Hankyu Hanshin REIT's right to request that the person or another person in charge of affairs related to Individual Number provide the Individual Number shall be limited to the items listed under 3. Purpose of Use of Personal Information (2) Purpose of Use concerning Individual Number below. In addition, the request for provision of Individual Number shall be made at the point in time when the need arises for processing the concerned affairs or at the point in time when it becomes foreseeable that the concerned affairs will take place.
    3. Identity verification
      In being provided with the Individual Number, Hankyu Hanshin REIT shall perform identity verification by the methods provided in Article 16 of the Number Act. In addition, in the case of a proxy, Hankyu Hanshin REIT shall perform confirmation of the proxy's identity, confirmation of the authority of representation and confirmation of the person's Individual Number by the methods provided in said Article.
  3. Purpose of Use of Personal Information
    1. 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 for 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 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;
    2. Purpose of use concerning individual number

      Notwithstanding the provisions of the preceding section, Hankyu Hanshin REIT's purpose of use for individual number shall be as follows:

      1. to conduct affairs of preparing records of financial instruments transactions, etc.;
      2. to prepare payment records concerning payment of compensation, fees, signing bonuses, bonuses and other remuneration for services or rights;
      3. to prepare payment records concerning payment of remuneration for use or incoming transfer of real estate, etc.;
      4. to prepare payment records concerning payment of distributions, surplus or interest, etc., and other distribution of income;
      5. 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;
      6. to prepare statutory records, etc., required by the provisions of laws and regulations for Individual Number to be stated
  4. Restrictions on Provision of Personal Data to Third Parties
    1. Restrictions on provision of personal data to third parties

      Hankyu Hanshin REIT shall not provide personal data to third parties except in the following cases:

      1. where the person has consented;
      2. where pursuant to laws and regulations;
      3. where necessary for the prevention of death or personal injury or damage to a property, and it is difficult to obtain the consent of the person;
      4. where it is particularly necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the consent of the person;
      5. where it is necessary to cooperate with a government agency or local government, or an individual or business operator representing a government agency or local government in executing the affairs prescribed by laws and regulations, and obtaining the consent of the person is likely to impede the execution of the affairs;
      6. where provision and disclosure are in the form of statistical data or other state through which the person cannot be identified
    2. Restrictions on provision of specific personal information to third parties

      Notwithstanding the provisions of the preceding section, Hankyu Hanshin REIT shall not provide specific personal information to any third parties except in the cases listed in the items of Article 19 of the Number Act.

  5. Ensuring of Accuracy, etc.
    Hankyu Hanshin REIT shall strive to keep the content of personal data both accurate and updated within the scope necessary to achieve the purpose of use, and to delete such data without delay when its use is no longer necessary.
  6. Ensuring of Security
    Hankyu Hanshin REIT shall take necessary and appropriate security control measures for the prevention of unauthorized access to personal data as well as loss, damage, falsification, divulgation, etc., of personal data.
  7. Supervision of Parties Entrusted with Handling of Personal Data
    In the outsourcing of handling of personal data, Hankyu Hanshin REIT shall carry out the necessary and appropriate supervision over the party to which handling is outsourced in order to ensure the party's safe management of personal data.
  8. Notification of Purpose of Use / Disclosure / Correction, etc. / Discontinuance of Use, etc. / Discontinuance of Provision to Any Third Party, of Personal Data
    Concerning procedures for notification of purpose of use; disclosure; correction, addition and deletion (hereinafter "Correction, etc."); discontinuance of use and erasing (hereinafter "Discontinuance of use, etc."); and discontinuance of provision to any third party, of personal information of the person including personal data, please inquire with the contact shown in 9. below for appropriate responses in accordance with prescribed procedures for personal data.
  9. Inquiries regarding Personal Information

    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, disclosure, correction, etc., discontinuance of use, etc., discontinuance of provision to any third party, complaints, etc., regarding personal information.

    Hankyu Hanshin REIT Asset Management, Inc.
    IR and Public Relations Department
    Address 19-19 Chayamachi, Kita-ku, Osaka
    Email IR_PR@hhram.co.jp

    Please inquire with the administrator of 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 Bank holidays)
  10. Ongoing Improvement
    Hankyu Hanshin REIT shall strive to continuously review and thereby improve the Privacy Policy and other frameworks for the protection of Personal Information to ensure the appropriate protection of personal information.