Personal Information Protection Policy

Uni-Asia Capital (Japan) Ltd. (the “Company”) will establish and comply with its Personal Information Protection Policy (the “Policy”) in order to prevent loss, leakage and/or falsification of, and to protect, personal information.Based on the Policy, the Company will establish internal rules for the protection of personal information, and will also ensure on a best effort basis that personal information is properly managed by having such internal rules disseminated to every executive and employee as well as implementing other measures.

Note
  1.  Compliance with Laws and Regulations
    The Company will designate the officer who is responsible for managing the customers’personal information, and will comply with the Personal Information Protection Act (Act No. 57, 2003 as the law is being referred to), associated laws and regulations and guidelines set forth by the relevant authority regarding the protection of personal information.

     
  2. Proper Acquisition of Personal Information
    The Company will acquire personal information by lawful and fair means. Even if such personal information is to be acquired indirectly via a third party the Companywill try our best to ensure that the personal information was not illegally obtained by a third party.

     
  3. Purpose of Utilisation
    The Company, except in cases permitted by law, will not utilise the personal information it acquires beyond what it is required for to achieve the purposes set forth below:

     
    1. To execute the contract and/or to provide information/services relating to the sale and purchase, brokerage, leasing, and management of real estate (including beneficial interest in real estate trust).
    2. To execute the contract and/or to provide information/services relating to the sale and purchase, brokerage and management of debts.
    3. To execute the contract and/or to provide information/services relating to advisory business on investment and/or debt workout (advisory services on investments and effective utilisation of assets).
    4. To execute the contract and/or to provide information/services relating to investments in companies.
    5. To execute the contract and/or to provide information/services relating to due diligence services (analysis/evaluation of investment value)
    6. To investigate and analyse market/customer trends, product development, andvaluations for the purpose of provision of information/services described in items A  through E above.
    7. To conduct sales and/or marketing activities including soliciting by means of visit, mail, phone call, facsimile, e-mail, etc. for the purpose of provision of information/services described in items A and C above.
    8. To preserve books and their associated materials pursuant to Article 49 (Obligation to Keep the Books) of Building Lots and Building Transaction Business Act.
    9. To provide personal information to third parties which is to be utilised as the “grounds of opinion” pursuant to Article 34-2(2) of Building Lots and Building Transaction Business Act.
    10. To select new officers and staff recruited for the group.
    11. To conduct business/services incidental to the business/services described in items A  through E and J above.
    12. To provide third parties with personal information only to the extent necessary to achieve the purposes described in items A through D above.
       
  4. Ensuring personal information is correct and up-to-date
    The Company will endeavor to ensure that the personal information retained is correct and up-to-date.

     
  5. Provision of Personal Information to Third Parties
    The Company will not provide any personal information to third parties without the prior consent of the individual concerned, except in cases permitted by law.

     
  6. Outsourcing
    When outsourcing the handling of personal information to third parties, the Company will take appropriate measures to protect personal information, including monitoring the personal information protection system of the third parties, or incorporating protection clauses in the outsourcing contracts with such third parties, etc.

     
  7. Security of Personal Information
    The Company will take appropriate measures in organisational, personnel, and system aspects, and establish the security management system, that are necessary to protect personal information.

     
  8. Procedure to Request Disclosure, etc. of Retained Personal Data
     
    1. In order to request the disclosureof personal data concerning the customer that is retained pursuant to Articles 24(2), 25(1), 26(1) and 27(1)(2) of the Act on the Protection of Personal Information, please fill in the prescribed request form and prepare personal verification documents (Driver’s License, copy of Resident Register, etc.), and request by visit in person or by mail. In the case where the request is made by a legal representative or an appointed representative, please also prepare personal verification documents (Power of Attorney, copy of Family Register, etc.) of the representative.
    2. If the Company receives a request for disclosure, etc., in order to protect privacy of the person who requested, a response will be made by mailing (Restricted Delivery Mail Service) written documents. Please be forewarned that the Company’s response may be addressed directly to the customer even if the request is made by his/her representative.
    3. For inquiry and complaints with regard to the Company’ssecurity control measures for personal information, please contact:
      <Asset Management Department, Administration team, Uni-Asia Capital (Japan) Ltd.>
      Phone: +81-3-3518-9251 (Monday-Friday, except public holidays 09:00 – 17:00)

       
  9. Continuous Improvement of Personal Information Protection System
    The Company will continually endeavor to review and improve its internal policies and systems with regard to the handling of personal information.

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