ES-CON ASSET MANAGEMENT Ltd.

Privacy Policy

1. Basic policy on the handling of personal information

ES-CON ASSET MANAGEMENT complies with the Act on the Protection of Personal Information (2003 Act No. 57,including subsequent amendments; hereinafter, the "Personal Information Protection Law"), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (2013 Act No. 27, including subsequent amendments; hereinafter, the "My Number Act"), and other related laws, regulations and guidelines (collectively with the Personal Information Protection Law and the My Number Act, hereinafter, "Laws"). ES-CON ASSET MANAGEMENT recognizes the importance of protecting personal information (individual number and specific personal information, hereinafter, "specific personal information"; unless otherwise stipulated elsewhere in this Privacy Policy, the same applies below), and shall properly handle, protect, and manage personal information as a business operator handling personal information as stipulated in the Personal Information Protection Law.

  1. Acquisition of personal information
    ES-CON ASSET MANAGEMENT will acquire personal information only to the extent necessary for the purpose which ES-CON ASSET MANAGEMENT has established and by proper and legal means. ES-CON ASSET MANAGEMENT will not acquire any special care-required personal information (as defined in the Personal Information Protection Law.) without the prior consent of the person except as permitted by laws and regulations.
  2. Management of personal data
    ES-CON ASSET MANAGEMENT handles acquired personal information properly and carefully, and educates its employees and appropriately take necessary measures in accordance with each phase, such as acquisition, handling and protection of specific personal data, to appropriately control the acquisition, usage and management of personal data, to prevent unauthorized access, leakage, loss, destruction, and tampering of specific personal information and personal data. If an incident should occur, ES-CON ASSET MANAGEMENT will take corrective measures to minimize damage and prevent a recurrence. Moreover, in the event of a leak, loss, damage, or falsification of personal data handled by ES-CON ASSET MANAGEMENT, or any other incident related to the security of personal data, which the Rules of the Personal Information Protection Commission stipulate is of significant risk of harm to the rights and interests of a person, ES-CON ASSET MANAGEMENT will notify the relevant person of the incident as stipulated in the Rules of the Personal Information Protection Commission. However, this does not apply to instances in which notification to the relevant person is difficult and when alternative measures necessary to protect the rights and interests of the relevant person have been taken.

2. Reasons for using personal information

  1. Reasons for use of personal information (excluding specific personal information. The same applies throughout this section, “2. Reasons for using personal information”).

    Except as permitted by laws and regulations or with the prior consent of the relevant person, ES-CON ASSET MANAGEMENT will handle personal information only to the extent necessary to achieve the purposes of use in the following cases. In addition, information will not be used in any manner that is likely to promote or provoke illegal or improper activities.

    1. For exercise the rights of investors (hereinafter simply referred to as “Unitholders”) and perform obligations to Unitholders in relation to the investment corporation (hereinafter referred to as the “Investment Corporation”) for which ES-CON ASSET MANAGEMENT is entrusted with asset management based on the Act on Investment Trusts and Investment Corporations (Act No. 198 of 1951, including subsequent amendments; hereinafter, the "Investment Trusts Act") and other related laws and regulations as well as the exercise of ES-CON ASSET MANAGEMENT’s rights, duties and related procedures
    2. To prepare and submit various reports and other documents of the Investment Corporation and to prepare and manage various data and information pertaining to Unitholders and Investors, in accordance with the Investment Trust Act, the Financial Instruments and Exchange Act and other related laws and regulations
    3. To facilitate borrowings by Investment Corporation, to issue investment corporation bonds and investment units, and to implement other fund-raising tasks
    4. For ES-CON ASSET MANAGEMENT to carry out operations related to the acquisition, brokerage, transfer, leasing, and management of assets related to the Investment Corporation as well as providing information gathering, research and analysis, and investigations (including, but not limited to, legal investigations and credit investigations)
    5. To analyze market trends, conduct customer satisfaction surveys, and conduct product development surveys and analysis
    6. To provide information, etc. concerning the business of Investment Corporation to Unitholders or Investors
    7. To respond to inquiries, requests for materials, etc. directed at ES-CON ASSET MANAGEMENT
    8. For verification at the time of transactions, etc. on the Act on Prevention of Transfer of Criminal Proceeds (Act No. 22 of 2007, including subsequent amendments) and ES-CON ASSET MANAGEMENT’s regulations.
    9. To perform IR activities and general administrative duties related to Investment Corporation
    10. To carry out operations related to the collection of information, research analysis and investigations (including, but not limited to, legal investigations and credit investigations) of transactions conducted by ES-CON ASSET MANAGEMENT
    11. To provide personal information to third parties within the scope necessary to achieve or execute business related to the reasons for using personal information described above in items (1) to (10)
    12. For human resource management (including wage management, health management, benefit affairs, personnel evaluation, occupational health and safety, etc.), employment selection and hiring procedures, and post-retirement communications and procedures for ES-CON ASSET MANAGEMENT 's officers and employees, etc. (including people who have been offered jobs and people who have retired)
  2. Reasons for use of specific personal information

    Except as permitted by the My Number Act, ES-CON ASSET MANAGEMENT will handle specific personal information only to the extent necessary to achieve the purposes of use in the following cases, regardless of the consent of the person.

    1. Administrative work related to the Personal Number of officers and employees (including dependents) (including administrative duties related to the following)
      1. Administrative work related to withholding tax undertaken by the employer in accordance with the Income Tax Act
      2. Administrative work related to individual inhabitant tax undertaken by the employer in accordance with local tax laws
      3. Administrative work related to employment insurance undertaken by the employer in accordance with the Employment Insurance Act
      4. Administrative work related to health insurance (application-related and benefit-related) undertaken by the employer in accordance with the Health Insurance Act
      5. Administrative work related to employees’ pension insurance undertaken by the employer in accordance with the Employees' Pension Insurance Act (application-related)
    2. Administrative work related to the Personal Number of individuals other than officers and employees (including administrative duties related to the following).
      1. Administrative work related to payment records of remuneration and fees, etc. in accordance with the Income Tax Act
      2. Administrative work related to payment records of dividends, distribution of surplus and interest on funds in accordance with the Income Tax Act
      3. Administrative work related to payment records of real estate royalties, etc. in accordance with the Income Tax Act
      4. Administrative work related to payment records of the acquisition of real estate, etc. in accordance with the Income Tax Act

3. Providing personal data to third parties

ES-CON ASSET MANAGEMENT will not provide any personal data (here, excluding personal data related to specific personal information, etc.) to any third parties, except in the following cases. With regard to specific personal information, except for cases stipulated in the My Number Act, specific personal information will not be provided to any third parties, either with or without the consent of the person.

  1. When agreed to by the person
  2. When in accordance with Laws and regulations
  3. When necessary for the protection of life, body or property under circumstances where it is difficult to obtain consent from the person in advance
  4. When necessary for the improvement of public well-being or the promotion of the healthy growth of children under circumstances where it is difficult to obtain consent from the person in advance
  5. When necessary for cooperating with national institutions, local public bodies, or the person entrusted by them, in executing operations prescribed by laws and regulations, and obtaining consent may impede the execution of those operations
  6. When providing information to subcontractors that are appropriately supervised by ES-CON ASSET MANAGEMENT within the scope necessary to achieve the reason for use
  7. When such personal data is provided to the Investment Corporation for the joint use of personal data as stipulated in Paragraph 5
  8. When the provision of personal information is otherwise permitted under the Personal Information Protection Law or other laws and regulations

4. Supervision over outsourcees

ES-CON ASSET MANAGEMENT may entrust to outsourcees all or part of the handling of specific personal information and personal data, to the extent necessary for achieving the purpose of use. ES-CON ASSET MANAGEMENT shall take necessary and appropriate safety measures for outsourcees to ensure the strict control of the security of entrusted specific personal information and personal data. ES-CON ASSET MANAGEMENT shall also perform supervision to determine whether appropriate oversight supervision is implemented when the personal information is further entrusted to other outsourcees.

5. Joint Use of Personal Data

  1. Joint use shared with the Investment Corporation
    ES-CON ASSET MANAGEMENT will share certain personal data between ES-CON ASSET MANAGEMENT and the Investment Corporation within the scope necessary to achieve the purpose of the shared use, as described below.
    1. Personal data to be jointly used
      • Information on investors (for example, attributes such as address, name, number of investment units held, etc., and details of opinions, requests, complaints, etc., and information related thereto)
      • Tenants, etc. (including prospective tenants, former tenants, guarantors, and co-occupants) of properties owned or being considered for acquisition by the Investment Corporation. (for example, information such as address, name, contents of opinions, requests, complaints, etc., and information related to such information)
      • Information related to other contractors, business partners, etc. (for example, information such as the name and address of the representative or person in charge in the case of a corporation, opinions, requests, complaints, etc., and information related thereto)
    2. Scope of Joint Users
      ES-CON ASSET MANAGEMENT and the Investment Corporation. For more information on the Investment Corporation, please refer to the following.
      ESCON JAPAN REIT Investment Corporation
      https://www.escon-reit.jp/en/index.html
    3. Purpose of Joint Use
      • To appropriately address opinions, etc. from investors of the Investment Corporation, and to appropriately manage other investors
      • To examine each tenant, etc. of the Investment Corporation, to respond to opinions, requests, etc. from each tenant, etc., and to appropriately manage other properties managed by the Investment Corporation
      • To respond to opinions, requests, etc. from contractors, business partners, etc.
      • For other appropriate responses to contractors, business partners, etc.
    4. Name of the person responsible for the management of personal data
      Each company that initially acquired the relevant personal data is responsible for its management.
  2. Joint Use within ES-CON JAPAN Group
    ES-CON JAPAN Group (hereinafter referred to as the entity stipulated in ② below) will jointly use Personal Data as follows. If there are any restrictions on the relevant joint use under related laws and regulations other than the Financial Instruments and Exchange Act and the Personal Information Protection Law, such joint use shall be handled in accordance with the relevant laws and regulations.
    1. Personal Data to be Jointly Used
      • Information related to attributes (for example, information that can distinguish or identify an individual, such as an address, name, date of birth, gender, place of employment, title, contact information such as telephone number or e-mail address, personal identification code, and information related to family members, etc.)
      • Information related to finances (for example, income and expenses, status of assets and liabilities, etc.)
      • Information related to transactions (for example, information pertaining to the type of product or service, transaction amount, contract date and other information related to applications, information related to claims for insurance accidents, etc., transaction needs, securities number, various control numbers such as branch numbers and account numbers, transaction history, records and background, information related to decisions for actioning or not actioning transactions, etc.)
      • Information obtained through applications, websites, and other documents provided by ES-CON JAPAN Group (hereinafter referred to as the entity stipulated in ② below) (for example, status of use of applications, browsing history, location information, and response data from surveys, etc.)
    2. Scope of Joint Users
      ES-CON JAPAN Ltd. and its consolidated subsidiaries and its equity method investees that have already made an public notification pursuant to Article 27, Paragraph 5, Item 3 of the Personal Information Protection Law (hereinafter referred to as “ES-CON JAPAN Group”).
    3. Purpose of Joint Use
      • To plan and develop various financial products and services offered by ES-CON JAPAN Group
      • To propose, introduce, or provide ES-CON JAPAN Group's corporate information, various financial products and services, and other related information, or to provide responses to opinions and inquiries regarding such information
      • To perform other operations incidental to a and b above and to ensure the smooth operation of ES-CON JAPAN Group's business operations
    4. Name of the person responsible for the management of personal data
      Each ES-CON JAPAN Group company that initially acquired the relevant personal data is responsible for its management.

6. Handling of sensitive information

Except as permitted by the Guidelines for the Protection of Personal Information in the Financial Sector, ES-CON ASSET MANAGEMENT will not acquire, use or provide to any third party sensitive information. Here, “sensitive information” is defined in the Guidelines for Protection of Personal Information in the Financial Sector as “Special care-required personal information” along with information regarding labor unions, family origin, legal address on family registry, healthcare and sex life that are not part of the “Special care-required personal information”. Notwithstanding the forgoing, information disclosed by the person concerned, national institutions, local public bodies, an academic or research institution (meaning a university or other institution or organization for the purpose of academic research, or a person who belongs to such an institution or organization.), or the person set out in the Personal Information Protection Act or the Ordinance for Enforcement of the Act on the Protection of Personal Information is not considered “sensitive information”. Also, information obtained by visual inspection or photography which can be identified by its presence is not considered “sensitive information”.

7. Application for disclosure of personal data

ES-CON ASSET MANAGEMENT shall, in accordance with an invoice including identifying documents specified by ES-CON ASSET MANAGEMENT, immediately and without delay respond to a request from the person to receive notification of the purpose of use, or disclose, correct, append to, delete, cease use of, remove, cease provision, or disclose records provided to third parties to a third party of personal data pertaining to that person (hereinafter, Application for Disclosure), after confirmation of identity and ownership.
For further details, apply to one of the service desks indicated in Section 9. There are cases where we will charge for sending documents that constitute a response to a request for notification of purpose of use or disclosure of retained personal data. However, ES-CON ASSET MANAGEMENT may refuse the disclosure of all or part of the personal data, and give the reason without delay, in the following cases:

  1. When it may harm the life, body, property and other rights and interests of the person or a third party
  2. When it may result in conspicuous impediment to the business operations of ES-CON ASSET MANAGEMENT
  3. When it is in violation of laws and regulations

8. Continuous improvement

In addition to complying with the Privacy Policy, ES-CON ASSET MANAGEMENT will continue to make improvements in the future by reviewing the policy in accordance with the revision of laws and regulations, and an increase or a change in public demand.

9. Inquiries and help desks

Please see the contact regarding personal information provided, questions about the handling of personal information including security control measures and requests for disclosure, complaints offer. If ES-CON ASSET MANAGEMENT receives any questions or a complaint has been filed about the handling of acquired personal information, etc., it will investigate the details in order to deal with them in an appropriate way within a reasonable period of time.

10. Business Operators Handling Personal Information

Business operator handling personal information and person in charge of personal data management
https://www.esconam.jp/en/about/index.html

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