Privacy policy

Privacy policy

Established Jan. 27, 2010

TLC REIT Management Inc. (hereinafter the Company) recognizes the importance of handling our customers’ personal information (including personal numbers and specific personal information; the same applies hereafter) carefully and will carry out the following measures to provide better products and services for our customers and protect such information responsibly.

  1. (Execution policy)
    The Company recognizes that the proper protection and use of personal information is an important social responsibility and in the due course of carrying out its various business activities, promises to comply with the Act on the Protection of Personal Information (hereinafter the “Privacy Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter the “Numbers Act”) and other relevant laws, regulations and guidelines, etc.
  2. (Internal structure)
    With regard to the handling of personal information, the Company will not only set down internal regulations and necessary rules for each business activity but also establish an appropriate internal structure for the management of personal information and construct a compliance structure to comply with the protection of personal information.
  3. (Proper acquisition)
    In the event that the Company requires personal information from any of our customers, we will do so through proper and legal means (including but not limited information filled in and provided in person in contracts and other materials) and only for the intention of achieving the clearly stated purpose for its use.
  4. (Purpose of use)
    The Company will only use the personal information within the scope of use and not for anything other than that, unless otherwise specified by laws and regulations.
  5. (Restriction on provision to third party)
    Unless otherwise having received prior consent from the customer or when separately specified by laws and regulations, the Company will not provide a customer’s personal information to any third party without consent. Based on the Numbers Act, the Company will not provide personal numbers and specific personal information which it collects, uses and stores for specific purposes to any third parties regardless of the consent of the customer except when such a provision is based on laws and regulations.
  6. (Disclosure of, correction, addition, and deletion of contents of, termination of use of, and deletion of possessed personal data in accordance with the Privacy Protection Act)
    With respect to each customer's personal data that the Company possesses, we will respond according to laws regulations to any customer's request if any customer requests to disclose, correct, add to or delete the content of, suspend use of, delete, etc. such customer’s possessed personal data. We will carry out identity verification steps before taking any procedure mentioned above, etc. Regarding all or part of measures requested, in the case of notification of not having implemented the measure or of having implemented a different measure, we will endeavor to explain the reasons to the customer.
  7. (Safe management measures)
    In order to keep our customers’ personal information accurate and up-to-date within the scope required for achieving the purpose of use, the Company will handle the information with strict care, and take preventive and safety measures to ensure that the information is not accessed illegally, lost, destroyed, altered or leaked. In addition, when the Company entrusts any third party to acquire and manage any personal information, we will require and oversee that the third party fulfills management of the personal information with the same care.
  8. (Staff education)
    The Company familiarizes its executives and other staff with protection and appropriate management of personal information.
  9. (Constant review of internal structure)
    With regard to the internal regulations and organizational structure related to the handling of personal information, the Company will constantly review and revise such to ensure that effective and reasonable operations are continuously carried out.
  10. (Disclaimer)
    Links to external websites are provided on the website operated and managed by the Company; however the Company bears no responsibility for any contents related to the protection of personal information, etc. found in these websites.

[Purpose of Use of Personal Information (Excluding Personal Numbers and Specific Personal Information)]

1. The Company uses the personal information (excluding personal numbers and specific personal information) it has acquired for the following purposes:

  1. (1)To manage information, to conduct attributable analysis, or to disclose data related to unitholders (hereinafter the "Unitholders") of the investment corporations (hereinafter collectively the "Investment Corporations" or, individually “Investment Corporation”) delegating asset management duties to the Company (with the exception of posting major Investment Corporation Unitholders (Top 10 Unitholders) on the Investment Corporation website, no personally identifying information will be disclosed)
  2. (2)To perform duties related to the exercise of Unitholder rights, or to perform obligations to Unitholders of the Investment Corporations
  3. (3)To perform necessary due diligence (including, but not limited to, background checks for transactions, credit checks or other rights-related research) related to the acquisition or sale by Investment Corporation of real estate or trust beneficiary rights in real estate (real estate serving as trust assets is hereinafter referred to as "Real Estate in Trust"), or to perform duties related to the execution of contracts (notification, inquiries, registrations, etc.) for the acquisition or sale of same
  4. (4)To perform necessary due diligence (including, but not limited to, background checks for transactions and credit checks) for real estate leases related to real estate, Real Estate in Trust, or other assets held by the Investment Corporation, or to perform duties (notification, inquiries, registrations, etc.) related to the execution of lease contracts for the same
  5. (5)To perform duties other than the above related to the management of real estate and Real Estate in Trust held by the Investment Corporations
  6. (6)To perform duties related to confirming identities, responding to, or preparing transaction records for referred persons, visitors to, or individuals requesting documents from the Company or the Investment Corporation
  7. (7)To perform other duties related to financial products transaction business, etc.
  8. (8)To perform duties related to measures (information-provision activities, etc.) for ensuring smooth relations with Company shareholders and prospective shareholders, the Investment Corporation, Unitholders, and prospective unitholders
  9. (9)To verify the identity of counterparties, etc. in respect of any transactions when making the transaction in accordance with the Act for Prevention of Transfer of Criminal Proceeds
  10. (10)To analyze market trends for the above-mentioned businesses, customer satisfaction surveys and product development surveys and analysis
  11. (11)To execute the Company’s duties and exercise our rights and handling incidental issues
  12. (12)To make disclosure to third parties to the extent necessary for appropriate performance of the Company’s business
  13. (13)To perform other duties incidental or related to the above items

2. In the event that the Company modifies the intended usage, the Company notifies the customer and discloses the modified intended usages.

Contact for [Disclosure, correction, suspension of use, etc. of personal information and inquiries regarding personal information]

Please contact the following with regards to requests for disclosure, etc. of personal data owned by the Company and other inquiries. The following department may be contacted for consultation, complaints, etc. regarding handling of personal information of the Company.

○ TLC REIT Management Inc. Corporate Planning & Administration Department
Upon calling the main number +81-3-3401-1090 ask for the “Contact for Personal Information Inquiries Division.”
Business hours are 9:30 A.M. to 6:00 P.M. except on Saturdays, Sundays, national holidays and company-designated holidays.

The Company is also a member of The Investment Trusts Association, Japan, a recognized personal information protection organization authorized based on legal regulations on personal information protection. The association handles consultations and complaints on the handling of personal information from member organizations.
Name: Investors Consultation Office, The Investment Trusts Association, Japan
TEL: +81-3-5614-8440

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