TLC REIT Management Inc. (hereinafter the “Company”) recognizes the importance of handling our customers’ personal information (including personal number and specific personal information; the same shall apply hereinafter) carefully, and will carry out the following measures to provide better products and services for our customers and protect such information carefully.

1. (Execution policy)
   The Company considers the appropriate protection and use of personal information to be its social responsibility. The Company will perform operations in compliance 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 Administrative Procedures (hereinafter the “Numbers Act”) and other applicable laws, regulations, and guidelines.
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 directly or indirectly obtains customers’ personal information, 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) upon notice or announcement of the purposes of use, and only for the intention of achieving the clearly stated purpose for its use. Furthermore, the Company will not obtain customers’ special care-required personal information (as defined in the Personal Information Protection Act; the same shall apply hereinafter) without prior consent of customers, unless otherwise specified in laws and regulations.
4. (Purposes of use)
   The Company will only handle the personal information within the scope of purposes that are described in the Purpose of Use of Personal Information below, and not for anything other than that, unless otherwise specified by laws and regulations or approved by the customers in advance. Furthermore, with the exception of cases based on laws and regulations, the Company will not use personal numbers or specific personal information, which it collects, uses or keeps for specific purposes based on the Numbers Act, beyond the scope of the purposes, regardless of whether customer’s consent is obtained or not.
5. (Appropriate use)
   The Company will not use customers’ personal information by a way that has the possibility of fomenting or prompting unlawful or unfair act.
6. (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 party regardless of the consent of the customer except when such a provision is based on laws and regulations.
7. (Acquisition of sensitive information, etc.)
   The Company will not obtain, use or provide to any third party, unless stipulated in the “Guidelines for Personal Information Protection in the Finance Sector”, special care-required personal information or information relating to membership in labor unions, family origin, registered domicile, healthcare, and sex life (excluding those falling under special care-required personal information) (excluding any information made public by the person themselves or by national government organizations, local public entities, academic research institutions, or those listed in the Personal Information Protection Act or the Ordinance for Enforcement of the Act on the Protection of Personal Information or seemingly-clear information acquired by visual observation, filming or photographing of the person).
8. (Request for disclosure, etc. based on the Personal Information Protection Act)
   If a customer requests the notice of purpose of use of the retained personal data that is held by the Company, or its disclosure, corrections, additions to or deletion of its contents, the suspension of its use, its elimination, cessation of its disclosure to third parties, or the disclosure of record on a third-party provision (hereinafter collectively “Request for Disclosure, etc.”), the Company will respond to the Request for Disclosure, etc. pursuant to laws and regulations. In each procedure, the Company will verify that the person making the Request for Disclosure, etc. is the principal. The Company may receive prescribed fees for procedures for the request for disclosures, etc. In case of informing a principal to the effect that, as regards a whole or part of action requested by the principal, the action will not be taken, or to the effect that different action from the said action will be taken, the Company will endeavor to explain a reason therefor to the said principal.
9. (Complaints, etc. regarding personal information)
   The Company will endeavor to properly and expeditiously process any complaints, etc. on the handling of personal information within a reasonable period.
   For contact information regarding any complaints, etc. about our handling of personal information, please see below.
10. (Safety management measures)
    The Company will keep customers' personal data (“personal data" means personal information that the Company has acquired, or is to acquire, including that which is planned to be handled as personal data; hereinafter the same will apply in this policy 10) accurate and up-to-date, strictly manage customers' personal data, and take institutional safety management measures, human safety management measures, physical safety management measures, and technological safety management measures against any leakage, loss or damage (hereinafter collectively “Leakage, etc.”) (in the event where the Company handles personal data in a foreign country, the Company will take such safety management measures after having understood the legal system, etc. related to protection of personal information in such foreign country), and endeavor to delete such personal data without delay when it is no longer needed. In addition, when the Company entrusts any third party the handling of personal data, the Company will oversee the handling of such personal data, for example by obligating the third party to strictly manage the personal data. For contact information regarding details of safety management measures of the Company, please see below.
11. (Staff education)
    The Company familiarizes its executives and other staff with protection and appropriate management of personal data.
12. (Constant review of the Company’s 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.
13. (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.

Name: TLC REIT Management, Inc.

1. The Company uses the personal information (excluding personal numbers and specific personal information) 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 the rights of, or to perform obligations to the 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 Corporations of real estate, trust beneficiary rights in real estate (real estate serving as trust assets is hereinafter referred to as "Real Estate in Trust") or other assets, or to perform duties related to the execution of contracts (notification, inquiries, registrations, etc.) for the acquisition or sale of the 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 Corporations, or to perform duties (notification, inquiries, registrations, etc.) related to the execution of lease contracts of the same
5. (5)To perform duties other than the above related to the management of real estate, Real Estate in Trust, and other assets 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 Corporations
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 the Company shareholders and prospective shareholders, the Unitholders, and prospective unitholders of the Investment Corporations
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 use, the Company notifies the customer and discloses the modified intended use.

TLC REIT Management Inc. Corporate Planning Department, Corporate Management Division

Upon calling the main number +81-3-6455-3442, 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.
Business hours are 9:30 A.M. to 6:00 P.M. except on Saturdays, Sundays, national holidays and company-designated holidays.

Name: Investors Consultation Office, The Investment Trusts Association, Japan
+81-3-5614-8440

Amended: May 2, 2024