KIA Trust Co., Ltd (hereinafter known as the Company), recognizes the importance of personal information and handles acquired personal information complying with the, “Act on the Protection of Personal Information” (Act No. 57 of 2003, including subsequent amendments. Hereinafter referred to as the “Personal Information Protection Act”) and other laws and regulations regarding the protection of personal information including further guidelines from qualified government authorities. In addition, based on this privacy policy, we will properly handle, protect and manage personal information.

1. Policy on efforts to protect personal information

We believe that personal information should be handled carefully under the principle of respect for the personality of individuals and that it shall be handled appropriately, and we will endorse the below articles to protect personal information.

• We will not acquire personal information by deception or other fraudulent means. In addition, when acquiring personal information from a third party, we will not infringe the interests of the person.
• We will not handle the acquired personal information beyond the scope of the purpose of use specified in advance without the consent of the person, except when permitted by law.
• In addition to cases where the acquired personal data is permitted by law and or described in “4. Provisions and disclosure of personal data to a third parties” below, it will not be provided to a third party without the consent of the individual.
• We will keep the acquired personal data accurate and up-to-date within the scope necessary to achieve the purpose of use.
• We will take necessary and appropriate measures along with other security management measures to prevent leakage, loss or damage of the acquired personal data of personal information.
• We will establish an appropriate internal management system and provide necessary and appropriate supervision to employees so that personal data will be safely managed.

2. Acquiring method and source of personal information

We will acquire personal information from the following sources, by lawful and fair means to the extent necessary to achieve the purpose of use.

• When directly provided by documents such as contracts, etc. that the individual fills out and submits
• When personal information is provided by a third party such as a subcontractor

(For example, acquiring the personal information within a lease contract of an individual who moves into a property owned by a fund, etc. defined below in “3. Purpose of use of personal information”.)

3. Purpose of use of personal information

The Company`s main business is, the business of managing the assets under consignment from a third party, the business of giving advice on investment for a third party, the second-class financial instruments business, and the residential land and building transaction business, property management business along with related businesses, and we will use personal information accordingly to carry out each business. The Company will not use personal information acquired beyond the scope of the following purposes of use, except when permitted by law. Specific purposes of use for example are as follows. Do note that, customers involved in asset management or investment advice by the Company (assuming SPCs and other forms of corporations or unions, trustees, etc., which are investment vehicles, are collectively referred to as “funds, etc.”) Investors are hereinafter referred to as “investors”.

• To fulfill our obligations to investors such as funds and responding to investors exercise of rights based on the provisions within the Financial Instruments and Exchange Act (hereinafter referred to as the “Financial Instruments and Exchange Act”), the Companies Act and other related laws and regulations.
• To provide investors with notifications of information about the funds business and other various matters.
• To implement measures to facilitate the relationship between the fund, investors, and those who are considering to acquire or sell securities and or other issued shares by the fund.
• For investor information management, attribute analysis, and disclosure of data such as the list of investors of funds created based on the Financial Instruments and Exchange Act, the Companies Act, and other related laws and regulations.
• To understand the credit status of the lessee or the person who is considering renting the property that the fund, etc. owns or is considering to acquire.
• To investigate and consider the acquisition, sale, maintenance, leasing, etc., and other related management matters of the assets managed (including fund procurement) by the Company for funds, etc.
• To respond to inquiries or requests for materials from investors and those who are considering to acquire the securities and or other issued shares by the fund.
• For funds, etc. to issue securities.
• For funds, etc. financing
• To confirm details at the time of transaction based on the Act on Prevention of Transfer of Criminal Proceeds.
• To be used for market trend analysis, customer satisfaction survey, product development, and other survey analysis.
• To fulfill the Company`s obligations, exercise of rights, and take appropriate measures.
• To provide, if necessary, to a third party in order to carry out business matters properly.
• For settlement of accounts of funds and other accounting and tax related operations.
• For the sale, brokerage, or intermediary of real estate and or trust beneficiary rights of entrusted real estate.
• For work related to the building management duties and tenant management duties.
• To carry out other related duties of the preceding articles.

4. Provisions and disclosure of personal data to a third parties

The Company will not provide or disclose acquired personal data to third parties except in the following cases.

• ① With the consent of the person
• ② When required by law
• ③ When it is necessary to protect the life, body or property of a person and it is difficult to obtain the consent of the person.
• ④ When it is particularly necessary to improve public health or to protect children, and it is difficult to obtain the consent of the individual.
• ⑤ In a case where the consent of the person may interfere in carrying out the affairs when and should it be necessary, for a national institution or a local public entity or a person entrusted with it to cooperate in carrying out the affairs stipulated by laws and regulations.
• ⑥ In addition, when it is permitted to provide to a third party without obtaining the consent of the person according to the Personal Information Protection Law, guidelines, etc.

5. Disclosure, correction, deletion, suspension of use, etc. of retained personal data

If there is a request from the person regarding the retained personal data, we will confirm that he / she is the person and take measures such as disclosure, correction, addition, deletion, suspension of use, etc. in accordance with the law. For contact information, please refer to “9. Contact information” below. In addition, we may charge a fee prescribed by our company for procedures such as disclosure.

6. Strict management of personal data

The Company will endorse to keep personal data as accurate and up-to-date as possible. In order to prevent leakage, loss, damage and other safety management of personal data, we will take necessary and appropriate safety management measures in accordance with laws and guidelines in managing personal data.

7. The handling of personal data when outsourcing and supervision

The Company outsources part of our business such as the below.

• Printing or shipping of documents to be sent to customers
• Providing professional advice such as legal and accounting
• Operation and maintenance of information systems

When we outsource all or part of the handling of personal data, we shall supervise the outsourced party as necessary so that the security of personal data will be managed.

8. Application and revision of this policy

The contents of this policy will be applied from the date of publication on our website. In addition, this policy may be revised without notice when requested by laws and regulations or when the Company deems it to be necessary, but in such cases, it will be posted on the Company’s website immediately.

9. Contact information

For questions regarding personal information, suspension of provision of personal data to third parties, disclosure, correction, complaints, and other inquiries, please contact the following.

Name：KIA Trust Co., Ltd Business Administration Headquarters

Address：Kasumigaseki Bldg. 35F, 3-2-5, Kasumigaseki Chiyoda-Ku, Tokyo

Telephone：03-5157-1103

Hours of Operation： Monday – Friday: 9am – 5pm (except weekends, national and company holidays)

In addition, the Company is a subject business operator of the Japan Investment Advisers Association, whom is a part of the Personal Information Protection Commission (PPC), that accepts consultations and complaints regarding the handling of personal information of subject business operators.

Name：Japan Investment Advisers Association, Tokyo (JIAA) Complaint Counseling Room (in charge of personal information)

Telephone：03-3663-0505

Hours of Operation： Monday – Friday: 9am – 5pm (except weekends, national and association selected holidays)