III. Publication of Information Based on the Act on the Protection of Personal Information

The Company (please refer to “Company Overview” under “Corporate Profile” for the company name, address, and name of the representative) publicizes the following information in compliance with Japan’s Act on the Protection of Personal Information (Act No. 57 of 2003, including subsequent amendments).

1. Policy for Protection of Personal Information

The Company recognizes the importance of personal information in this advanced information and telecommunications society, and by respecting and complying with the laws, regulations and social order regarding the protection of personal information, we shall strive to obtain and manage personal information appropriately and maintain its accuracy and confidentiality, and to not use it for any purpose other than the purpose of use.

2. Purpose of Use of Personal Information

We shall endeavor to specifically define the purpose of use so that it is clear, and to limit the purpose of use in accordance with the circumstances of acquisition.
In accordance with the Act on the Protection of Personal Information, we shall use customers’ personal information within the scope necessary for the following operations in (1) to achieve the purposes of use described in (2).
When acquiring personal information directly from customers in writing, the purpose of use shall be clearly stated in advance (except in cases where laws and regulations stipulate that such clarification is not required).
If a customer requests that we suspend use of their personal information, we shall suspend use of their personal information for the concerned purpose.

• Business Operation
  • Businesses related to the handling of sales and purchases, brokerage of sales and purchases, offering, etc., and handling of offering, etc., of real estate trust beneficiary interests and collective investment schemes, etc.
  • Businesses related to discretionary investment contracts
  • Businesses related to asset management for Samty Residential Investment Corporation
  • Businesses related to investment advisory contracts
  • Comprehensive real estate investment advisory business and operations incidental thereto
  • Real estate brokerage business and operations incidental thereto
  • Other business that we may engage in and operations incidental thereto (including operations that we will be permitted to handle in the future)
• Purpose of Use
  • To solicit, sell, and provide information on products and services related to the operations in (1) in light of factors such as an analysis of investment styles based on past transactions
  • To determine the appropriateness of products and services in light of the principle of suitability (so as not to solicit, sell, or provide information on products and services found to be inappropriate in light of the customer’s investment knowledge, experience, status of property, and intentions)
  • To verify the identity of the customer or the customer’s agent
  • To perform administrative work related to transactions with customers
  • To exercise rights and perform obligations under contracts with customers, laws, etc.
  • To research and develop financial products and services by conducting market research, data analysis, questionnaires, etc.
  • To carry out other administrative work for properly and smoothly executing transactions and contracts with customers

The Company shall not acquire, use, or provide to third parties with sensitive personal information as stipulated by the Act on the Protection of Personal Information, such as race, creed, or criminal record, nor information related to labor union affiliation, family origin, legal domicile, or healthcare, nor other sensitive information, except as required by laws and regulations or as otherwise stipulated by the Act on the Protection of Personal Information.

3. Provision of Personal Information to Third Parties

We shall not provide customers’ personal data to any third party without the customer’s consent, except when required by laws and regulations, when such personal data is provided as a result of our entrustment of all or part of the handling of personal data within the scope necessary to achieve the purpose of use or when otherwise required by the Act on the Protection of Personal Information, or when we have obtained the customer’s prior consent.

4. Joint Use of Personal Information

We may share and use personal data as follows.

• Items of Personal Data to Be Shared
  ・Information about the customer such as name, address, date of birth, telephone number, occupation, and transaction needs
  ・Information related to customer transactions such as transaction details and balance on deposit
• Scope of Parties for Joint Use
  The Company’s holding company, Samty Holdings Co., Ltd., and its consolidated subsidiaries listed in its annual securities report, etc. (the “Samty Group”)
• Purpose of Use
  To conduct business management and internal control of the Samty Group, including integrated compliance and risk management
• Personal Data Manager
  Samty Asset Management Co., Ltd.

5. Security Control Measures for Personal Information

We shall have a system in place for managing the security of personal information by taking, depending on the circumstances, (i) institutional security control measures, (ii) personnel security control measures, (iii) physical security control measures, and (iv) technological security control measures. In addition, we shall periodically educate our employees on the protection of personal information.
We shall manage personal data of our customers in an appropriate and prudent manner by endeavoring to keep personal data of our customers accurate and up to date to the extent necessary to achieve the purpose of use and delete such without delay when use is no longer necessary.

6. Outsourcing of Personal Information Processing

Although we outsource personal data within the scope necessary to achieve the purpose of use, we conclude contracts necessary for managing the security of personal information and exercise appropriate management and supervision.

7. Procedures for Requesting Disclosure, Correction, Etc. of Retained Personal Data

We acknowledge that customers have the right to request disclosure, correction, suspension of use, deletion, etc. of their personal data, and we shall promptly respond to any such requests, except as otherwise provided by laws and regulations.

• How to Make a Request
  Please send by postal mail to the following address: (i) the Company’s designated request form filled in with the prescribed items, and attached with (ii) the required documents.
  If the request is for disclosure, please also enclose (iii) the postal money order (of the fee in the amount of 500 yen).
  If the request is otherwise correction, suspension of use, deletion, etc., no fee is required.
  
  • Personal Information Consultation Desk, Samty Asset Management Co., Ltd. 20F Marunouchi Trust Tower Main, 1-8-3 Marunouchi, Chiyoda-ku, Tokyo 100-0005
  ★Please indicate whether it is a “Request Form for Disclosure Enclosed” or “Request Form for Correction (or Other Purpose) Enclosed” by writing such in red on the envelope.
• The Company’s Designated Request Form
  Request Form for Disclosure: EXCEL Version　PDF Version (Click to download)
  Request Form for Correction (or Other Purpose) (i.e., correction, suspension of use, deletion, etc.): EXCEL Version　PDF Version (Click to download)
  *If you are unable to download the request form, please contact us via “8. Contact for Inquiries.”
• Required Documents (Please prepare the required documents according to the following categories for verification of identity.)
  
  • In the case of requests by customers themselves
    A. Certificate of residence
    B. Copy of identification issued by a public institution (e.g., driver’s license)
    
  • In the case of requests by agents
    i. For legal representatives (all of the following documents from A. through C.)
    　A. Document proving the right of legal representation
    　　・For those representing minors: Certified copy of the family register
    　　・For those representing adult wards: Certificate of registered matters (please inquire at the Tokyo Legal Affairs Bureau)
    　B. Certificate of residence of the legal representative
    　C. Copy of the legal representative’s identification issued by a public institution (e.g., driver’s license)
    ii. For agents other than those in i. (all of the following documents from A. through E.)
    　A. Power of attorney document (stamped with personal seal)
    　B. Certificate of registered seal of the represented customer
    　C. Certificate of residence of the represented customer
    　D. Certificate of residence of the agent
    　E. Copy of the agent’s identification issued by a public institution (e.g., driver’s license)
    
• Method of Response to Requests for Disclosure, Correction, Suspension of Use, Deletion, Etc.
  A written response will be sent to the address of the subject (customers themselves) indicated on the request form.
• Purpose of Use of Personal Information Obtained in Connection with Requests for Disclosure, Correction, Suspension of Use, Deletion, Etc.
  Personal information obtained in connection with a request shall be handled only to the extent necessary for the request for disclosure, correction, etc.
  Submitted documents will not be returned. After the response to the request for disclosure, correction, etc., these will be stored for one year and then disposed of.
• Cases of Non-Disclosure
  Information shall not be disclosed in the following cases. If we decide not to disclose the information, the reason will be noted in the written response. Please note that the fee is non-refundable even if information is not disclosed.
  • If identity cannot be verified for reasons such as discrepancies between the information in the request and the information that we have
  • In the event of non-payment of fees associated with a request
  • If the authority of representation cannot be verified when a request is filed by an agent
  • If there is a deficiency in the prescribed documents other than (i)
  • If the subject of the request does not fall under the category of retained personal data
  • If there is a risk of harm to the life, body, property, or other rights or interests of the person concerned or a third party
  • If there is a risk of significant hindrance to the proper conduct of our business
  • If unable to respond to the request as provided by related laws, regulations, etc.
• If Unable to Respond to Requests for Correction, Suspension of Use, Deletion, Etc.
  We will process a request for correction, suspension of use, deletion, etc. based on the results of a fact-finding investigation that shall be launched without delay within the scope of the purpose of use, except when unable to respond to the request in the case of falling under any of the items in (6) (excluding (ii)). The reason will be noted in the written response in the event of such.

8. Contact for Inquiries

For inquiries regarding the handling of personal information, please contact us through the following means.

• By Postal Mail
  To: Personal Information Consultation Desk, Samty Asset Management Co., Ltd. 20F Marunouchi Trust Tower Main, 1-8-3 Marunouchi, Chiyoda-ku, Tokyo 100-0005
• By E-Mail
  E-mail：