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

The Company (for the Company’s name, address and the name of its representative, please refer to the “Company Profile”) publishes the following information pursuant to Japan’s Act on the Protection of Personal Information (Act No. 57 of 2003, including subsequent amendments; hereinafter referred to as the “Act on the Protection of Personal Information”).

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 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 Customers’ 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 in the businesses described in (1) below to the extent necessary to achieve the purposes of use described in (2) below.
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 the use of their personal information, we shall suspend the use of their personal information for that purpose.

• Description of Business
  • 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 related businesses
  • Real estate brokerage business and related businesses
  • Other businesses that we may engage in and operations incidental thereto (including operations that we will be permitted to handle in the future)
• Purposes of Use
  • To solicit, sell, and provide information on products and services related to the businesses in (1), based on analysis of investment style, etc. derived from transaction history
  • To determine the appropriateness of products and services in light of the principle of suitability (in order to avoid soliciting, selling, or providing information on products and services deemed inappropriate in light of the customer’s knowledge of and experience in investment, financial situation, 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, and questionnaires
  • To perform administrative work for the proper and smooth execution of other transactions and contracts with customers

The Company shall not acquire, use, or provide to third parties sensitive information as stipulated by the Act on the Protection of Personal Information such as race, creed, and criminal record as well as information related to labor union affiliation, family origin, legal domicile, and healthcare, and 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 Customers’ Personal Data 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, in other cases stipulated by the Act on the Protection of Personal Information, or when we have obtained the customer’s prior consent.

4. Joint Use of Customers’ Personal Data

We may jointly use customers’ personal data as follows.

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

5. Handling of Personal Information of Officers, Employees, Etc.

• Purposes of Use
  The Company shall use the personal information of its officers, employees, etc. (including former officers, former employees and their dependents; the same applies hereinafter) to the extent necessary to achieve the following purposes of use.
  • Procedures related to joining and leaving the Company
  • Personnel and labor management (personnel evaluation, assignment (including secondment and transfer), attendance management, optimal allocation of human resources within the Group, prevention of duplicate hiring, etc.)
  • Wage management (determination, calculation and payment of salaries, bonuses, lump-sum payments, corporate pensions, retirement allowances, etc., and procedures related to social insurance and taxation, etc.)
  • Health management (health checkups, stress checks, health guidance, mental health support, prevention of overwork, etc.)
  • Operations related to employee benefits (including confirmation of eligibility for and administration of various programs)
  • Security management (crime prevention, disaster prevention, occupational safety and health, etc.)
  • Business management (business communications, preparation of various reports, response to internal audits, etc.)
  • Human resource development and career support (identification and selection of high-potential talent, provision and sharing of training and education programs, etc.)
  • Analysis and utilization of personnel data (statistical processing, setting of KPIs such as labor share, formulation of personnel systems and measures, etc.)
  • Notifications and reports to, and responses to inquiries from, government agencies, etc. based on laws and regulations, and other legal compliance and audit response (data management for compliance with and audits under the Labor Standards Act, the Act on the Protection of Personal Information, etc.)
  • Other matters related to operations necessary for labor management and company operations
  Health information (information related to healthcare) of officers, employees, etc. shall be acquired in accordance with the Industrial Safety and Health Act and other laws and regulations, and shall be handled only to the extent necessary to achieve the purposes of use such as health management.
• Joint Use of Personal Data of Officers, Employees, Etc.
  Pursuant to Article 27, Paragraph 5, Item 3 of the Act on the Protection of Personal Information, the Company jointly uses the personal data of officers, employees, etc. as follows.
  • Items of Personal Data to Be Jointly Used
    Basic information (name, date of birth, age, gender, nationality, address, telephone number, e-mail address, facial photograph, employee number, and other identifiers); personnel information (department, position, rank/grade, hiring category, work history, transfer history, personnel evaluations, commendations/disciplinary actions, and years of service); wage-related information (salary, bonuses, retirement allowance, social insurance, and attendance status); family and relative information (information on dependents); physical and health information (results of health checkups, health guidance, and information related to mental health); and ability and qualification information (qualifications held, history of education and training, and results of various assessments)
    *Individual Numbers (My Number) and Specific Personal Information are not subject to joint use.
  • Scope of Joint Users
    Samty Asset Management Co., Ltd. and its parent company and affiliated companies (the companies covered may increase or decrease due to changes in capital relationships, etc.)
  • Purposes of Use by Joint Users
    The personal data shall be used within the scope of the purposes of the following operations conducted jointly among the joint users listed in (ii) above: personnel and labor management (including personnel evaluation, assignment (including secondment and transfer), and attendance management); wage management (including determination of salaries, bonuses and lump-sum payments, and payment of retirement allowances and corporate pensions); health management (including health checkups, health guidance, mental health management, and prevention of overwork); employee benefits (including confirmation of eligibility for and administration of various programs); security management (including crime prevention, disaster prevention, and occupational safety and health); business management (including business communications, preparation of various reports, and response to internal audits); management of recruitment and transfers (including optimal allocation of human resources within the Group and prevention of duplicate hiring); human resource development and career support (including identification and selection of high-potential talent, and provision and sharing of training and education programs); analysis and utilization of personnel data (including statistical processing, setting of KPIs such as labor share, and formulation of personnel systems and measures); and legal compliance and audit response (data management for compliance with and audits under the Labor Standards Act, the Act on the Protection of Personal Information, etc.).
    *Each of the above purposes of use sets forth the scope anticipated by each joint user, including the future development of the Group’s management structure, and personal data shall be used only to the extent necessary for the relevant operations when each joint user carries out such operations. Accordingly, this does not mean that joint use is currently conducted for all of the above purposes.
    No joint user shall use the personal information of officers, employees, etc. beyond the scope of the purposes of use set forth in its own privacy policy, etc.
  • Person Responsible for the Management of the Personal Data
    Samty Asset Management Co., Ltd. (for its address and the name of its representative, please refer to the “Company Profile”)
• Other Handling
  With respect to security control measures, restrictions on provision to third parties, and supervision of outsourcing contractors in relation to the personal data of officers, employees, etc., the other provisions of this Policy shall apply mutatis mutandis (with “customers” read as “officers, employees, etc.”).

6. Security Control Measures for Personal Information

As part of establishing a framework for the security management of personal information, the Company shall take (i) organizational security control measures, (ii) human security control measures, (iii) physical security control measures, and (iv) technical security control measures, as appropriate to the actual circumstances. We shall also periodically educate our personnel on the protection of personal information.
We shall maintain accurate and up-to-date personal data of our customers to the extent necessary to fulfill the purpose of use, shall endeavor to delete personal data without delay when it is no longer necessary for the purpose of use, and shall manage customers’ personal data appropriately and diligently.

7. Outsourcing of Personal Information Processing

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

8. Procedures for Requests for Disclosure, Correction, Etc. of Customers’ 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. Requests for disclosure, etc. and inquiries concerning the retained personal data of officers, employees, etc. should be directed to the Contact for Inquiries in 9 below.

• Method of Request
  Please fill in the prescribed items on (i) the request form designated by the Company, attach (ii) the required documents, and send them by postal mail to the address below. When requesting disclosure, please also enclose (iii) a fixed-amount postal money order (fee: 500 yen).
  *No fee is required for requests for correction, suspension of use, deletion, etc.
  
  • To the Personal Information Consultation Desk, Samty Asset Management Co., Ltd.
    20F Marunouchi Trust Tower Main, 1-8-3 Marunouchi, Chiyoda-ku, Tokyo 100-0005, Japan
  ★Please write “Request Documents for Disclosure, Etc. Enclosed” or “Request Documents for Correction, Etc. Enclosed” in red on the envelope.
• Company-Designated Request Forms
  Request Form for Disclosure: EXCEL Version　PDF Version (Click to download)
  Request Form for Correction, Etc. (including correction, suspension of use, deletion, etc.): EXCEL Version　PDF Version (Click to download)
  *If you are unable to download the request forms, please contact us via “9. Contact for Inquiries” below.
• Required Documents (For identity verification, please prepare the required documents according to the following categories.)
  
  • Requests made by the customer in person
    A. Certificate of residence
    B. Copy of identification issued by a public institution (e.g., driver’s license)
    
  • Requests made by proxy
    (i) For legal representatives (all of documents A to C below)
    　A. Documents proving the right of legal representation
    　　・For those representing minors: A 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 proxies other than those in (i) above (all of documents A to E below)
    　A. Power of attorney (stamped with the registered personal seal)
    　B. Certificate of the customer’s registered seal
    　C. Certificate of residence of the customer
    　D. Certificate of residence of the proxy
    　E. Copy of the proxy’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 (the customer) stated 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; they will be retained for one year after our response to the request for disclosure, correction, etc. 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 shall be stated in the written response. Please note that the fee cannot be refunded even in the case of non-disclosure.
  • If the identity of the person cannot be verified due to a discrepancy between the information in the request and the information held by the Company, etc.
  • If the fee associated with the request has not been paid
  • If the authority of representation cannot be verified in a request made by a proxy
  • If, in addition to ① above, there is any deficiency in the prescribed documents
  • If the subject of the request does not fall under “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 the request cannot be complied with due to provisions of relevant laws and regulations, etc.
• Cases in Which Requests for Correction, Suspension of Use, Deletion, Etc. Cannot Be Complied With
  Upon receiving a request for correction, suspension of use, deletion, etc., we shall conduct a fact-finding investigation without delay within the scope of the purpose of use and process the request based on the results; however, we cannot comply with the request if any of the items in (6) above (excluding ②) applies. In such case, the reason shall be stated in the written response.

9. Contact for Inquiries

Inquiries regarding the handling of personal information are accepted by the following methods.

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