Privacy Policy

1. Basic Policy Concerning Protection of Personal Information

Sakura Sogo REIT Investment Corporation. (hereinafter the "Company") shall comply with the "Act on the Protection of Personal Information" (Act No. 57 of 2003 including subsequent revisions, hereinafter "Personal Information Protection Act"), Law on the use of the number system in order to identify a specific individual in the administrative procedures Act No. 27 of 2013 including subsequent revisions, ( Hereinafter “My Number Law”) and other related laws and regulations of The Investment Trusts Association, Japan and financial instruments exchanges (hereinafter "Financial Instruments Exchanges,) on which the Company is listed and this Privacy Policy, (hereinafter "Laws and Regulations ") and strive to handle personal information in an appropriate manner. Furthermore, the meaning of the terms used in this Privacy Policy shall conform to those used in the Personal Information Protection Act and My Number Law.

2. Acquisition of Personal Information

2-1.	Acquisition of Personal Information The Company shall obtain personal information in an appropriate manner as specified below 5.1 to achieve the purposes of use specified for the proper execution of its business.
2-2.	Acquisition of Individual Number The Company shall obtain Individual Number as required for the administration processes stipulated in 5-2 below. The Company shall obtain Individual Number as soon as it is necessary to obtain it for the Company’s administration processes.
2-3.	Confirmation of ID The Company shall confirm the relevant person’s ID upon the collection of Individual Number according to the procedures described in My Number Law Article 16. In case of the agent, the Company shall confirm the agent’s ID, authorization and Individual Number according to My Number Law.

3. Management of Personal Information

The Company shall implement the necessary and appropriate security control measures according to each stage of information processing such as acquisition, usage and storage of personal information in order to prevent the leaking, loss, or damage thereof.

4. Use of Personal Information

4-1.	Restriction by the use of Personal Information The Company will not use the Personal Information other than for the purposes defined in clause 5-1 below or permitted by law, without the consent of the corresponding person.
4-2.	Use of Specific Personal Information Notwithstanding the previous clause, the Company shall not use Specific Personal Information for purposes other than those defined in article 5-1 below whether with or without the consent of the corresponding person, unless it is necessary to protect life, body or properties and with the corresponding person’s consent or wherever it is difficult to obtain its consent, or is allowed under other Laws and Regulations.

4-1.

Restriction by the use of Personal Information
The Company will not use the Personal Information other than for the purposes defined in clause 5-1 below or permitted by law, without the consent of the corresponding person.

4-2.

Use of Specific Personal Information
Notwithstanding the previous clause, the Company shall not use Specific Personal Information for purposes other than those defined in article 5-1 below whether with or without the consent of the corresponding person, unless it is necessary to protect life, body or properties and with the corresponding person’s consent or wherever it is difficult to obtain its consent, or is allowed under other Laws and Regulations.

5. Purpose of Use

5-1.

Purpose of Use of Personal Information
The Company shall use the personal information retained for the following purposes:

(i)	To perform its business related to the exercise of the rights of all holders of securities issued by the Company and the performance of the Company’s business in accordance with the "Act on Investment Trusts and Investment Corporations" (Act No. 198 of 1951 including subsequent revisions, hereinafter "Investment Trust Act") and other laws and regulations as well as regulations of administrative agencies and Financial Instruments Exchanges.;
(ii)	To prepare data in the investors' registry, prepared in accordance with the Investment Trust Act and manage other information belonging to the holders of securities issued by the Company and provide information to all the holders of securities issued by the Company;
(iii)	To handle and confirm all inquiries and visits to the business conducted by the Company;
(iv)	To perform any necessary investigations and analysis, collection of materials and various notices for the acquisition, sale, lease and other asset management and the performance of other business connected to the assets of the Company;
(v)	To confirm the identity of the concerned parties in application forms and agreements necessary for the performance of the business conducted by the Company;
(vi)	To perform business related or incidental to the business usually conducted by the Company in addition to the above;
(vii)	To disclose and provide personal information to third parties within the scope necessary for the purposes of use described above;

5-2.

Providing Individual Number to the Third Party
Notwithstanding the previous clause, the Company shall not provide Individual Number to any third parties other than those described in each paragraph in article 19 of My Number Law.

(i)	to create an administrative record in relation to the financial instruments transactions;
(ii)	to create an administrative record in relation to fees, charges, contract fees, prize or payment made for other services or rights;
(iii)	to create an administrative record in relation to the payment of rent pursuant to a lease agreement or other payment in connection with a property transaction;
(iv)	to create an administrative record in relation to the payment of distributions, surplus or interests or distribution of other income;
(v)	to create an administrative record in relation to the entitlement of subscription rights or issuance of new investment units of the Company or allocation without contribution; and
(vi)	to create legally required records which require the inclusion of Individual Number.

6. Provision to Third Parties

6-1.

Disclosure and Provision of Personal Information to Third Parties

(1)

The Company shall not disclose or provide personal information to third parties except in the cases listed below:

(i)	The owner of the information gives his/her consent;
(ii)	Pursuant to Laws and Regulations;
(iii)	It is necessary for the protection of the life, body or property of an individual and difficult to obtain the consent of the owner of the information;
(iv)	It is necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the owner of the information;
(v)	It is necessary for cooperating with a state or local government or an entity entrusted with executing the affairs prescribed in Laws and Regulations and obtaining the consent of the owner of the information is likely to obstruct the execution of such affairs;
(vi)	It is provided to parties consigned to execute the business conducted by the Company within the scope necessary for the achievement of the purpose of use thereof;
(vii)	Other cases where disclosure or provision is permitted under Laws and Regulations;

6-2.

Provision of Specific Personal Information to Third Parties
Notwithstanding the above clause, the Company will not provide Specific Personal Information to third parties other than in those situations listed in the Article 19 of My Number Law.

7. Procedures for the Notification or Disclosure of the Purpose of Use of Personal Information

Unless the purpose of use is publicly announced in advance, the Company shall notify the owner of the information of the purpose of use of the personal information acquired by either publically disclosing the same by posting or attaching a document in its place of business, or by posting the fact on the Company website or by providing notification, in writing, via post or email.
If there is a change to the purpose of use of personal information, the Company shall notify the owner of personal information of the changed purpose of use or publically disclose the same in the same manner as described above.

8. Supervision of Consignees

Where the Company discloses or provides personal information to its consignees, it shall obligate such consignees to exercise strict security control measures in order to prevent against loss, misuse and alterations, to the personal information handled thereby and carry out necessary and appropriate supervision of consignees.

9. Disclosure, Correction, Discontinuance of Use and Deletion, etc. of Retained Personal Data

The Company shall manage personal information to ensure that the same is as far as possible accurate and up-to-date. In addition, when a request is received from the owner of retained personal data to disclose, correct, discontinue use or delete the same, or to discontinue its provision to a third party, the Company shall respond appropriately in accordance with laws and regulations upon confirming the identity of the owner of the information.

10. Inquiries Regarding Personal Information

Please address any questions concerning personal information provided or inquiries concerning the disclosure, correction, discontinuance of use, deletion or complaints related thereto to the contact listed below.

Sakura Real Estate Funds Management, Inc
Hiei-Kudan BLDG. 9th Floor,
3-8-11 Kudan-Minami Chiyoda-ku Tokyo
()

TEL No.
Business Hours	from 9:00 AM to 5:00 PM (excluding Saturdays, Sundays, national holidays, Year-End/New Year holidays)

Provided, however, inquiries concerning the matters stated in the investors' registry and administrative affairs related thereto should be addressed to the administrator of the investors' registry below in Japanese.

Stock Transfer Agency Business Planning Department of Sumitomo Mitsui Trust Bank, Limited (Toll-free within Japan: 0120-782-031).

*Revisions
This Privacy Policy are subject to change pursuant to revisions to Laws and Regulations,

Established:  April 1, 2016
Amended:     November 14, 2016
Amended:     May 30, 2017