Privacy Policy

April 2024
Daiwa Real Estate Asset Management Co. Ltd.

The Company establishes and complies with privacy policy as follows, and treats personal information and individual number ("Personal Information, etc.") appropriately pursuant to the Act on the Protection of Personal Information, etc.

1. The Company recognizes the importance of Personal Information, etc. as an individual's valuable asset, and acknowledges its appropriate protection as an important responsibility. To fulfill its responsibility, the Company complies with the Act on the Protection of Personal Information, the relevant laws and regulations, the guidelines of the relevant ministries and agencies, the Company's internal rules, and other norms.
2. The Company shall not use Personal Information, etc. beyond the extent necessary to achieve the purpose of use of Personal Information without the consent of the individual, or the cases subject to laws and regulations allows.
3. The Company shall acquire Personal Information, etc. to the extent necessary for the accomplishment of the purpose of use in an appropriate and lawful manner.
4. The Company shall appropriately manage with a necessary security measure in order not to occur leakage, loss, or the like, regarding Personal Information, etc..
5. The Company shall implement a necessary and appropriate supervision for the entrusted company in the case of entrustment of handling of personal data.
6. The Company shall review this privacy policy in accordance with a change of laws and regulations and continuously improve.
7. The Company will endeavor to appropriately and promptly respond when there is a request for disclosure, correction, deletion, and discontinuation of use, regarding retained personal data.
8. The Company will endeavor to respond to inquiries, requests, and complaints, regarding handling of Personal Information, etc. promptly and sincerely.

Handling of Personal Information, Etc.

1. Purpose of Use of Personal Information, Etc.

The Company mainly engages in the investment management business, investment advisory business and type II financial instruments business.

The Company shall use the Personal Information, etc. to the extent necessary for the accomplishment of the following purposes of use in order to appropriately perform these operations. The investors of these operations' clients (assumed to be investment corporations, funds, etc.; hereinafter collectively referred to as the "investment corporations, etc.") are referred to as the "customers".

1. To ensure the exercise of the rights of the customers and fulfill the obligations of the investment corporations, etc. to the customers pursuant to the Financial Instruments and Exchange Act, the Act on Investment Trusts and Investment Corporations, the Companies Act and other relevant laws and regulations (hereinafter collectively referred to as the "relevant laws and regulations"), and to carry out measures to ensure a smooth relationship among the investment corporations, etc. and the customers
2. To prepare and submit reports and other documents of the investment corporations, etc. in accordance with requirements under the relevant laws and regulations, and to manage information on the customers
3. To respond to inquiries, material requests, etc. concerning fund procurement by the investment corporations, etc.
4. To execute acquisitions, sales, management and leasing of properties of the investment corporations, etc. and to carry out examination, consideration, etc. concerning such (including identification, credit check, rights relations research, etc.)
5. To manage the receipt of rental payments, return of deposits and other operations related to leasing of properties of the investment corporations, etc.
6. To respond to inquiries, material requests, etc. from the customers and those considering trading in the securities issued by the investment corporations, etc.
7. To conduct research, development or improvement of financial instruments and services through implementation of market surveys, data analyses or questionnaires, etc.
8. To perform business operations related to IR activities conducted by the Company
9. To perform human resources and labor management (including wage management, health management, welfare benefits, personnel evaluation, occupational health and safety, etc.), employment screening and hiring procedures and the various post-resignation/retirement communications and procedures of the Company's executives, employees, temporary employees, etc. (including those who have been offered a position and those who have left the Company; the "employees, etc".)
10. To conduct research, examination, conclusion, performance, administration and administrative circular of the agreement in connection with transactions with business partners of the Company
11. To perform business operations related or incidental to the businesses set forth in the previous items; and
12. To provide Personal Information, etc. to third parties within the necessary scope for achieving the purposes of use set forth in the previous items

2. Appropriate Acquisition of Personal Information, Etc.

The Company shall acquire Personal Information, etc. to the extent necessary for conducting business operation.

n addition, the Company will not obtain, use, or provide to any third parties any sensitive information (including, special care-required personal information and information concerning membership of any labor unions, family origin, registered domicile, medical or health care record, etc.), except as permitted by laws and regulations.

3. Appropriate Management of Personal Information, Etc.

The Company will appropriately manage with a necessary security measure in order to prevent leakage, loss, alteration, improper access or the like regarding Personal Information, etc.

(Formulation of Basic Policy)

To ensure appropriate handling of Personal Information, etc., the Company will formulate a basic policy on compliance with relevant laws and regulations, guidelines, etc.; on the contact point for inquiries and complaints; and on other relevant matters.

(Creation of Regulations on Handling of Personal Information, etc.)

The Company will formulate rules on handling of Personal Information, etc., which define, the method of handling Personal Information, etc., people responsible for and in charge of handling Personal Information, etc., their duties, and other relevant matters for each stage including acquisition, usage, storage, deletion and disposal.

(Organizational Security Measures)

The Company will appoint a person responsible for handling Personal Information, etc., clarify the scopes of employees who handle Personal Information, etc. and of Personal Information, etc. handled by those employees, and create a system to contact the person responsible when a violation or a sign of violation of laws or the rules on handling of Personal Information, etc. is found.

(Personnel Security Measures)

The Company will educate and appropriately supervise employees on handling of Personal Information, etc.

(Physical Security Measures)

The Company will control the entry and exit of employees into and from areas where Personal Information, etc. is handled, impose restrictions on devices, etc. that can be brought into such areas, and take measures to prevent unauthorized persons from viewing Personal Information, etc.

(Technical Security Measures)

The Company will introduce a system to protect the information system that handles Personal Information etc. from unauthorized external access or malware.

(Understanding of the External Environment)

When storing personal data and Personal Information, etc. overseas, the Company will take security measures based on an understanding of the relevant country’s systems for protecting personal information.

4. Provision of Personal Data to Third Parties

The Company will not disclose and provide personal data to a third party, without obtaining an individual's consent in advance, for reasons other than following the designations of laws and ordinances and entrusting personal data, but to the extent necessary for achieving the purposes of use.

The Company will not disclose and provide personal data to an overseas third party without obtaining an individual’s consent in advance, except in cases permitted by laws and regulations. When obtaining an individual’s consent, the Company will provide the individual with the country’s name, the country’s systems for protecting personal information, measures taken by the third party to protect personal information, and other information that should be helpful.

5. Entrustment of Handling of Personal Data

The Company may entrust all or a part of the business to the extent necessary for the accomplishment of the purposes of use and provide the necessary personal data to the entity so entrusted. In the case of entrustment, the Company will supervise the entity entrusted by it with necessary and adequate care, including supervision of any entity entrusted by the entity entrusted by the Company.

6. Joint Use of Personal Data

The Company may use personal data of customers jointly within the following scope.

1. Items of Personal Data Jointly Used
   The customers' name, address, date of birth, contact information (such as telephone number or e-mail address), occupation, information regarding the customers such as customers' transaction needs, contents of transaction, information regarding the customers' transaction such as balance on deposit
2. Scope of Joint Users
   Daiwa Securities Group Inc. (the Company's parent company) and its consolidated subsidiaries
3. Purposes of Use of Joint Users
   For management and internal administration of the Daiwa Securities Group
4. Address and representative name of the responsible person for managing the Personal Data

7. Disclosure, Correction, Deletion, Discontinuation of Use, Etc. of Personal Data

When the disclosure, correction, deletion, discontinuation of use or the like ("disclosure etc.") regarding retained personal data are asked by the person himself/herself or his/her agent, the Company will respond in writing, other methods within a reasonable period and to a reasonable extent except for the case where, based on laws and regulations, disclosure etc. is not required, after confirming that it is a request from the person himself/herself. Please contact the “Reception Counter for an Inquiry, Etc.” below.

8. Inquiry, Request, Complaint, Etc. About Handling of Personal Information, Etc.

The Company will endeavor to respond to inquiries, requests, complaints, regarding handling of Personal Information, etc. promptly and sincerely. About an inquiry about handling of Personal Information, etc., please inquire with the contact below.

Reception Counter for an Inquiry, Etc.

Customer Service Representative of Daiwa Real Estate Asset Management Co. Ltd.

9. Accredited Personal Information Protection Organization

The Company is a Member of Japan Investment Advisers Association, which is an accredited personal information protection organization as accredited by Financial Services Agency. The Association's Investor Enquiry Section takes complaints and consultations concerning the handling of personal information of members.

Contact for Complaints and Consultations

Investor Enquiry Section of The Investment Trusts Association, Japan