Enacted January 20, 2016
Revised February 27, 2017
Revised May 25, 2017
Revised November 1, 2019
Revised June 29, 2020
1. Basic Policy on Handling of Personal Information
We understand that personal information is an important information asset and, recognizing that its acquisition, management and use to the extent necessary for business is not only a legal requirement but also our social responsibility, we comply with the following basic policy.
- We acquire personal information by appropriate and lawful means to the extent necessary to achieve our stipulated purposes of use. We do not acquire personal information in a manner that is deceptive or otherwise fraudulent or that unjustly infringes the interests of the individual. In addition, we do not acquire sensitive personal information without the consent of the individual unless otherwise stipulated by laws and regulations.
- We store and manage acquired personal data in an accurate and up-to-date state and endeavor to delete such personal data without delay when it is no longer necessary to use it. In addition, in order to prevent unauthorized access, leakage, loss, damage or alteration of personal data, we thoroughly educate employees and take necessary and appropriate measures to safely manage it.
- We do not handle acquired personal information beyond the scope necessary to achieve our stipulated purposes of use except in cases where we have obtained prior consent from the individual or in exceptional cases permitted by laws and regulations.
- We endeavor to respond appropriately and promptly within a reasonable period of time when we receive a complaint regarding the handling of personal information. For inquiries regarding our handling of personal information, please contact us using the information in 8. below.
2. Purposes of Use of Personal Information
We handle personal information only to the extent necessary to achieve the purposes of use set forth below, except in cases where we have obtained prior consent from the individual or in exceptional cases permitted by laws and regulations. In addition, when acquiring personal information described in a contract or other document directly from the individual, we specify the following purposes of use to the individual beforehand. However, we may not specify the purposes of use when they are clear from the context of the acquisition or otherwise recognized by laws and regulations.
- To exercise unitholders’ rights or fulfill our obligations to unitholders based on the Act on Investment Trusts and Investment Corporations (the “Investment Trusts Act”) and other relevant laws and regulations for investment corporations that entrust asset management to us (the “Investment Corporations”). To fulfill our other obligations and exercise our rights as well as execute any work incidental to this.
- To exercise investors’ rights or fulfill our obligations to investors based on the Financial Instruments and Exchange Act (the “Financial Instruments Act”) and other relevant laws and regulations in relation to customers who entrust asset management to us as an investment management business based on the Financial Instruments Act, customers to whom we provide investment advice and customers of our Type II financial instruments business as well as between those investors and our customers.
- To prepare and submit various reports for our investment corporations and customers based on the Investment Trusts Act, Financial Instruments Act and other relevant laws and regulations and prepare various data and manage information related to unitholders of the Investment Corporations and investors of our customers.
- To execute asset acquisition, brokerage, sale, transfer, lease and management as well as provide related investment advice, information collection, research analysis and examination for the Investment Corporations entrusting asset management to us and our investment management, investment advice and Type II financial instruments business customers.
- To conduct market trend analysis, customer satisfaction surveys and research analysis for product development, etc.
- To execute business related to the Investment Corporations borrowing capital and issuing additional investment units or our customers borrowing and raising capital.
- To notify the Investment Corporations’ unitholders or customers’ investors of investment corporation or customer business
- To respond to inquiries or requests for materials, etc. to the Investment Corporations or customers
- To confirm the Act on Prevention of Transfer of Criminal Proceeds when transacting.
- To provide to third parties to the extent necessary to execute appropriate business.
- To execute business incidental or relevant to the above.
3. Provision of Personal Data to Third Parties
We do not provide acquired personal data to third parties except in the following cases.
- When the individual consents
- When based on laws and regulations
- When necessary to protect a person’s life, body or property, and it is difficult to obtain the consent of the individual
- When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the individual
- When it is necessary to cooperate with national institutions or local public entities or those entrusted to carry out their affairs as stipulated by laws and regulations, and there is a risk of obstructing the execution of these affairs by obtaining the consent of the individual
4. Acquisition of Sensitive Information
Except in cases stipulated in the Guidelines for Personal Information Protection in the Financial Field, we do not acquire, use or provide to third parties sensitive personal information or information on trade union membership, ancestry, homeland, healthcare or sex life (excluding that which falls under sensitive personal information, is disclosed by the individual, a national institution, local public entity, person listed in the Act or Enforcement Rules of the Act or is obvious from the individual’s appearance such as that which can be acquired by seeing or photographing the individual).
5. Supervision of Outsourcing and Subcontractors
When we outsource all or part of the handling of personal data to an outside party, we take appropriate measures to protect personal data based on laws and regulations and implement the necessary and appropriate supervision of the subcontractor to ensure safe management of entrusted personal data.
6. Procedure for Disclosure of Stored Personal Data
If we receive a request for stored personal data disclosure, correction, addition, deletion, suspension of use, elimination or suspension of provision to a third party (“disclosure, etc.”) based on the Act or for notification of purposes of use by our prescribed request form with stipulated ID verification documents attached, we respond appropriately without delay based on laws and regulations as soon as we can confirm that the request is from the individual or a legitimate proxy. Stored personal data is disclosed in writing or by another method agreed to by the individual. However, we may not be able to respond to requests for disclosure, etc. or notification of purposes of use in certain cases such as when there is a risk of harming the life, body, property or other rights or interests of the individual or a third party. In those cases, we will notify the individual or their proxy of the reason without delay. For details of the procedure, please use the contact information in 8. In addition, disclosure of stored personal data may incur a prescribed fee.
7. Continuous Improvement
The contents of this Policy will be applied from the date it is posted on this website. We strive to improve our management of personal information by continuously reviewing its contents and revising it as necessary. If the contents of this Policy are revised, we will immediately post it on our website.
Please use the following contact information for inquiries regarding our handling of personal information, requests for disclosure of stored personal data, requests for notification of purpose of use and complaints. Inquiries Regarding Matters Stated in Unitholder Registries of the Investment Corporations
Inquiries Regarding Matters Stated in Unitholder Registries of the Investment Corporations
Please use the following information to contact the unitholder registry administrator to correct, add to or delete items in the unitholder registries of the Investment Corporations.
|Name||Securities Agency Department, Sumitomo Mitsui Trust Bank, Ltd.|
|Address||2-8-4 Izumi, Suginami Ward, Tokyo 168-0063|
|Business Hours||9 a.m. to 5:00 p.m. (excluding Saturdays, Sundays, public holidays, etc.)|
Inquiries Regarding Other Personal Information
Please use the following information to contact us to correct, add to or delete personal information other than the above.
|Name||Operations Management Department, NTT Urban Development Asset Management Corporation|
|Address||1-5-1 Otemachi, Chiyoda Ward, Tokyo 100-0004|
|Business Hours||9 a.m. to 5:30 p.m. (excluding Saturdays, Sundays, public holidays, etc.)|
We are also members of the Investment Trusts Association, Japan and the Japan Investment Advisers Association, both personal information protection organizations authorized under the Act on the Protection of Personal Information Protection. These associations accept consultation and complaints regarding member companies’ handling of personal information. Their contact information for inquiries is as follows.
Contact for Investment Trusts Association, Japan
Investor Consultation Office, Member Research Department, Investment Trusts Association, Japan
Contact for Japan Investment Advisers Association
Personal Information Desk, Complaint Consultation Office, Japan Investment Advisers Association