Privacy Policy

We recognize the importance of appropriately and securely managing the personal information collected for our operations from our customers, clients, and related parties. In pursuit of these objectives, we have established the following basic policies for compliance with the laws and guidelines concerning the protection of personal information.

Basic Policies

1. 1. We will properly collect, use, and provide personal information for our businesses (Financial instruments business and Real estate business).
2. 2. We seek to properly manage personal information by familiarizing our officers and employees with Company regulations stipulating the proper collection, use, and provision of personal information as well as establishing a management system to protect personal information.
3. 3. We will only collect, use, and provide personal information as necessary for business purposes and not for any other purpose; in addition, we will prevent the use of collected personal information for any other purpose.
4. 4. We will observe laws, government guidelines, and other regulations concerning personal information.
5. 5. We will appoint personnel responsible for managing personal information to ensure appropriate management and prevention of unauthorized disclosure; in addition, we implement all measures to prevent illegal access, leakage, loss, or damage to personal information and swiftly correct any risk of accidents.
6. 6. We will ensure that privacy practices only apply to fulfilling the purposes of use without prejudice for the rights of our customers.
7. 7. We will appoint personnel responsible for providing privacy contact information to properly respond to questions and concerns about privacy practices.
8. 8. We will review and improve our privacy policy and implement rules and systems on a continued basis according to changes in future situations.

Privacy Practices

We have stipulated the following privacy practices according to Act on the Protection of Personal Information and other related regulations for us to collect and manage the personal information of our customers, clients, and concerned parties.

1. 1. Our position on privacy:
   We stipulate and enforce privacy policies and privacy regulations to respect and preserve the spirit of Act on the Protection of Personal Information; we will treat personal information appropriately under the supervision of Privacy Managers.
2. 2. Personal information and its purposes:
   We collect the following types of personal information for the following purposes:

	Type of personal information	Purpose
(1)	Information on owners, tenants, subtenants, co-occupants, guarantors, and other related parties to the real estate or the trust estate of beneficial interest in real estate trusts.	・ Asset management for real estate fund business務 ・ Trading in real estates, beneficial interest in real estate trust or anonymous partnership capital investment interest, etc., or operations related to brokerage, agency, solicitation, etc., for the above. ・ Brokerage/agency for real estate leasing. ・ Real estate management. ・ Operations related to examinations, activities, implementations and other similar operations, and analyses, decisions, advices, etc., concerning acquisition or sale of real estates, beneficial interest in real estate trust or anonymous partnership capital investment interest, etc. ・ Operations incidental to the operations above. ・ Disclosure of information to third parties to fulfill the purposes above.
(2)	Information on our employees and recruitment and prospective employees.	・ Operations necessary and based on laws for performing labor/personnel management and other operations. ・ Recruitment/selection management ・ Contact with applicants ・ Disclosure of information to third parties to fulfill the purposes above

1. 3.Statement or announcement of purposes for personal information:
   We announce purposes for our acquired personal information through procedures such as postings on the website or displays at the Company.
2. 4.Privacy measures:
   We will carefully implement security measures to prevent leakage, loss, or damage to personal information; in addition, we will train and supervise our officers, employees, and other job-related personnel on the privacy policies to ensure strict control of acquired personal information.
3. 5.Outsourced privacy management:
   For the purpose of control and supervision, we will enter into a necessary contract to outsource any privacy management operation.
4. 6.Consigned privacy management:
   We will strictly manage and use any acquired personal information within the scope of a contract entered into for accepting consigned privacy management operations.
5. 7.Distribution and sharing of personal information:
   To the extent necessary for the purposes under 2 (1), including the purposes required by law, we may, in writing or by mail, electronic medium, e-mail, etc., disclose to third parties acquired personal data such as addresses, names, telephone numbers, jobs, ages, annual incomes, co-occupants, guarantors, and other items concerning real estate leasing, and other items necessary for related operations; in addition, we will discontinue disclosing personal information upon request.
   We will separately implement the necessary measures to share any of our acquired personal information.
6. 8.Contact for disclosure, correction, elimination, etc.:
   You may have our acquired personal data disclosed, corrected, eliminated, or otherwise processed only if they are yours; contact the Company with your identification data (such as driver’s license) including Company forms delivered by mail or in person for disclosure, correction or elimination of you personal data.
   ※You may not have our consigned personal data disclosed, corrected, eliminated, or otherwise processed.
7. 9.Privacy contact information:
   Corporate Division, Sumisho Realty Management Co., Ltd.
   Tel. 03-5547-0571

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