Privacy Policy

We recognize the importance of the appropriate and secure handling and managing of personal information we acquire for our operations from our customers, clients, and related parties. From the standpoint of privacy, we have established the following basic policy to comply with the laws, regulations, and guidelines, etc. concerning the protection of personal information.

1. Basic policy for protecting personal information

  • We will acquire, use, and provide personal information appropriately, taking into account the nature of our businesses (Financial Instruments Business, Building Lots and Buildings Transaction Business, and businesses incidental and related thereto).
  • We will establish a management system for protecting personal information, and endeavor to properly manage personal information by ensuring our officers and employees comply with SRM’s regulations that set forth rules for appropriately acquiring, using, and providing personal information.
  • We will observe the laws, regulations, guidelines, and other standards concerning the protection of personal information.
  • We will not acquire personal information through false or dishonest means. Moreover, we will not infringe upon the rights of any person without due cause when we acquire personal information from a third party.
  • We will not use the personal data we acquire beyond the extent necessary to fulfill the purpose of use specified beforehand without obtaining the prior consent of the person concerned, unless such use is permitted by laws and regulations.
  • We will not use personal information in a manner that may encourage or induce illegal or unjust acts.
  • We will appoint personnel to be responsible for managing personal data to ensure it is managed appropriately and to prevent the loss, damage, and unauthorized disclosure outside SRM of the information. In addition, we will implement all measures necessary to prevent illegal access of personal information from outside SRM, leakage or loss of personal information, or damage to personal information, and swiftly correct any risk of accidents.
  • We will establish points of contact for complaints, consultation and inquiries related to the handling of personal information to respond to questions and concerns about our privacy practices in an appropriate manner.
  • We will continuously review and improve our privacy policy and the rules and management system for its implementation, taking into consideration future changes in circumstances.

2. Personal information sources and methods for acquiring personal information

We will acquire personal information from the following sources within the extent necessary to fulfill the purpose of use:

  • Personal information provided through applications, agreements, and other documents that are directly filled out and provided by individuals.
  • Personal information provided by subcontractors, etc. or counterparties to contracts in real estate, etc. transactions and other related parties (including other co-owners, quasi co-owners, sectional owners, and partners and candidates for the foregoing in cases where tenants, funds, etc. (defined in 3. below) have co-ownership interests, etc.)

3. Purpose of use

The main business of SRM consists of investing assets entrusted by third parties, providing investment advice to third parties, the Type II Financial Instruments Business, the Building Lots and Buildings Transaction Business, and businesses incidental and related thereto. SRM will use personal information to perform these duties in an appropriate manner. The specific purposes of use of the personal information entrusted to SRM and the personal data it holds include the following:

Purpose of use

  • Asset management services (including financing operations) related to the real estate funds, etc. for which SRM is entrusted with providing investment advice, or investment corporations for which SRM is entrusted with managing assets (these real estate funds, etc. and investment corporations shall be collectively referred to as “funds, etc.”).
  • Services related to purchasing and selling real estate, real estate trust beneficial rights, or equity interests in silent partnerships, functioning as an agent or mediating these purchases and sales, and handling the public offering, etc. of these assets.
  • Intermediary/agency services for real estate leasing.
  • Real estate management.
  • Services connected to examining, conducting related activities, and performing services concerning the acquisition or sale of real estate, real estate trust beneficial rights, or equity interests in silent partnerships, and providing analysis, judgment, and advice, etc. related to these services.
  • Settlement of accounts and other services related to accounting and tax affairs concerning funds, etc.
  • Response to the exercise of rights by unitholders of funds, etc. and other investors (“investors”), and fulfillment of SRM’s obligations to investors, etc. in accordance with the Financial Instruments and Exchange Act, Act on Investment Trusts and Investment Corporations (“Investment Trusts Act”), Companies Act, and other relevant laws and regulations.
  • Conveyance of information, etc. concerning the business of funds, etc. and provision of various forms of assistance for investors.
  • Management, analysis, and provision of information concerning investors, using registers, etc. prepared in accordance with the Financial Instruments and Exchange Act, Investment Trusts Act, Companies Act, and other related laws and regulations.
  • Implementation of various measures to facilitate the relationship between funds, etc. and investors and persons considering the purchase or sale of securities issued by funds, etc. or other interests.
  • Response to inquiries from investors or persons who are considering purchasing or selling securities issued by funds, etc. or other interests.
  • Identity verification procedures performed prior to making an actual transaction in accordance with the Act on Prevention of Transfer of Criminal Proceeds.
  • Performance of human resource operations conducted by SRM (including, but not limited to, recruiting activities and labor management).
  • Internal control and risk management.
  • Other business ancillary to each of the foregoing.
  • Provision or disclosure of personal information to third parties to the extent necessary for the above purposes of use and to the extent permitted by laws and regulations.

4. Procedures, etc. for conveying or announcing the purpose of use of personal information

We will announce the purpose for using personal data we hold through means such as posts on our own website or displays at our head office. Any change to the purpose of use will be conveyed to the individuals concerned or published on our own website, etc.

5. Safety control measures for personal data

We will endeavor to keep the personal data we acquire as accurate and up to date as possible within the extent necessary to fulfill the purpose of use, and shall wipe it out promptly when its use is no longer necessary under the purpose of use. We will implement necessary and appropriate safety control measures to prevent the leakage, loss, damage of personal data, etc. In addition, we will train and supervise our officers, employees, and other job-related personnel on the protection of personal information to ensure strict control of the personal data held by SRM.

6. Outsourcing the handling of personal information

When we entrust the handling of personal data to an external party, we will select an appropriate trustee, enter into the mandatory contracts, and ensure the necessary and appropriate management and supervision.

7. Entrusted operation concerning the handling of personal information

When we are entrusted with the handling of personal data, we will strictly manage and use the entrusted personal data within the scope of the purpose of use stated in the corresponding contracts.

8. Provision of personal information to third parties

We will not provide personal information to any third party, except in the following cases:

  • Cases in which the individual has given consent in advance.
  • Cases in which the provision of personal data is required by laws and regulations.
  • Cases in which it is otherwise difficult to obtain the individual’s consent, and where the provision of personal data is necessary to protect human life, limb, or property.
  • Cases in which it is difficult to obtain the individual’s consent and where the provision of personal data is particularly necessary to enhance public health or promote healthy development of children.
  • Cases in which a national institution, local public organization, or a fiduciary thereof is obligated to cooperate with the performance of a statutory mission, and where obtaining the person’s consent may interfere with the performance of this mission.
  • Cases in which we outsource the handling of personal data to an outside contractor to the extent necessary to achieve the purpose of use in accordance with 6. above.
  • Cases in which we provide personal data associated with succession of business due to a merger, etc.
  • In addition to the above, as otherwise stipulated in the Act on the Protection of Personal Information.

9. Procedures for disclosure, etc.

When an individual requests the notification of purpose of use, disclosure (including disclosure of records of provision to third parties), correction, addition, deletion, wiping out or the suspension of use, etc. of the personal data we hold, we will seek to respond to the request in accordance with laws and regulations after confirming the request is from the actual individual. However, any request for the disclosure, etc. of matters described in the register of investors of an investment corporation whose assets we manage should be directed to the administrator of the register. Please contact us by mail or in person when you wish to have your personal data in our possession disclosed or otherwise processed. If you contact us by mail, please enclose a copy of your personal identification data, such as your driver's license. If you contact us in person, please bring the original or a copy of your personal identification data, such as your driver's license. Please submit this request to the contact listed below in 10. Be aware that our company may charge a processing fee to process the disclosure, etc. of this information.

10. Contact information for inquiries or complaints about the handling (including safety control measures) of personal information

Corporate Coordination Department, Sumisho Realty Management Co., Ltd.

Tel. 03-4346-0571 (main phone number)
Hours 9:30 am to 6:00 pm Japan Standard Time (excluding Saturday, Sunday, public holidays, and holidays prescribed by SRM)

Note that inquiries about matters described in the register of investors of an investment corporation whose assets we manage should be directed to the administrator of the register. Please submit inquiries to the contact indicated below.

Administrator of the register of investors

Stock Transfer Agency Business Planning Department, Sumitomo Mitsui Trust Bank, Limited.

Place of business 4-1 Marunouchi 1-chome, Chiyoda-ku, Tokyo
Address 2-8-4 Izumi, Suginami-ku, Tokyo
Tel. 0120-782-031
Hours 9:00 am to 5:00 pm Japan Standard Time (excluding Saturday, Sunday, public holidays, and holidays prescribed by the bank)

SRM is a target entity of the Investment Management Association of Japan, the Association is organization authorized to protect personal information and accept consultation requests and complaints, etc. about the target entities’ handling of personal information.

Investor Consultation Office, Membership Audit Department, Investment Management Association of Japan

Tel. 03-6821-8756
Hours 9:00 am to 11:30 am, and 12:30 pm to 5:00 pm Japan Standard Time (excluding Saturday, Sunday, public holidays, and holidays prescribed by the Association)

11. Name, address, and name of representative of personal information handler

Name Sumisho Realty Management Co., Ltd.
Address 1-17-10 Kyobashi, Chuo Ward, Tokyo
Name of representative Yukinari Shiraishi, President
  • February 16, 2009
  • July 18, 2014
    December 12, 2014
    May 30, 2017
    March 1, 2019
    June 1, 2019
    December 17, 2022
    June 27, 2023