Japan Senior Living Investment Corporation

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  1. Basic Policy on Personal Information Japan Senior Living Investment Corporation (hereafter, “JSL”) complies with the Act on the Protection of Personal Information (Act No. 57, 2003; as amended; hereafter, the “Personal Information Protection Act”) and related laws, regulations and guidelines; the regulations of the financial instruments exchanges on which JSL is listed (hereafter, “financial instruments exchanges”); this privacy policy; etc. (hereafter, “laws, regulations, etc.”) and endeavors to handle personal information appropriately. Furthermore, the meanings of the terms used in this privacy policy conform to the Personal Information Protection Act.
  2. Obtaining Personal Information JSL obtains personal information only through appropriate means and only to the extent necessary for the purposes of use specified below. Furthermore, it will not use personal information beyond the extent of the purposes of use specified below without the consent of the concerned party except in cases recognized by laws, regulations, etc.
  3. Managing Personal Information As it obtains, uses and holds personal information, JSL will exercise necessary, appropriate and secure management to prevent loss, misuse, modification, etc.
  4. Purposes of Use of Personal Information JSL uses the personal information it collects for the following purposes:
    (i)
    To exercise the rights of holders of securities issued by JSL and fulfill the obligations of JSL in accordance with the Act on Investment Trusts and Investment Corporations (Act No. 198, 1951; as amended; hereafter, “Investment Trusts Act”) as well as other laws, regulations and rules of administrative agencies and financial instruments exchanges (hereafter, “Investment Trusts Act, etc.”) such as reporting on asset management, sending out convocation notices for unitholder meetings and distributions and providing a unitholder benefits program
    (ii)
    To prepare data for the unitholder registry in accordance with the Investment Trusts Act, manage data on owners of securities issued by JSL and provide information to owners of securities issued by JSL
    (iii)
    To respond to or confirm inquiries of business and visits to JSL
    (iv)
    To conduct acquisition of assets (including the securities or credit backing the assets; same hereafter) under the management of JSL as well as the necessary investigation and consideration
    (v)
    To conduct disposition of assets under the management of JSL as well as the necessary investigation and consideration of the buyer or new real estate management company
    (vi)
    To understand and manage leasing to lessees or operators as well as manage the receipt of rental payments, return of deposits and other leasing operations related to JSL’s assets under management
    (vii)
    To verify the credit status of lessees or operators of assets JSL owns or is considering acquiring or parties JSL is considering leasing or entrusting operation to (including buyers and new real estate asset management companies) and fulfill lease agreement obligations
    (viii)
    To carry out duties related to analyzing demand for service improvement surveys of lessees or operators of assets JSL owns or parties to which JSL is considering leasing or entrusting operation
    (ix)
    To carry out duties related to calculating reserves for irrecoverable debt for financial results, other calculations and financial matters
    (x)
    To carry out duties related to providing information to unitholders on financial results briefings, operational status briefings and property tours as well as preparing attendance data
    (xi)
    To carry out duties related to inquiries or requests for materials from unitholders or those considering purchasing securities issued by JSL
    (xii)
    To bill for loss insurance, etc. of assets JSL owns
    (xiii)
    To verify the identification of a party described in an application, agreement or other document for the purpose of conducting the business of JSL.
    (xiv)
    For debt financing, issuance of investment corporation bonds, issuance of new investment units, issuance of investment unit reservation rights or acquisition of JSL investment units
    (xv)
    To disclose or provide personal information to third parties to the extent necessary for the purposes of use set forth in the previous items
  5. Disclosing/Providing Personal Information to Third Parties
    (1)
    JSL will not disclose or provide personal information to third parties except in cases fulfilling 5 (1) or 5 (2).
    (i)
    When the consent of the concerned party has been obtained
    (ii)
    When it is in accordance with laws, regulations, etc.
    (iii)
    When it is necessary to protect the concerned party’s life, health or property and impossible to obtain the consent of the concerned party
    (iv)
    When it is particularly necessary to improve public health or promote healthy child-raising and impossible to obtain the consent of the concerned party
    (v)
    When it is necessary to cooperate with a governmental institution, local public body or individual entrusted as such in accordance with laws, regulations, etc. and obtaining the consent of the concerned party could interfere with the execution of such
    (vi)
    When it falls within the extent of the specified purposes of use and is provided to a third party properly supervised by JSL
    (vii)
    Other cases where disclosure/provision is allowed based on laws, regulations, etc.
    (2)
    Within the extent necessary for the purposes of use specified in 4 (xv) above, JSL’s asset manager, Japan Senior Living Partners, Inc., may provide personal information by e-mail, document, fax, etc. to counterparties or possible counterparties for transactions of assets under management, real estate brokers, financial institutions engaging in ancillary businesses pertaining to real estate transactions, etc., casualty insurance companies, attorneys, judicial scriveners, real estate appraisers, real estate agents, unitholder register administrators, etc. However, provision of personal information to any third party shall cease promptly upon the request of the concerned party.
  6. Notifying/Publicizing Purposes of Use of Personal Information Apart from cases in which the purposes of use are already publicized, JSL will promptly notify the concerned party of the purposes of use of personal information through announcement on the JSL website or by document, post, e-mail, etc.
    When JSL revises the purposes of use of personal information, it will notify the concerned party or publicize them by the above means.
  7. Supervising Entrusted Third Parties JSL, as a registered investment corporation, will require strict, secure management and carry out necessary and appropriate supervision of third parties entrusted with handling personal information for asset management and general administration in order to prevent loss, misuse, modification, etc.
  8. Disclosing, Correcting, Deleting or Discontinuing Use of Personal Information JSL will make every effort to ensure that the personal information it obtains remains accurate and up to date. Moreover, when a concerned party makes a request regarding retained personal information, JSL will, after verifying that the request is from the concerned party, respond appropriately based on laws, regulations, etc. to disclose, correct, discontinue, delete or otherwise.
  9. Inquiring About Personal Information Please use the following contact information for questions, requests or complaints regarding disclosure, correction, deleting or discontinuing use of personal information. Japan Senior Living Partners, Inc.
    2-2-9 Shimbashi, Minato-ku, Tokyo 105-0004
    TEL: +81-3-6206-6460
    Business hours: 9:00-17:00 (closed weekends, holidays, Year-end and New Year Holiday)
    However, for inquiries regarding unitholder registry information, please contact the unitholder registry administrator listed below: Mitsubishi UFJ Trust and Banking Corporation Stock Transfer Agency Department
    7-10-11 Higashisuna, Koto-ku, Tokyo 137-8081
    TEL: 0120-232-711
    Business hours: 9:00-17:00 (closed weekends, holidays, Year-end and New Year Holiday)

*Regarding revisions
This privacy policy is subject to change in accordance with revisions to laws, regulations, etc.

Set on June 8, 2015