1. Formulation and Continuous Improvement of Rules for Handling Personal Information, Etc.

The Company shall make its directors, officers and other employees understand the importance of protecting personal information, formulate rules for appropriate handling of personal information (including this policy, Rules for Handling Personal Information, and other relevant rules and manuals), and continuously improve their content.

2. Appropriate Handling of Personal Information in Accordance with the Rules, Etc.

In accordance with the Rules for Handling Personal Information and other relevant rules and manuals, the Company shall establish a management framework, taking into account the size and activities of each department, obtain, use, and provide personal information in an appropriate manner, and respond appropriately to the requests from individuals for disclosure, correction, etc., of their personal information.

3. Items Relating to Security Management Measures

The Company shall take security management measures necessary and appropriate for management of personal data including preventing leakage, loss or damage thereof, etc. In addition, the Company shall supervise its employees, contractors, subcontractors, etc. that handle personal data in an appropriate manner when necessary. Of the security management measures for personal data that the Company implements, main contents of such measures are as follows:

(1) Formulation of Basic Policy

• Formulating this Policy in order to ensure the proper handling of personal information and informing individuals of contact persons in charge of handling inquiries and complaints.

(2) Establishment of Rules relating to Handling of Personal Data

• Formulating the Rules for Handling Personal Information with respect to the handling method, responsible persons in charge and their duties, etc. relating to personal information for each stage of obtainment, use, storage, provision, deletion and destruction, etc. thereof.

(3) Organizational Security Management Measures

• By appointing an Overall Information Management Controller in charge of handling personal data as well as clarifying the employees who handle personal data and the scope of such data handled by them, improving the system for reporting and communicating to the Overall Information Management Controller in case of finding any fact or indication which is in breach of the Personal Information Protection Act or the Rules for Handling Personal Information.
• Regularly conducting audits on the status of compliance with the Personal Information Protection Act, this policy, the Rules for Handling Personal Information and other relevant rules and manuals, etc. for the handling of personal data.

(4) Human Security Management Measures

• Providing necessary education and training to its employees, etc. in order to promote and improve the security management of personal data.
• Stipulating the provisions relating to the confidentiality of personal data in the Rules of Employment.

(5) Physical Security Management Measures

• Restricting the devices being brought into the area where the important information system which handles personal information database, etc. is managed, and implementing the measures to prevent access to personal data by any unauthorized persons.
• Implementing the measures to prevent personal data from being identified easily when carrying the devices, electronic media or documents, etc. which handle personal data, including any move within the Company’s office.

(6) Technological Security Management Measures

• Limiting the persons in charge and the scope of the personal information database, etc. by implementing access control.
• Introducing the mechanism which protects the information system handling personal data from external unauthorized access or software.

4. Purposes of Using Personal Information

The Company shall make appropriate use of personal information, to the extent required to achieve the purposes indicated in Section II, “Handling of Personal Information.”

5. Handling of Outsourcing

The Company may entrust the handling of personal data to a third party, insofar as it is necessary to achieve its purposes. In such a case, the Company shall supervise the third party in an appropriate manner, when necessary, in accordance with the relevant laws and regulations.

6. Inquiries

Inquiries concerning the Company's handling of personal information shall be handled by the relevant contact persons, who are listed in Section II, "Handling of Personal Information".

7. Revisions to This Policy

The Company may revise the contents of this policy without notice in order to comply with the relevant laws and regulations and to further improve its personal information protection measures. The latest policy shall be posted on its website.

1. Purposes of Using Personal Information

The Company shall make appropriate use of personal information that it obtains insofar as it is necessary to carry out the business of the Company and the Tokyo Tatemono Group, as follows. Please note that if, at the time of obtaining personal information, the individual in question is notified by the Company or it is otherwise indicated that the purpose of use differs from any of the following, that purpose shall take priority.

(1) Tokyo Tatemono Group’s business

• 1.
  Tokyo Tatemono Group’s business includes various activities conducted by the Company and the Tokyo Tatemono Group companies. The main activities are as follows:
• 1)
  Sales, development, leasing, operation/management, brokerage, consulting, and appraisal of Real estate (office buildings, condominiums, logistic facilities, child and nursing care-related facilities, tourism and leisure facilities, commercial facilities, public facilities such as parking lots, etc.);
• 2)
  Construction and renovation work of and consulting service on buildings;
• 3)
  Development, sales and brokerage of, and consulting service on, investment in co-owner’s share interest in real estate and real estate securitization products
• 4)
  Other activities that fall within the scope of businesses purposes of Tokyo Tatemono Group companies
• 2.
  "Tokyo Tatemono Group companies" refers to subsidiaries and consolidated affiliates indicated in the financial statements of the Company (Tokyo Tatemono Co., Ltd.).

(2) Purposes of Use

The Company shall use the personal information that it obtains for the purposes indicated in 1 to 7 below and provide it to third parties insofar as it is necessary to achieve those purposes.

Relating to Tokyo Tatemono Group’s business

• 1.
  Analyzing customer trends and conducting research/analysis for product development, etc.
• 2.
  Determining stakeholders required for carrying out the Company’s business and providing information of various kinds for carrying out the Company’s business^*
• 3.
  Checking identity and conducting credit checks when receiving applications, entering into contracts, etc., to carry out the Company’s business
• 4.
  Providing various kinds of information relating to promotional activities, execution of applications and contracts, customer satisfaction surveys, etc.^*

Relating to the Company’s business

• 5.
  Providing information about the company* and notices about PR activities such as events, surveys, etc.^*
• 6.
  Verifying the identity of visitors to the Company and recording information about services provided to them
• 7.
  Conducting activities (screening and provision of recruitment information) to recruit the Company’s employees (executives, employees, temporary employees, loaned employees, etc.)^*

• *
  The various kinds of information and notices mentioned above may be provided in person or by means of direct mail (postcard, letter, etc.), phone call, email, or delivery of behavioral targeting advertising using advertisement distribution business operators, etc.

2. Shared Use of Personal Data

The Company and other Tokyo Tatemono Group companies shall share personal data in accordance with the following:

Items relating to shared use

• 1)
  Companies that will share information

  • The Company (Tokyo Tatemono Co., Ltd.) and its subsidiaries and consolidated affiliates indicated in the financial statements of the Company.
• 2)
  Personal data that will be shared

  • Address, name, contact information (phone number, email address, etc.), business card information, workplace information, real estate information, details about correspondence, and other items required for companies’ business.
• 3)
  Purposes of those who share information

  • Information shall be shared insofar as it is necessary in order for such companies that share information to achieve the purposes indicated in Section II-1-(2) above.
• 4)
  Management framework

  • The person responsible for the management of personal data that will be shared (the “Management Representative”) shall be the company which originally obtains such personal data. The corporate name, address, and the name of the representative of the Management Representative are as follows.

3. Provision of Personal Data to Third Parties

Personal data obtained by the Company may be provided to a third party if such provision is required in order to achieve the purposes of use and if it falls under any of the cases listed below. The Company shall suspend the provision of personal data about an individual to third parties if it receives a request to that effect from the individual. However, in cases corresponding to (2) below, the Company may not comply with the request, depending on the details. Please see Section 4, “Contact Information,” below with regard to contacting the Company to request a suspension of provision of information to third parties, to make an inquiry, etc.

(1) Cases where the individual’s consent has been obtained in advance

(2) Cases where provision to a third party without the individual’s consent is allowed by law

• 1.
  Cases where disclosure is required by law, where disclosure is necessary in order to protect the life or assets of an individual but obtaining the individual’s consent is difficult, cases where co-operation with national or local authorities is required and obtaining the individual’s consent may impede activities, etc.
• 2.
  Cases where it does not legally fall under provision of information to a third party
• a)
  Cases where handling of personal data is outsourced to the extent required to achieve the purposes of use
• b)
  Cases where personal data is provided in conjunction with a succession of business
• c)
  Cases where personal data is shared with the parties that share the data (see Section II-2-1 above).

4. Contact Information

If you wish to make an inquiry regarding your personal information provided to the Company or request disclosure, correction, or suspension of use of your personal data, please use the contact information below. For a prescribed procedure for disclosure, correction, or suspension of use of personal data (confirmation of identity, required documents, processing fees, etc.), please see Section III, “Procedures for Disclosure, Etc. of Personal Information.”

1. Brillia Club members and condominium customers
   Business Planning Department, Tokyo Tatemono Co., Ltd.
   Phone no.: 03-3274-0124
   (Click link for more details.)

2. Customers of real estate securitization products
   Invest Plus contact person, Finance Department, Tokyo Tatemono Co., Ltd.
   Phone no.: 0120-877-885

3. Customers of Tokyo Tatemono Brillia Bond (for individual investors)
   Brillia Bond contact person, Finance Department, Tokyo Tatemono Co., Ltd.
   Phone no.: 03-3274-0114

4. Applicants for jobs (new graduates or mid-career recruitment) and internships
   Hiring Manager/Internship Manager, Personnel Department, Tokyo Tatemono Co., Ltd.
   Phone no.: 03-3274-0112
   (Click link for more details.)

5. Inquiries about real estate appraisals, etc.
   Personal Data Disclosure Request Supervisor, Market & Policy Research Department, Tokyo Tatemono Co., Ltd.
   Phone no.: 03-3274-0125
   (Click link for more details.)

6. +OURS members
   +OURS Manager, Leasing & Consulting Department, Tokyo Tatemono Co., Ltd.
   Phone no.: 03-3274-1971

7. Shareholders
   Securities Agent Department, Mizuho Trust & Banking Co., Ltd.
   Phone no.: 0120-288-324

8. Inquiries about office building leasing
   Leasing & Consulting Department, Tokyo Tatemono Co., Ltd.
   Phone no.: 03-3274-1971

9. Inquiries about office building business
   Business Planning Department, Tokyo Tatemono Co., Ltd.
   Phone no.: 03-3274-0140

10. Inquiries about housing business
    Business Planning Department, Tokyo Tatemono Co., Ltd.
    Phone no.: 03-3274-0124

11. Other general inquiries about handling of personal information
    Personal Information Manager, Legal ＆ Compliance Department, Tokyo Tatemono Co., Ltd.
    Phone no.: 03-3274-1390

1. Flow of Procedure

(1) Reception of Claim for Disclosure, Etc.

• To make a Claim for Disclosure, Etc., please contact the person specified in Section II-4 “Contact Information” above.

(2) Delivery of Application Form for Disclosure, Etc. of Retained Personal Data from the Company

• The Company will mail an Application Form for Disclosure, Etc. of Retained Personal Data to the individual.

(3) Submission of the Application Form for Disclosure, Etc. of Retained Personal Data from the individual

• The individual will mail the Application Form for Disclosure, Etc. of Retained Personal Data after completing required items to the address designated by the Company enclosing a copy of the individual’s identity verification documents designated by the Company.

(4) Reply from the Company

• The Company will mail a written reply to the address set out in the Application Form for Disclosure, Etc. of Retained Personal Data.

2. Fees

• If such request from the individual is the one requesting a notice of the purpose of use of personal data, or disclosure of personal data or traceability record of personal data, the Company will collect 1,000 yen for each request as the fee. However, if the postage for such mail exceeds 1,000 yen, the fee will be the full amount of such postage. The Company will not make notice of the purpose of use of personal data, or disclose personal data or (traceability record) of personal data until it receives payment of such fee.

• The fee will be paid by means of mailing the postal money order with fixed amount.