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Ichigo Group Holdings Co., Ltd. (“IGH”) and the Ichigo Group (“Ichigo Group”, comprised of IGH and its 100% subsidiaries (excluding special purpose entities) Ichigo Real Estate Investment Advisors Co., Ltd., Ichigo REIT Management Co., Ltd., Ichigo Estate Co., Ltd. and Ichigo Solutions Co., Ltd.), hereby establish this Personal Information Protection Policy (“Policy”) in furtherance of their commitment to complying with the Personal Information Protection Law and all other applicable laws and ordinances regarding the protection and handling of personal information in Japan.

 

  1. Fundamental Commitment
    All Ichigo directors and part- and full-time employees regardless of their employment status (“Ichigo Employees”) shall be notified of the contents of this Policy. The Ichigo Group shall establish and maintain this Policy through the implementation of an appropriate corporate governance and internal rule framework.
  2. Acquisition and Use of Personal Information
    The Ichigo Group establishes herewith that personal information shall be acquired and used only to the extent necessary to effect legitimate business purposes.
  3. Objective of Use of Personal Information (Note 1)
    The Ichigo Group shall indicate the objective for its use of personal information through public disclosure or written notification. The Ichigo Group shall use personal information only in accordance with such stated objective and in no case shall the use of personal information exceed the scope of consent received from the relevant person.
  4. Provision of Personal Information to Third Parties (Note 2)
    The Ichigo Group may disclose personal information to third parties to the extent of the stated objective and only if required by applicable law. The Ichigo Group shall not disclose any personal information if so requested by the relevant person unless compelled by law.
  5. Delegation of Handling of Personal Information
    The Ichigo Group may delegate the handling of personal information from time to time to third parties that handle personal information in a legal and appropriate manner. In such case, the Ichigo Group shall supervise such delegated parties as necessary.
  6. Sharing of Personal Information (Note 3)
    The Ichigo Group may share personal information from time to time within the Ichigo Group in accordance with applicable law and for mutual use in accordance with the stated objective.
  7. Measures for Protection of Personal Information
    The Ichigo Group shall take appropriate technological and organizational measures to secure personal information from unauthorized access, loss, destruction, manipulation, and/or disclosure to any third parties.
  8. Internal Rules and Training regarding the Protection of Personal Information
    The Ichigo Group shall establish an internal rule framework and provide appropriate training to Ichigo Employees to raise their awareness regarding the importance of protecting personal information.
  9. Disclosure, Amendment and Cessation of Use of Personal Information
    In the event the relevant person so requests, the Ichigo Group shall immediately disclose, amend and/or cease the use of personal information in accordance with procedures established separately by the Ichigo Group.
  10. Continual Review of Internal Governance Structure
    The Ichigo Group shall, in accordance with all related laws and ordinances, continually review and improve its internal governance structure for protecting personal information.

  11. Inquiries concerning Personal Information
    Please direct inquiries or concerns regarding the use of personal information to the following:

  (1)

Ichigo Group Holdings Co., Ltd.
Compliance Department
1-1-1 Uchisaiwaicho Chiyoda-ku, Tokyo 100-0011
TEL: 03-3502-4806

 
   

For inquiries regarding the Register of Shareholders, etc.:
Mitsubishi UFJ Trust and Banking Corporation
Custody Services Division
7-10-11 Higashisuna Koto-ku, Tokyo 137-8081
TEL: 0120-232-711 (Japanese Only)

 
  (2)

Ichigo Real Estate Investment Advisors Co., Ltd.
Compliance Department or Business Planning Department
1-1-1 Uchisaiwaicho Chiyoda-ku, Tokyo 100-0011
TEL: 03-3502-4886

 
  (3)

Ichigo REIT Management Co., Ltd.
Compliance Officer
1-1-1 Uchisaiwaicho Chiyoda-ku, Tokyo 100-0011
TEL: 03-3502-4891

 
   

For inquiries regarding the unitholders register and other investment unit-related operations:
Sumitomo Mitsui Trust Bank, Limited
Custody Services Division
2-8-4 Izumi Suginami-ku, Tokyo 168-0063
TEL: 0120-782-031 (Japanese only)
   

Ichigo REIT Management Co., Ltd. is a member of the Investment Trust Association of Japan. Please direct any inquiries or complaints concerning the Policy of Ichigo REIT Management Co., Ltd. to:
The Investment Trust Association of Japan
Investment Advisory Desk
TEL: 03-5614-8400 (Japanese only)

 
  (4)

Ichigo Estate Co., Ltd.
Compliance Officer
1-1-1 Uchisaiwaicho Chiyoda-ku, Tokyo 100-0011
TEL: 03-3502-5801

 
  (5) Ichigo Solutions Co., Ltd.
Compliance Department
1-1-1 Uchisaiwaicho Chiyoda-ku, Tokyo 100-0011
TEL: 03-3502-5625

This Policy is effective as of January 1, 2012.

(Note 1)  
1.

Personal information acquired by the Ichigo Group shall be used for the following purposes:

 
(1) To solicit, sell and manage the Ichigo Group’s real estate products, including quasi-partnership (tokumei kumiai) agreements for real estate funds, and to provide services related thereto;
(2) To provide information regarding the solicitation, sale and management of real estate products for the Ichigo Group and affiliated companies;
(3) To assess the appropriateness of providing products and services to clients;
(4) To verify the identity of the related person and any agents of the related person;
(5) To report deposit balances and asset management results to clients;
(6) To carry out business with clients and counterparties;
(7) To carry out legal obligations and contract rights of the Ichigo Group;
(8) To use in research and data gathering and analysis in the course of the Ichigo Group’s business;
(9) To dispose of personal information in an appropriate manner in case of being delegated to do so by third parties;
(10) To provide appropriate information to shareholders and investors and manage shares in the course of the Ichigo Group’s investor relation services;
(11) To report and exchange information with governmental authorities as necessary;
(12) To contact job applicants and keep and manage employee records; and
(13)

To carry out transactions with clients and counterparties as appropriate.

 
2.

In addition to the above, the following purposes shall apply to Ichigo REIT Management Co., Ltd.:

 
(1) With respect to Ichigo Real Estate Investment Corporation (“Ichigo REIT”, securities code 8975), an entity managed by Ichigo REIT Management Co., Ltd., to exercise its rights and duties in accordance with the Investment Trust and Corporation Law and other applicable laws and ordinances;
(2) To properly manage inquiries and visitors to Ichigo REIT;
(3) To carry out business operations of Ichigo REIT in the normal course of business;
(4) To engage in matters such as data gathering and analysis, sending notices, and supplying information as necessary to execute Ichigo REIT's business;
(5) For identification purposes for any applications, contracts, and other documents necessary in the normal course of Ichigo REIT's business; and
(6) To provide personal information to third parties as necessary to carry out (1) to (5) above.
(Note 2)  
1.

The Ichigo Group may, from time to time, acquire personal information in order to provide such information to third parties. In such cases, the Ichigo Group shall act in accordance with the following unless agreed or stipulated otherwise. In the event the affected person so requests, the disclosure of personal information to third parties shall be discontinued.

 
(1)

Personal Information to be Disclosed

The name of persons, addresses and building information regarding real estate transactions, real estate debt, etc.
(2)

Methods of Disclosure
Per writing, mail, telephone, FAX, electromagnetic methods or advertising channels

 
2.

Notwithstanding the foregoing, the Ichigo Group may in the following cases disclose personal information to third parties without the consent of the affected person:

 
(1) In the event disclosure is required by applicable law or ordinance;
(2) In the event receiving timely consent is difficult and disclosure is necessary to protect life or property;
(3) In the event receiving timely consent is difficult and disclosure is particularly necessary for educational purposes or to protect public health; and
(4) In the event necessary to cooperate with governmental or local authorities in their execution of official work where the acquisition of consent from the affected person may interfere with such official work.
(Note 3)  
 

Notwithstanding any provisions regarding the disclosure of personal information to third parties, the Ichigo Group may, from time to time, share personal information within the Ichigo Group in accordance with applicable law and to the extent necessary to achieve the stated objective.

 
(1) Information Sharing Entities
All Ichigo Group companies (including Ichigo REIT)
(2) Subject Information
Names, addresses, building information, etc.
(3) Purpose of Use
As specified in Note 1
(4) Managers responsible for supervision of Personal Information
Compliance Officers of each of the Ichigo Group companies (For Ichigo Group Holdings Co., Ltd., the Head of Compliance and for Ichigo Real Estate Investment Advisors Co., Ltd., the Head of Business Planning)