Statement on Protection of Personal Information

Kiraku Asset Management Inc. (the “Company”) recognizes the importance of protecting personal information and is committed to the proper handling and protection of personal information in accordance with the Act on the Protection of Personal Information of Japan (“APPI”), other applicable laws and regulations, and this Privacy Policy. The Company strives to maintain the trust and confidence of its customers through the appropriate management of personal information.

1. Compliance with related laws and regulations
In handling the personal information of customers, the Company will comply with the APPI, laws and regulations related to our business, and other applicable guidelines.

2. Purpose of Use of Personal Information
The Company will use the collected personal information of customers only to the extent necessary to achieve the purposes described in 【Purpose of Use of Personal Information】 below, and will not use it for any other purposes.
The Company will disclose the purposes of use of personal information on the Company’s webpage or through a written notice, etc.

3. Joint Use of Personal Data
The Company may jointly use the personal information of customers within the scope of the specified purposes.
For details regarding the joint use of personal data, please refer to 【Joint Use of Personal Data】 described below.

4. Restriction on provision to third parties
Except where prior consent has been obtained from the customer or as permitted by laws and regulations, the Company will not provide a customer’s personal data to third parties.

5. Security Control Measures for Personal Information
In order to prevent any leakage, loss, or damage of customers’ personal information, the Company will implement necessary and appropriate security control measures as set forth in 【Safety Management Measures for Handling Personal Information】 below. The Company will also conduct appropriate supervision of its officers, employees, and contractors to whom the handling of personal information is entrusted, inspect their compliance status, and appropriately address complaints.

6. Accuracy of Data Contents
The Company shall strive to keep personal data accurate and up to date within the scope necessary to achieve the purposes of use.

7. Customer’s Request for Disclosure and/or Correction of Personal Data; Inquiries regarding Handling of Personal Information
The Company accepts requests for the disclosure and/or correction of personal data held by the Company under the APPI. Any customer may request the disclosure and/or correction of their personal data at any time in accordance with the procedures designated by the Company. Please refer to 【Request for Disclosure and/or Correction of Personal Data】 described below.
The Company also accepts complaints and inquiries regarding the handling of customers’ personal information. Please contact our sales representatives or the following department for further details.

＜Contact＞

Kiraku Asset Management Inc.
Internal Control Department
NOIR AKASAKA BLDG 12F, 2-11-2 Akasaka, Minato-ku, Tokyo, Japan
107-0052
Phone: +81-(0)3-3588-8870 (Switchboard)

8. Accredited Personal Information Protection Organization
The Company is a business operator covered by the following Accredited Personal Information Protection Organization.

＜Name of accredited personal information protection organization and contact＞

Investment Management Association of Japan (IMAJ)
Investor Consultation Office, Member Inspection Department Tel: +81-3-6821-8756
Business hours: Monday to Friday, 9:00 a.m. to 11:30 a.m. and 12:30 p.m. to 5:00 p.m.
(Excluding national holidays and the year-end/New Year holiday period.)

9. Continued Improvement of the Statement on Protection of Personal Information (Privacy Policy)
In order to ensure the safety control of customers’ personal information and to handle it appropriately, the Company will review this statement from time to time and strive to improve it on an ongoing basis. Any material change to this statement will be announced on the Company’s website below.
The Company’s website: https://www.kiraku-am.com/

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①【The Purposes of Use of Personal Information】

The Company will use the personal information of customers only to the extent necessary to conduct the businesses described below and to achieve the purposes described in 【Purposes of Use】 below.

＜Description of Business＞

1. Investment Management Business, Type II Financial Instruments Business, Investment Advisory and Agency Business, General Real Estate Investment Advisory Business, Real Estate Specified Joint Enterprise Business, and businesses incidental thereto (including businesses that may be authorized in the future).

2. Business pertaining to intermediary services for the lending and borrowing of money.

3. Business pertaining to building lots and buildings transactions, or the lease of building lots or buildings.

4. Real property management business.

5. Business of conducting affairs related to the management of an organ of a Special Purpose Company, based on entrustment by such Special Purpose Company.

＜Purposes of Use＞

1. For solicitation or offering of real estate-related financial instruments, or the publication of services related thereto.

2. For performing operations in connection with investment advisory agreements or discretionary investment management agreements concluded with customers.

3. For providing investment advisory services.

4. For solicitation of other businesses and services that the Company is permitted or licensed to conduct, in addition to the foregoing businesses.

5. For making judgments on the appropriateness of providing products and services in accordance with the principle of suitability, etc.

6. For verification of the principal or agent in charge of a transaction, by confirming whether the person is the customer himself/herself, his/her agent, or a representative of a corporate customer, etc.

7. For providing reports to customers regarding transaction results, account balances, etc.

8. For performing operations, evaluations, and the storage of records related to transactions with customers.

9. For the management and internal administration of the Company.

10. For other uses required for the proper and smooth performance of transactions with customers.

The Company will neither use, nor provide to any third party, sensitive personal information related to race, creed, ancestry, domicile, medical insurance, or criminal history for any purposes other than those required or considered necessary to perform duties properly.

②【Request for Disclosure and/or Correction of Personal Data】

For requests for notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to a third party (hereinafter referred to as “Requests for Disclosure, etc.”) of personal data held by the Company from the individual concerned or his/her representative, please fill out the necessary items on the request form provided by the Company, attach the identity verification documents listed in (2) below, and send it to the Company’s contact address.

1. Document prescribed by the Company
　　Personal Information Disclosure Request Form
　　* Please fill out the form with your request.

2. Identity verification documents (Please provide one of the following)
　　ⅰ. If the requester is the individual concerned:
A copy of a document issued by a public institution, such as a driver’s license, health insurance card, or passport.
* Please mask the insured person’s number and the insured person’s symbol/number.
　　ⅱ. If the requester is a representative:
In addition to the identity verification documents of the representative (the documents listed in i. above), the following documents must be submitted:
　　(a) In the case of a statutory agent, a copy of the family register, a copy of the adult guardianship registration certificate, or other documents confirming the authority of statutory representation.
　　(b) In the case of a voluntary agent, a power of attorney from the principal and a seal registration certificate of the principal.

＜Contact＞

Kiraku Asset Management Inc.
Internal Control Department
NOIR AKASAKA BLDG 12F, 2-11-2 Akasaka, Minato-ku, Tokyo, Japan
107-0052
Phone: +81-(0)3-3588-8870 (Switchboard)

3. Fees for Requests for Disclosure, etc.
The Company may require the payment of a handling fee for Requests for Disclosure, etc.

4. Response Method
With regard to Requests for Disclosure, etc. received by the Company, the Company will confirm and investigate the details of the request, and respond to the individual concerned using the method they have requested. If no response method is specified, the Company will respond in writing.
Please note that the Company may not be able to respond to a request for disclosure, etc., if doing so may harm the life, body, property, or other rights or interests of the individual concerned or a third party; if it may seriously impede the proper conduct of our business; or if it would violate other laws and regulations. In such cases, the Company will notify you of the reason.

5. Suspension of Use, Deletion, etc.
If the Company receives a request to cease the use of or erase retained personal data based on any of the following grounds, it will immediately investigate the details of the request. If the request is found to be reasonable, the Company will cease the use of or erase the data without delay. However, in cases where the suspension of use or deletion requires a large amount of money or is otherwise difficult, the Company may take alternative measures necessary to protect the rights and interests of the individual concerned.
(a) Where the retained personal data is handled in violation of Article 18 of the APPI.
(b) Where the retained personal data has been obtained in violation of Article 20 of the APPI.
(c) Where the retained personal data has been provided to a third party in violation of Article 27(1) of the APPI.
(d) Where the Company no longer needs to use the retained personal data.
(e) Where a leakage, loss, damage, or any other incident specified in Article 26(1) of the APPI has occurred in relation to the retained personal data.
(f) Where the handling of the retained personal data is likely to harm the rights or legitimate interests of the individual.

6. Reasons for Non-Disclosure of Retained Personal Data
In any of the following cases, the Company will not be able to fulfill your request for disclosure, etc. The Company will notify you to that effect with the reason. (Please note that the Company will not be able to refund any handling fees sent to us.)
(a) When the requester’s identity cannot be confirmed.
(b) When the requester’s authority of representation cannot be confirmed.
(c) When the submitted documents are incomplete.
(d) When the required fee has not been paid, or the amount paid is insufficient.
(e) When the subject of the request for disclosure is not within the scope of the retained personal data.
(f) When a request for correction is not made in accordance with the procedures specified by the Company.
(g) When the reason for suspension of use or deletion does not fall under the grounds set forth in the APPI.
(h) When there is a risk of harm to the life, body, property, or other rights or interests of the individual or a third party.
(i) When the disclosure is likely to significantly impede the proper execution of our business.
(j) When it would violate laws and regulations.
(k) When otherwise provided for by other laws and regulations.

③【Joint Use of Personal Data】

The Company may jointly use the personal data of customers obtained by us in accordance with the APPI and applicable laws and regulations as follows.

＜Items of personal data to be shared＞

1. The items of personal data to be shared by the Company are as follows:
(1) Name
(2) Address
(3) Telephone number
(4) Facsimile number
(5) Date of birth (Age)
(6) Occupation and place of work
(7) Nationality
(8) Email address
(9) Transaction information
(10) Real estate information
(11) Contractual information

2. Scope of Entities with Which Data May Be Shared:
The data may be shared with Housing Japan K.K., K.K. Trunk Room Tokyo, and Ken’s Place K.K.

〈 Purposes of Use by Entities Who Share Data 〉
Please refer to the links below for the purposes of use of each entity listed above.
(a) Housing Japan K.K. : https://housingjapan.co.jp/privacy-policy/
(b) K.K.Trunk Room Tokyo : https://trunkroomtokyo.jp/user/privacy-policy/
(c) Ken’s Place K.K. : https://kens-place.com/en/policy/

3. Entity Responsible for the Management of Jointly Used Personal Data:
Kiraku Asset Management Inc. (the “Company”)

④【Safety Management Measures for Handling Personal Information】

1. Formulation of Basic Policy
To ensure the appropriate handling of personal data, we have formulated a basic policy concerning “Compliance with related laws, regulations, and guidelines,” “Contact for inquiries and complaints,” etc.

2. Development of Regulations Concerning the Handling of Personal Data
We have established rules for handling personal data, including handling methods, responsible personnel, persons in charge, and their duties at each stage of acquisition, use, storage, provision, and deletion/disposal. These rules are in accordance with the “Guidelines for the Protection of Personal Information in the Financial Sector” established by the Personal Information Protection Commission and the Financial Services Agency, as well as guidelines from self-regulatory organizations to which we subscribe as a financial instruments business operator.

3. Organizational Measures
(a) In addition to appointing a person responsible for the handling of personal data, the Company clarifies which employees handle personal data and the scope of personal data handled by them. We have also established a system for reporting to the responsible person in the event that the Company becomes aware of facts or signs of a violation of laws or handling regulations.
(b) We regularly conduct self-checks and internal audits by staff members from other departments regarding the handling of personal data.

4. Personnel Measures
(a) We regularly provide our employees with training regarding precautions for handling personal data.
(b) Confidentiality clauses regarding personal data have been incorporated into our employment regulations.

5. Physical Measures
(a) In areas where personal data is handled, we manage employee entry/exit and restrict the devices they are allowed to carry. We have also implemented measures to ensure that unauthorized employees do not have access to personal data.
(b) We have implemented measures to prevent the theft or loss of devices, electronic media, and documents used to handle personal data. We have also taken steps to ensure that personal data is not easily identifiable when devices or electronic media are carried out of the office.

6. Technical Measures
(a) By controlling access, we limit the number of employees who handle personal data and the scope of the personal database and other data.
(b) We have implemented a system to protect personal data-related information systems from unauthorized external access or malicious software.

7. Understanding the External Environment
To ensure data security, we do not store our customers’ personal information outside of Japan.
In the event that we store our customers’ personal information outside of Japan in the future, we will implement security control measures equivalent to those described in the “Practical Guidelines for Security Control Measures, etc.” under the “Guidelines for the Protection of Personal Information in the Financial Sector.” This will be based on our understanding of the personal information protection system of the relevant country, and we will make a public announcement or notify customers of such measures.

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