Asset Management Company
Simplex REIT Partners
Sponsor
Mizuho Trust & Banking

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Privacy Policy

Privacy Policy

One REIT, Inc. (hereafter referred to as “One REIT”) has formulated and published the following “Privacy Policy” (hereafter referred to as the “Policy”) as its principle concerning protection of personal information and philosophy concerning handling of personal information.

1. Principle

Recognizing appropriate protection and use of personal information as an important social responsibility, One REIT strives to appropriately protect and use personal information of the individual (the person) in compliance with various rules of One REIT including the Policy together with the “Act on the Protection of Personal Information” (hereafter referred to as the “Personal Information Protection Act”) and other related laws and regulations, guidelines etc. Moreover, in regard to personal number and specific personal information (defined in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures), One REIT shall establish a basic policy concerning appropriate handling of specific personal information and comply with it.

2. Appropriate Collection

One REIT collects personal information of the individual (the person) within the scope necessary to perform in lawful and appropriate manners. Moreover, One REIT shall not collect special care-required personal information (defined in the Personal Information Protection Act. The same applies hereinafter) without obtaining the consent of the individual (the person) unless stipulated by laws and regulations.

3. Purposes of Use

One REIT defines the purposes of use of personal information of the individual (the person) and handles the information within the scope necessary to achieve the purposes of use, and shall not use personal information beyond that scope except when consent of the individual (the person) has been obtained in advance and when authorized by laws and regulations, etc.
For the purposes of use concerning handling of personal information of the individual (the person), please refer to One REIT’s website (http://www.one-reit.com/en/).

4. Restrictions on Provision of Personal Data to Third Parties

As a principle, One REIT shall not provide personal data of the individual (the person) to any third parties excluding cases where the prior consent of the individual (the person) has been obtained and where required by laws and regulations, etc. However, in case of outsourcing handling of personal data within the scope necessary to achieve the purposes of use, merger, etc. and in case of using jointly with the specified parties prescribed in Item 5, One REIT may provide personal data of the individual (the person) to any parties other than One REIT without obtaining consent of the individual (the person).

5. Joint Use within the Group

One REIT may, limited to when necessary within the scope below, jointly use personal data it possesses with the following joint users.

(1) Items of Personal Data to be Jointly Used
1)The individual's (the person's) name, date of birth, address, telephone number, e-mail address and other contact information, information regarding family members, information regarding place of employment, information regarding assets and liabilities, information regarding transaction needs and publicly available information
2)Types of respective instruments, services, etc. under transaction, contracted date, transacted amount, balance, due date and other information regarding contents of respective transaction
3)MManagement numbers such as transaction numbers, transaction history information, information regarding transaction judgement and other information necessary for management of transactions
(2) Scope of Joint Users
Mizuho Financial Group, Inc. and its consolidated subsidiaries indicated in the Securities Report, etc. and its affiliated companies accounted for by the equity-method (in case joint use is restricted by the Financial Instruments and Exchange Act and other relevant laws and regulations, handling what should be compliant with such laws and regulations, etc.)
Moreover, the current status such as the name of companies included in the scope of joint users will be posted on the website of Mizuho Financial Group, Inc. (https://www.mizuho-fg.com).
(3) Purposes of Joint Use
1)To make proposals and give guidance on various instruments, services, etc. and for research and development
2)To make judgement when providing various instruments, services, etc.
3)To appropriately implement business management tasks as a group, including understanding and managing various risks
(4) Responsible Party for the Management
Simplex REIT Partners Inc.

6. Handling of Sensitive Information

One REIT shall not collect, use and provide to any third parties special care-required personal information as well as information regarding participation in a labor union, family origin, legal address on family registry, healthcare, sexual life (excludes those that fall under special care-required personal information) in the financial field unless stipulated in the guideline concerning protection of personal information in the financial field (excludes information disclosed by the person, national institutions, local governments, and persons stated in the Personal Information Protection Act or the Ordinance for Enforcement of the Act on the Protection of Personal Information as well as information that clearly shows the external appearance of the person obtained by looking at or taking a photo of the person (hereafter referred to as “Sensitive Information”)).

7. Security Measures / Safeguards

One REIT strives to store and manage the personal information of the individual (the person) accurately and keep it up to date, and erase the data without delay when its use is no longer necessary. One REIT takes the necessary and appropriate security measures/safeguards to prevent the leakage, etc., of personal information of the individual (the person). Moreover, it conducts necessary and appropriate supervision of employees and service providers (including subcontractors, etc.) of who handle personal information of the individual (the person).

8. Continuous Improvement

One REIT reviews the Policy in a timely manner according to the development of information technologies, the changes in social demand, etc. and strives to continuously improve the handling of personal information of the individual (the person).

9. Procedures to Request Disclosure, etc.

One REIT strives to conduct appropriate and prompt responses regarding requests for notification of purposes of use of personal data it possesses concerning the individual (the person), requests for disclosure of the contents, requests for correction/addition/deletion in case the contents of personal data it possesses differ from the fact, etc., and requests for suspension of usage/erasure/cease of provision to any third parties, etc.
Please direct requests for the disclosure, etc., of personal information regarding the individual (the person) One REIT possesses to the “Finance & Administration Division (Tel: +81-3-3242-7153)” of Simplex REIT Partners Inc.

10. Comments & Requests, Complaints, etc.

One REIT strives to deal with comments, requests, complaints, etc. for the handling of personal information sincerely and promptly.
Please direct comments and requests concerning One REIT’s handling of personal information to the “Finance & Administration Division (Tel: +81-3-3242-7153)” of Simplex REIT Partners Inc.
Business hours 9:00 a.m. -5:30 p.m. (Closed Saturdays, Sundays, national holidays, and year-end and new-year holidays)

Simplex REIT Partners, Inc. is a member of the Investment Trusts Association, Japan (JITA; http://www.toushin.or.jp/english/), a certified personal information protection organization. The JITA also accepts inquiries, complaints, etc. concerning the handling of personal information by its members at its Investor Consultation Office.

Investment Trusts Association, Japan
Investor Consultation Office
Tel: +81-3-5614-8440
Business hours 9:00 a.m. -11:30 a.m. and 0:30 p.m. -5:00 p.m. (Closed Saturdays, Sundays, national holidays, and year-end and new-year holidays)/td>

11. Revision of the Policy

Contents of the Policy will be applied from the date it is posted on its website. Furthermore, the Policy may be revised without prior notice in case requested by laws and regulations, etc. or when One REIT believes such is necessary.

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