HJ Asset Management K.K. (the “Company”) will strictly manage the personal information of customers in accordance with the Act on the Protection of Personal Information (the “APPI”) and this Statement on Protection of Personal Information (Privacy Policy) based on the idea that we should put the assurance of customer confidence first.

1. Compliance with other related laws and regulations

In handling personal information of customers, the Company will comply with APPI, Financial Instruments and Exchange Law, Real Estate Brokerage Act，other related laws regulations and other codes.

2. The purposes of use of Personal Information

The Company will use the collected personal information of customers to the extent necessary for the achievement of the purposes of use, please see【Annex 1】”The Purposes of Use of Personal Information”,  and will not use for any other purposes.

The Company will inform the purposes of use of personal information on the Company’s webpage or in a written notice, etc.

3. Joint Use of Personal Information

The Company may jointly use personal information of customers within the purposes of use. For the handling of joint uses of personal data, please see【Annex 3】“Joint Uses of Personal Data”.

4. Restriction on provision to third parties

Apart from having received prior consent from the customer or allowed by a regulation, the Company will not provide a customer’s personal data to third parties.

5. Security Control Measures for Personal Information

The Company will make efforts to keep personal information of customers accurate and up-to-date. In order to prevent any leakage, loss or damage of personal information of customers, the Company will develop an appropriate internal system by establishing internal rules on the protection of personal information and regularly reviewing and revising such rules as may be necessary; and implement strict security measures. In addition, the Company will examine the status of supervision and compliance by the officers, employees and contractors, and will appropriately work on the handling of complaints.

6. Customer’s Request for Disclosure and/or Correction of Personal Data and Inquiry regarding Handling of Personal Information

The Company accepts request for disclosure and/or correction of personal data of customers retained by the Company under APPI. Any customer may request for disclosure and/or correction of personal data of such customer at any time in accordance with the procedures designated by the Company, please see【Annex 2】”Request for Disclosure and/or Correction of Personal Data”.

The Company also accepts complaints and inquiries regarding handling of personal information of customers. Please get in touch with your main contact at the Company or the following for further details.

<Contact>

HJ Asset Management K.K.

Finance & Administration Department

BPR Place Kamiyacho 7F, 1-11-9 Azabudai Minato-ku, Tokyo Japan

106-0041

Phone: +81-(0)3-3588-8870 (Switchboard)

7. The Company is a target business operator of the following authorized personal information protection organization.

<Name of authorized personal information protection organization and contact information>

Japan Investment Advisers Association

Complaint Consultation Office

Tokyo Shoken Kaikan 7F, 1-5-8 Nihonbashi Kayabacho Chuo-ku,

Tokyo Japan 103-0025

Phone: +81-(0)3-3663-0505

8. Continuous Improvement of Statement on Protection of Personal Information

(Privacy Policy)

In order to ensure the security control of personal information of customers and appropriately handle such personal information, the Company will review this statement from time to time and try to improve this statement on an ongoing basis. Any material change of this statement will be announced on the Company’s webpage below.

The Company’s webpage:  www.hjasset.com

This Privacy Policy was revised on January 1, 2019

HJ Asset Management K.K

【Annex 1】 The Purposes of Use of Personal Information

The Company will use the personal information of customers only to the extent that is required for businesses described below and to achieve purposes for such use.

<Description of Business>

1. Investment Management Business, Type II Financial Instruments Business, Investment Advisory and Agency Business, General Real Estate Investment Advisory Business, and other businesses related thereto (including businesses that may be permitted to handle in the future);

2. Business pertaining to intermediary service of lending and borrowing of money;

3. Business pertaining to real estate brokerage or to lease of building lots or buildings;

4. Real Estate Management Business;

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

<Purposes of Use>

1. For solicitation or sale of real estate related financial instruments, or publication of services related thereto;

2. For performing operations in connection with investment advisory agreement or discretionary investment management agreement made with a customer;

3. For providing investment advisory services;

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

5. For making judgment of reasonability of provision of products and services in accordance with Principle of Suitability, etc.;

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

7. For providing report to customers regarding the results of transactions, the balance of accounts, etc.;

8. For performing operations, review, and storage of records related to transactions with customers;

9. For management and internal control of the Company;

10. For other uses required for proper and smooth transaction processing with customers;

The Company will neither use, nor provide to any third party, the sensitive information related to race, creed, family origin, registered domicile, medical care, past criminal records or the likes for any purposes other than those that are required or considered necessary to perform duties properly.

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

The Company accepts request for disclosure and/or correction of personal data of the customer retained by the Company upon verifying that the person requesting for such disclosure and/or correction is him- or herself and upon completion of the procedures designated by the Company.

【Annex 3】Joint Uses of Personal Data

The joint use of personal data by the Company and a joint user will be as follows.

<Items of personal data to be jointly used>

1.　The items of personal data to be jointly used by the Company and a joint user are as follows:

①　Name;

②　Address;

③　Telephone number;

④　Facsimile number;

⑤　Date of birth (Age);

⑥　Occupation, place of work;

⑦　Nationality;

⑧　Email address;

⑨　Deal information;

⑩　Real Estate Information; and

⑪　Contractual information

<Joint users’ purpose of use>

1. Purpose of using personal information of our customers

(1) Property information will be used to search for potential transaction counterparties.

(2) Property information will be used to place advertisements on the internet, flyers, and elsewhere.

(3) Property information may be registered with the property search system (REINS) run by the appointed real estate information network to search for potential transaction counterparties. In addition, if a deal has been closed, contractual information (information containing a summary of the property involved in a deal that has been closed, the closing date, closing price, but without containing the names of any individual) will be provided to the appointed real estate information network (the organization appointed by the Minister of Land, Infrastructure, Transport and Tourism under the Real Estate Brokerage Act). The appointed real estate information network will be used to provide property information and contractual information to members of the real estate information network, consisting of real estate brokers and public institutions, in the form of electronic data and paper media, to carry out the operations of the appointed real estate information network provided in the Real Estate Brokerage Act.

(4) Personal information will be used to search for potential transaction counterparties for the sale or lease of real estate, to conclude sales, leases, brokerage, management, and other contracts, and to provide services based on such contracts.

(5) Where property management is involved, personal information will be used to execute management operations conducted under contract with the management association of the condominium, etc.

(6) When believed to be of benefit to the customers, in association with the operations of (1) through (5) above, personal information may be used, among others, to inform customers of such products and services offered by the Company and/or affiliated companies, to send customers such products, or to notify customers related after-sales services and particulars of operations for maintenance, etc. if property management is involved.

(7) Personal information will be maintained for the ledgers and their information materials based on Article 49 of the Real Estate Brokerage Act.

(8) Personal information will be used in conjunction with value assessment related to the sale and lease of real estate. Contractual information used for value assessment may be provided to a brokerage client as the “Basis of opinion” defined in Article 34-2 Paragraph 2 of the Real Estate Brokerage Act.   

(9) Joint users may provide personal information to third parties by having prior consent from customers.

2.　The user to jointly use the personal data referred to in 1 above with the Company will be “Housing Japan K.K.” and “Kabushiki Kaisha Trunk Room Tokyo” which is our sister companies.

3.  The Chief Personal Data Controller will manage the personal data referred to in 1 above responsibly.

Chief Personal Data Controller: Masaru Koibuchi, Representative Director