HJ Asset Management K.K. (the “Company”) will strictly manage the personal information of customers in accordance with the Personal Information Protection Law (the “PIPL”) 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 PIPL, laws and regulations related to our business, and other related and incidental laws and regulations

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 described below【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. Sharing Use of Personal Data

The Company may jointly need to use the personal information of customers within the purposes.

For the handling of shared use of personal data, please see described below【Sharing Use 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. Safety 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, as well as conduct appropriate supervision of our officers and employees and of contractors to whom we entrust the handling of personal information, etc., and inspect their compliance status, while also appropriately addressing complaints.

6. The Accuracy of Data Contents

The Company shall strive to keep personal data accurate and up to date within the scope necessary to achieve a utilization purpose.

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

The Company accepts request for disclosure and/or correction of personal data of customers held by the Company, under PIPL. 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 described below【Request for Disclosure and/or Correction of Personal Data】.

The Company also accepts complaints and inquiries regarding handling of personal information of customers. Please contact our sales person or the following contact for further details.

<Contact>

HJ Asset Management K.K.
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. The Company is a target business enterprise of the following accredited personal information protection groups.

<Name of accredited personal information protection group and contact>

Japan Securities 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

9. Continued Improvement of Statement on Protection of Personal Information (Privacy Policy)

In order to ensure the safety 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 website:  www.hjasset.com

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 and Exchange 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 building lots and buildings transaction or lease of building lots or buildings;
4. Real property management business;
5. Business of conducting the 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 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 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 identification 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, evaluation, and storage of records related to transactions with customers;
9. For management and internal administration of the Company;
10. For other uses required for proper and smooth performance of transactions with customers;

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

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

For requests for notification of purpose of use, disclosure, correction, addition, deletion, suspension of use, elimination, or suspension of provision to a third party (hereinafter referred to as “demand etc. for disclosure etc.”) of personal data held by the Company from the person himself/herself or his/her representative, please fill in the necessary items on the request form provided by the Company, attach documents confirming the identity (the documents listed in (2) below), and send it to the Company contact below.

1. Document prescribed by the Company

　　Personal Information Disclosure Request Form

　　＊ Please fill out the any form with your request.

2. A copy of the identity verification document (one of the following)

　　ⅰ. If the claimant is the person.

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 claimant is a representative.

In addition to the identification documents of the proxy (the documents listed in i above), the following documents must be submitted.

　　(a) In the case of a legal representative, a copy of the family register, a copy of the adult guardianship registration certificate, or other document that confirms the authority of legal representation.

　　(b) In the case of a voluntary agent, a letter of attorney from the subscriber himself/herself and a certificate of seal registration of the subscriber himself/herself.

<Contact>

HJ Asset Management K.K.
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 “demand etc. for disclosure etc.”

The company may ask you to pay a handling fee for demand etc. for disclosure etc.

4. How to answer

With regard to requests for demand etc. for disclosure, etc. received by the Company, the Company will confirm and investigate the details of the request, and contact the person in question by the method of response he or she has requested. If the person does not specify a method of response, we will contact the person in writing.

There are cases in which we may not be able to respond to a request for disclosure, etc. if responding to the request may harm the life, body, property, or other rights or interests of the person in question or a third party, if it may seriously impede the proper conduct of our business, or if it would violate other laws or regulations. In such cases, we will inform you of the reason.

5. Utilization Cease etc.

The Company receive a request to cease use or erase retained personal data that falls under any of the following items, we will immediately investigate the details of the request, and if the request is found to be reasonable, we will cease use or erase the data without delay. However, in cases where suspension of use or deletion requires a large amount of money or is otherwise difficult, we may take alternative measures necessary to protect the rights and interests of the person in question.

(a) The case of reason is that the personal information is handled in violation of the provisions of Article 18 of the PIPL.

(b) The case of personal information has been obtained in violation of Article 20 of the PIPL.

(c) The case of personal information has been provided to a third party in violation of Article 27, Paragraph 1 of the PIPL.

(d) The case of the event of a leakage, etc. of personal data handled in accordance with Article 26, Paragraph 1 of the PIPL, or any other situation related to ensuring the security of personal data.

6. Other (Reasons for non-disclosure of retained personal data)

In any of the following cases, the Company will not be able to respond to 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 the fee sent to us.）.

(a) When the applicant’s identity cannot be confirmed.
(b) When the right of representation cannot be confirmed.
(c) In case the documents are incomplete.
(d) When the required fee has not been paid, or the amount paid is insufficient.
(e) The subject of the request for disclosure is not within the scope of the retained personal data.
(f) In the event that a request for correction cannot be made in accordance with the change procedures specified by the Company.
(g) When the reason for suspension of use or deletion does not fall under the reasons set forth in the PIPL.
(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) If the disclosure is likely to significantly impede the proper execution of our business.
(j) When it would violate laws and regulations.
(k) Otherwise provided for in other Act.

③【Sharing Use of Personal Data】

The Company may share the personal data of our customers obtained by us in accordance with the PIPL, and regulations as follows.

The shared use of personal data by the Company will be 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, place of work;
⑦　Nationality;
⑧　Email address;
⑨　Deal information;
⑩　Real Estate Information; and
⑪　contractual information

2. Scope of entities that data can be shared.

The data can be shared users are our affiliated companies Housing Japan K.K., K.K.Trunk Room Tokyo, and Ken’s Place K.K.

< Purpose of use by entities who share use >

Please see below for the purposes of use at each entities listed in the scope of share users.

(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. The Chief Personal Data Controller is responsible for the management of personal data.

The Chief Personal Data Controller: HJAM (https://hjasset.com/en/company-information/)

④【Safety Management Measures for Handling Personal Information】

1. Formulation of basic policy

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

2. Development of regulations concerning handling of personal data

We have established rules for handling personal data, including handling methods, responsible persons/persons in charge and their duties at each stage of acquisition, use, storage, provision, deletion/disposal, etc., in accordance with the “Guidelines Concerning Protection of Personal Information in the Financial Sector” established by the Personal Data Protection Commission and the Financial Services Agency, as well as 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 the employees who handle personal data and the scope of personal data handled by such employees, and establishes a system for reporting to the person responsible in the event that the Company becomes aware of facts or signs of violation of laws or handling regulations.

(b) Regarding handling personal data, we conduct self-check regularly and audits by staff members from other departments.

4. Human measures

(a) Regarding personal data handling-related precautions, we provide our employees with training regularly.

(b) Personal data-related confidentiality clauses have been incorporated into rules of employment.

5. Physical measures

(a) In the area where personal data is handled, we control our employees for entry/exit and restrict the devices they are allowed to carry. We also have implemented the measure in which unauthorized employees have no access to personal data.

(b) We have implemented the measures to prevent the theft or loss of devices, electronic media, books, etc., to handle personal data. We also implemented the steps to make personal data not easily identified when the device 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 the personal data-related information system from fraudulent external access or unauthorized software.

7. External environment awareness

In accordance with our approach to economic 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 in the Guidelines for the Protection of Personal Information in the Financial Sector” based on our understanding of the systems for the protection of personal information in japan. and will make a public announcement or notify customers of such measures.

End