AEON REIT Investment Corporation

Securities Code:3292

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JAPANESE

Privacy Policy

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AEON REIT Investment Corporation (the "Investment Corporation") recognizes the importance of protecting personal information, and it has accordingly established and adheres to the privacy policy (the "Privacy Policy") set forth as follows. In handling personal information, the Investment Corporation complies with the Act on the Protection of Personal Information (the "Personal Information Protection Act") and other relevant laws and regulations and guidelines, and it strives to properly handle, manage and protect such information. In addition, regarding the individual number and specific personal information (respectively defined in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures), the basic policy for the proper handling of the individual number and specific personal information shall be separately established and observed.

1. Basic policy on handling personal information

The Investment Corporation will be in compliance with the basic policy set forth as follows, under the understanding that personal information is an important information asset, and the recognition that it is not only legislative requirements but also the Investment Corporation's responsibility to society to acquire, manage and utilize personal information acquired only to the extent necessary for operations.

(1) The Investment Corporation will acquire personal information through appropriate and lawful means, and only to the extent necessary to achieve the purpose of utilization stipulated by the Investment Corporation. The Investment Corporation will not acquire personal information through fraudulent or other improper means, nor in a manner that would cause unjust harm to the interests of the persons concerned. Furthermore, unless otherwise provided for under laws and regulations, the Company will not acquire personal information requiring special care (as defined in the Personal Information Protection Act; the same shall apply hereinafter) without the prior consent of the person concerned.
(2) The Investment Corporation will endeavor to maintain and manage the personal information acquired to ensure that such information is accurate and up to date to the extent necessary to achieve the purpose of utilization and when the use of said information is no longer necessary, to erase it without delay. It will also take the necessary and proper measures to prevent unauthorized access, leakage, loss, damage or alteration of such information and to ensure its security control.
(3) The Investment Corporation will not handle acquired personal information beyond the scope necessary for the achievement of the purpose of utilization stipulated by the Investment Corporation, with the exception of cases whereby the person concerned has granted prior consent in that regard, or other exceptional cases as permitted by laws and regulations. Moreover, the Investment Corporation will handle such personal information to the minimum extent necessary to pursue the purpose of utilization.
(4) The Investment Corporation will endeavor to appropriately and promptly, within a reasonable period of time, process any complaints or other concerns it receives regarding the handling of personal information. The inquiries office listed in clause 8 hereafter deals with inquiries regarding the handling of such information.

2. Purpose of utilization of personal information

With the exception of cases whereby the person concerned has granted prior consent, or other exceptional cases as permitted by law and regulations, the Investment Corporation will handle personal information only to the extent necessary to achieve the purpose of utilization set forth below. The Investment Corporation will clarify matters to persons concerned beforehand regarding the purpose of utilization of the information listed hereinafter, in cases where a person's personal information stated in the contract or other documents is acquired directly from them; provided, however, the Investment Corporation at times will not disclose the purpose of utilization as permitted by law, including when such purposes are apparent based on the circumstances through which the information was acquired.

(1) To exercise rights of unitholders and to fulfill the Investment Corporation's duties to its unitholders in accordance with the Act on Investment Trusts and Investment Corporations (the "Investment Trusts Act") and other relevant laws and regulations;
(2) To prepare and submit various reports of the Investment Corporation in accordance with the Investment Trusts Act and other relevant laws and regulations, and also to prepare data pertaining to unitholders and to manage such information;
(3) For the Investment Corporation's acquisition, brokerage, sale, transfer, leasing and management of investment assets, and for the performance of duties relating to data collection, research and analysis, and review in that regard;
(4) To perform duties relating to the Investment Corporation's borrowing of funds, issuance of investment corporation bonds, and issuance of additional investment units;
(5) To provide unitholders with notice on information and other specifics relating to the business of the Investment Corporation;
(6) To respond, for instance, to inquiries and requests for information materials made to the Investment Corporation;
(7) To perform duties incidental or related to any of the aforementioned; and
(8) To request advice and other forms of assistance from attorneys at law, certified public accountants, certified public tax accountants, real estate appraisers, judicial scriveners, outside experts and other such professionals in order to achieve the above-mentioned purposes.

3. Provision of personal data to third parties

The Investment Corporation will not provide personal data to any third party without obtaining prior consent from the person concerned, except in the following cases:

(1) Cases in which the provision of personal data is based on laws and regulations;
(2) Cases in which the provision of personal data is necessary for protection of the life, body or property of an individual, and in which it is difficult to obtain consent from the person concerned;
(3) Cases in which the provision of personal data is specially necessary for improving public health or promoting the sound growth of children, and in which it is difficult to obtain consent from the person concerned;
(4) Cases in which the provision of personal data is necessary for cooperating with a state organ or a local government, or otherwise with an individual or a business operator entrusted by such authorities in executing the affairs prescribed by laws and regulations, and in which obtaining the consent of the person concerned is likely to impede the execution of the affairs concerned; or
(5) Cases where the provision of personal data to a third party is permitted under the Personal Information Protection Act.

However, the Investment Corporation sometimes provides personal information to outside entities, upon having deemed that doing so would not be construed as the provision of personal information to a third party under the Personal Information Protection Act. Such arrangements, for instance, involve entrusting certain entities to handle personal information retained by the Investment Corporation, in whole or in part, within the scope necessary to achieve the purpose of utilization of personal information.

4. Acquiring sensitive information, etc.

The Investment Corporation will not acquire, utilize or provide to a third party, any personal information requiring special care and information regarding labor union membership, family origin and domicile of origin, health and medical care, and sexual practices (other than special-care required personal information and information disclosed by the person concerned, the state institutions, local public entities, or the persons set forth in the Personal Information Protection Act or the Ordinance for Enforcement of the Act on the Protection of Personal Information or information obtained by visual inspection or photography which can be identified by its presence), unless doing so is stipulated in the Guidelines on Personal Information Protection in the Financial Industry.

5. Outsourcing and supervision of trustees

When outsourcing the handling of personal data in its entirety or a portion thereof, the Investment Corporation will take appropriate measures to protect such personal data in accordance with laws and regulations, and it will also perform necessary and appropriate supervision over the trustee to ensure the security control of the entrusted personal data.

6. Procedures relating to disclosure, etc. of retained personal data

The Investment Corporation will respond appropriately without delay in accordance with laws and regulations when receiving requests regarding the personal data it retains, such as those that are made on the basis of the Personal Information Protection Act, to give notice of the purpose of use of, disclose, correct, add, delete or utilize such data, or to discontinue its use, or to erase such data, or to discontinue its provision to a third party (hereinafter collectively referred to as "Requests, etc. for Disclosure or others"). Such response will be made as soon as it is verified that the party making the request is the person concerned or a legitimate representative of such person. However, there may be times when it is not possible to handle Requests, etc. for Disclosure or others, under certain circumstances such as when doing so could potentially cause harm to the life, body, property or other rights and interests of the person concerned or a third party. In such cases, the Investment Corporation will provide notice detailing such reasons without delay to the person concerned or the representative of such person.

7. Continual improvement

The Investment Corporation will regularly review the content of this Privacy Policy, appropriately revise it as necessary, and strive to bring about improvement such as to approaches used in managing personal information.

8. Inquiries

Please contact the offices below regarding questions and concerns pertaining to the Investment Corporation's handling of personal information, and also regarding Requests, etc. for Disclosure or others as well as complaints concerning the disclosure, etc. of personal data retained by the Investment Corporation.

For inquiries regarding matters listed in the register of unitholders

Stock Transfer Agency Department of Mizuho Trust & Banking Co., Ltd.
Address 2-8-4, Izumi, Suginami-ku, Tokyo, Japan 168-8507
Telephone 0120-288-324 (Toll free from Japan and in Japanese only)
Business hours 9:00 to 17:00 Japan standard time
(excluding Saturdays, Sundays, national holidays and year-end through New Year holidays)

For other inquiries regarding personal information

Business Administration Department, AEON Reit Management Co., Ltd.
Address 1-2-1, Kanda Nishiki-cho, Chiyoda-ku, Tokyo, Japan 101-0054
Telephone +81-3-5283-6360
URL https://www.aeon-reitm.co.jp/en/index.html
Business hours 9:00 to 18:00 Japan standard time
(excluding Saturdays, Sundays, national holidays and year-end through New Year holidays)

The Asset Manager entrusted with asset management for the Investment Corporation, AEON Reit Management Co., Ltd., is a member of The Investment Trusts Association, Japan, which acts as an authorized personal information protection organization under the Personal Information Protection Act. The Investment Trusts Association, whose contact information is provided below, handles consultations and grievances regarding handling of personal information by its member companies.

For inquiries with The Investment Trusts Association, Japan

Investor Enquiry Section, Member Inspection Dept. The Investment Trusts Association, Japan
Telephone +81-3-5614-8440

Established February 13, 2013
Revised May 30, 2017

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