HEIWA REAL ESTATE REIT, Inc. ("the REIT") believes that compliance and strong internal management systems are important issues for a company that aims to be worthy of society's trust.
Under this philosophy, we understand that the proper handling and protection of personal information and specific personal information (hereinafter collectively referred to as “private information”) is one of our social responsibilities. Accordingly, we have established the following Privacy Policy, and we have communicated this policy to our directors and contractors. Our compliance with this policy is one way that we will ensure the protection of private information.

1. Management Structure for Protecting Private Information

The REIT complies with all laws and other standards related to the handling of private information, engaging in the appropriate management of such.
We periodically review our management system for protecting private information, making improvements when and where necessary.

2. Appropriate Collection of Private Information

The REIT collects private information through appropriate methods as required within the scope of providing services. When collecting private information directly from individuals, we clearly state the purpose for which the information will be used, as well as where the individual can direct questions. We only collect information with the agreement of the individual, and such information is only used within the scope agreed to by said individual. However, we may not clarify the purpose of use when such purpose is obvious from the circumstances in which information is collected.
The REIT may request submission of an individual number from the person or any other person in charge of a process using an individual number solely in the event where it is necessary to handle the processes related to individual numbers specified in Paragraph 4 below. The request for submission of an individual number is made at the time when it becomes necessary to handle the processes in question or when handing of the processes becomes likely.
At the time of receiving an individual number submitted, the REIT performs identity verification by taking measures stipulated in Article 16 of the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of 2013, including amendments thereafter; hereinafter referred to as "the Numbers Act"). As regards the agent, the REIT performs verification of its identity, its agency rights and the individual number of the person for whom it acts as agent by taking measures stipulated in the said article.

3. Use of Private Information

The REIT uses private information in the course of purchasing, managing, and disposing of assets as an investment corporation, as well as performing other services incidental thereto, and handles such information to the extent necessary to accomplish the following use purposes. Further, it does not use such information in ways that may facilitate or induce illegal and/or improper acts. We deal with private information to the extent necessary to accomplish the purposes detailed below.
If, after collecting private information, the REIT must use such information for other than purposes identified below, we will promptly notify the individuals affected and/or issue a public announcement.
In such cases, we will generally send written notifications. Public announcements will take the form of written notice/note to the REIT inquiry desk, publication on the REIT website, and/or other methods deemed appropriate. 
The REIT will use private information collected for the following purposes, and otherwise as required by law:

1. Information management (including the creation of Investor Register) related to REIT investors ("Investor"), analysis of Investor attributes, and data disclosure (information that identifies individuals will not be disclosed, with the exception of the disclosure of major Investors (top 10) on the REIT website).
2. Exercise of Investor rights related to the REIT; performance of duties related to REIT Investors.
3. Necessary due diligence (including, but not limited to, identification of an individual, credit checks, and inquiries related to rights) when the REIT considers the purchase/sale of real estate, trust beneficiary rights utilizing real estate as trust assets ("Real Estate Trust Beneficiary Rights;" "Trust Real Estate" when referencing real estate as a trust asset) or other assets; necessary due diligence when executing tasks (communications, inquiries, registrations, etc.) required by agreements related to said purchase/ sale.
4. Necessary due diligence (including, but not limited to, identification of an individual and credit checks) when considering the leasing of real estate related to real estate, Trust Real Estate or other assets owned by the REIT; necessary due diligence when executing tasks (communications, inquiries, registrations, etc.) required by agreements related to said leases.
5. Analysis of management and/or lease conditions related to real estate, Trust Real Estate, or other assets owned by the REIT.
6. Implementation of measures (communications, etc.) to ensure smooth relationships with REIT Investors or potential investors.
7. Confirmation of, response to, and creation of records related to referrals, visitors, individuals seeking documents to the REIT or the asset management company ("Asset Management Company") contracted by the REIT.
8. Implementation of processes related to personnel affairs for directors of the REIT
9. Provision/disclosure of private information to third parties as necessary within the scope of (1) to (8) above.
10. Other use as necessary to facilitate the appropriate and smooth performance of tasks related to the REIT by the Asset Management Company.

4. Use of Individual Numbers

Notwithstanding the provisions in the preceding paragraph, the REIT uses individual numbers for the purposes detailed below.

(1) Processes related to individual numbers concerned with directors or individuals other than directors

1. Preparation of payment records of remuneration, fees and others
2. Preparation of payment records of dividends, distribution of surplus and for interest on funds
3. Preparation of payment records of usage fees of real estate and others
4. Preparation of payment records of compensation for real estate and others
5. Notifications to administrative institutions incidental to the preceding items
6. Preparation of other payment records
7. Other processes related to 1) to 5) above and preparation of statutory records or others required by laws to include individual numbers

5. Third-Party Usage

Except where required by law or other statutes, the REIT will not disclose or provide private information to third parties without the consent of the individual. Except where authorized by the Numbers Act, the REIT will not provide private information to third parties.
When providing private information to third parties with the consent of the individual and within the scope necessary to accomplish the originally intended purpose, the REIT will exercise due caution in usage and storage to ensure that private information is not subject to leakage or disclosure to non-intended parties.

6. Secure Management of Private Information

All REIT directors understand the importance of protecting private information; the REIT has established necessary and appropriate measures for the secure management of private information to ensure such is not subject to unauthorized access, loss, alteration, or leakage. 

7. Supervision of Contractors

At times, the REIT may contract the handling of collected private information to other service providers when necessary to accomplish the intended purpose of use. When contracting the handling of private information, in whole or in part, to a third party, the REIT shall engage in the necessary and appropriate supervision of said third parties to encourage the secure management of such private information.

8. Disclosure Requests

Individuals may request the disclosure (notification of purpose, disclosure, corrections/additions/deletions, cessation of usage, deletion, cessation of use by third party) of their personal data by contacting the following service desk.
The service desk will instruct said individual as to the proper request procedures, and, after having confirmed the identity of the individual, provide an appropriate response.
This also applies to the disclosure of the record of provision to third parties in conjunction with the transfer of personal data.

9. Contact regarding Questions or Complaints related to Private Information

Individuals with questions or complaints related to the REIT's handling of private information may contact the following service desk:

Questions regarding Private Information

Please address questions related to the Investor Register to the following: