Privacy Policy
Mitsui Fudosan Accommodations Fund Management Co., Ltd.
Mitsui Fudosan Accommodations Fund Management Co., Ltd. (the "Company") recognizes the importance of protecting personal information and specific personal information, etc. (where "specific personal information, etc." as used herein shall refer collectively to Individual Numbers and specific personal information), and has established and implements the following privacy policy with respect to the handling of personal information and specific personal information, etc. that the Company collects, retains and manages in exercising its asset management duties on behalf of Nippon Accommodations Fund Inc. ("NAF"). The Company has also established and implements rules on how the protection of personal information and specific personal information, etc. is handled. The Company periodically revises the content of the privacy policy and the rules noted above whenever necessary.
1．Compliance with Relevant Laws and Ordinances
The Company strives to protect personal information and specific personal information, etc. by abiding by the "Act on the Protection of Personal Information" (the "Personal Information Protection Act"), the "Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure" (the "My Number Act") and other relevant laws and ordinances, as well as the "Guidelines for Personal Information Protection in the Financial Field" (the "Guidelines in Financial Field") and "Guidelines for proper handling of Specific Personal Information (for private entities)," etc., (referred collectively as "Laws and Ordinances, etc.") in the handling of personal information and specific personal information, etc.
2．Collection of Personal Information and Specific Personal Information, etc.
The Company collects personal information and specific personal information, etc. through legal and appropriate means to the extent necessary to perform its services. Moreover, the Company shall not collect special care-required personal information without consent from the individual except in cases required by laws and ordinances, nor shall the Company collect sensitive information (as defined in the Guidelines in Financial Field) except in cases stipulated in the Guidelines in Financial Field.
3．Purpose of Use of Personal Information and Specific Personal Information, etc.
The Company uses specific personal information, etc., only to the extent provided by laws and ordinances. In addition, other than these, any personal information collected by the Company are used, only for the following purposes. As for sensitive information, it shall not be used except in cases stipulated in the Guidelines in Financial Field.
- To enforce the rights of those who own securities issued by NAF, to fulfill the obligations of NAF and to carry out measures to ensure a smooth relationship among NAF and its investors;
- To prepare and file various reports and documents of NAF in accordance with the Investment Trust and Investment Corporation Act, the Companies Act and other relevant laws and, to manage the information of NAF's investors;
- To respond to inquiries concerning the bonds, additional investment units and securities issued by NAF;
- To carry out operations related to the acquisition, transfer and leasing of assets by NAF and the management of real estate;
- To carry out general affairs the Company is responsible for or to carry out operations incidental or related to (1) through (4) above; and
- To provide personal information to a third party within the scope necessary to fulfill the purpose of use indicated in (1) through (5) above.
4．Provision of Personal Data and Specific Personal Information to Third Parties
Unless otherwise provided by the My Number Act, etc., the Company will not provide specific personal information to a third party, regardless of whether or not the consent of the individual has been obtained. In addition, other than these, the Company may provide personal information to a third party, only in the following cases. As for sensitive information, it shall not be provided to third parties except in cases stipulated in the Guidelines in Financial Field.
- In cases of the provision to a third party within the scope of the purpose of use as set forth in the preceding paragraph "3. Purpose of Use of Personal Information and Specific Personal Information, etc."; and
- Other cases where the provision is permitted under the Act on the Protection of Personal Information.
5．Disclosure Requests, etc.
The Company strives to respond swiftly and appropriately when a request for notification of purpose of use is made or when asked to disclose, modify, add, delete, suspend using, erase, or discontinue the provision to third parties the retained personal data (including retained personal data pertaining to specific personal information) of an individual after verifying that the request is from the individual himself/herself.
6．Security Measures
The Company has implemented the following measures in accordance with the relevant Laws and Ordinances, etc., to ensure the security of personal data and specific personal information, etc., such as prevention of leakage, loss or damage.
- Establishment of rules for the handling of personal information
The Company has established internal rules that specify the methods of handling personal information, responsible persons/persons in charge, their duties, etc. - Organizational security measures
The Company has appointed a Chief Information Officer to be responsible for the handling of personal information, and formulates a personal information protection plan each fiscal year to implement, evaluate and improve security measures.
In addition, it ensures that its employees (including contract employees and temporary employees) comply with its internal rules regarding security measures, and has established a system for reporting to and informing the responsible person if they become aware of any facts or signs of violations of laws or internal rules. - Personnel security measures
The Company provides its employees with education and training on the proper handling of personal information. - Physical and technical security measures
In the areas where personal information is handled, the Company controls employee access and locks all devices containing personal information.
In addition, it has implemented access control measures for personal information and the information systems that handle personal information as well as measures against unauthorized software, monitoring of information systems, etc. (e.g., restricting access to file servers, etc., implementing firewalls in the Internet connection environment and obtaining and analyzing operation history).
- Understanding of the external environment
The Company stores the customers’ personal information in its possession in Japan.
7．Inquiries Regarding Personal Information and Specific Personal Information, etc.
The contact information for inquiries related to the Company's handling of personal information and specific personal information, etc., requests for notification of purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, or discontinuation of the provision to third parties concerning the retained personal data (including retained personal data pertaining to specific personal information) and complaints, etc., is provided below. The Company will respond as quickly as possible and in good faith to complaints and consultations regarding personal information and specific personal information, etc.
Mitsui Fudosan Accommodations Fund Management Co., Ltd.
1-4-1, Nihonbashi, Chuo-ku, Tokyo 103-0027
Tel : 03-3246-3677
(9 a.m. - 5 p.m. (excluding weekends, holidays and scheduled non-working days))
The Company is also a member of the Investment Trusts Association, Japan (JITA), which is a personal information protection organization authorized under the Act on the Protection of Personal Information. JITA accepts complaints and provides consultation concerning its members' handling of personal information.
JITA Investor Advisory Office
Tel : 03-5614-8440
8．Revisions
The Company may revise this privacy policy from time to time in order to ensure the protection of personal information and specific personal information, etc., and to conform to changes in laws and ordinances. Please confirm the date of the last revision provided below.
Enacted ： July 31, 2006
Latest revision ： March 31, 2022