1. Basic Policy for Protection of Personal Information
Nippon Building Fund Management Ltd. (“NBFM”) will comply with the Act on Protection of Personal Information (the “Personal Information Protection Act”) as well as other related laws, regulations and guidelines issued by the relevant administrative agencies, etc. for the treatment of personal information and will endeavor to appropriately handle, manage and protect such information.
2. Acquisition of Personal Information
NBFM will acquire personal information through legal and fair means to the extent necessary to achieve the purposes of use defined in “3. Purpose of Use of Personal Information” below (the “Purpose of Use”).Moreover, sensitive information (those defined in guidelines for personal information protection in the financial field (the “Guidelines in Financial Field”) by the Financial Services Agency and policy on protection of personal information established by The Investment Trusts Association, Japan (the “Policy of the Investment Trusts Association”) will not be acquired or used except for cases stipulated in the Guidelines in Financial Field and the Policy of the Investment Trusts Association. When acquiring personal information, NBFM will disclose in advance the Purpose of Use on its website, etc. or notify or disclose the same promptly after acquisition to any individual whose personal information was so acquired. If personal information is acquired directly from an individual in written form, the Purpose of Use shall be expressly disclosed in advance; provided, however, that in the event that the Purpose of Use is considered to be obvious in light of the circumstances of such acquisition or as otherwise permitted by laws and regulations, such notification, disclosure or indication may be omitted.
Personal information acquired by NBFM includes, in addition to that of investors or prospective investors holding investment units of Nippon Building Fund Inc. (“NBF”), personal information of tenants of assets under management and other customers of NBF.
3. Purpose of Use of Personal Information
Acquired personal information will be used by NBFM in order to perform asset management services entrusted by NBF and other ancillary or related duties in accordance with the Financial Instruments and Exchange Act and the Act on Investment Trusts and Investment Corporations (the “Investment Trusts Act"). NBFM will not use personal information in ways that could encourage or induce an illegal or unjust act. Such purpose includes the following. NBFM will not, except for cases stipulated in laws and regulations, use any personal information for any purpose beyond the scope of the following Purpose of Use.
- to exercise rights of unitholders of NBF, for which NBFM is entrusted with the asset management (acquisition, management or disposition of assets, fund procurement, etc.) based on the Investment Trusts Act, etc. and other laws and regulations, based on the Investment Trusts Act, etc. and other laws and regulations, and to fulfill obligations of NBF;
- for NBFM to manage assets as entrusted by NBF and to research and review, etc. for the asset management;
- to confirm of and respond to inquiries, etc.;
- for NBFM to properly and smoothly implement general administrative affairs and other ancillary or related services; and
- to disclose and provide personal information to any third party to the extent necessary to achieve the abovementioned Purpose of Use.
4. Disclosure or Provision of Personal Data including Personal Information to Third Parties
NBFM will not disclose or provide any acquired personal data including personal information to any third party except for the following cases: Moreover, sensitive information will not be provided to any third party except for cases stipulated in the Guidelines in Financial Field and the Policy of the Investment Trusts Association.
- where an individual has consented to such disclosure or provision;
- where such disclosure or provision is required by laws and regulations;
- where such disclosure or provision is required to prevent death or injury to persons or damage to property and obtaining consent from the individual is difficult thereto;
- where such disclosure or provision is required to improve public health or promote healthy child-rearing and obtaining consent from the individual is difficult thereto;
- where cooperation with national agencies or local public authorities or with any of their representatives in performing administrative affairs stipulated by laws and regulations is required and obtaining consent from such individual thereto could hinder the implementation of such affairs;
- where NBFM entrusts in whole or in part the handling of personal information to contractors who are under NBFM’s necessary and proper control and supervision to the extent necessary for achievement of the Purpose of Use; or
- where such disclosure or provision is permitted by the Personal Information Protection Act or other laws and regulations.
5. Management of Personal Data
NBFM will endeavor to keep personal data both accurate and updated and delete such data without delay when its use is no longer necessary. NBFM will also implement necessary and adequate security control measures to prevent any leakage, loss, or damage of personal data and safely manage such data. NBFM sets rules on protection of personal information, and takes institutional security control measures, human security control measures, technological security control measures and physical security control measures as security control measures in accordance with those rules in order to prevent any leakage, loss or damage of personal data or otherwise safely manage personal data. In addition, NBFM will make its contractors to which personal data is to be disclosed or provided obligated to take security measures to ensure safe management of personal data, and will supervise the implementation of such security measures.
In the event of any leakage, loss, damage or other incident concerning the security of personal data of which are prescribed by rules of the Personal Information Protection Commission as having a large possibility of harming an individual’s rights and interests, NBFM will inform the individual that such incident has occurred pursuant to rules of the Personal Information Protection Commission; provided, however, that this does not apply when informing the individual would be difficult and in which case alternative measure is taken which is necessary to protect the individual’s rights and interests.
6. Inquiries concerning Personal Information, etc.
Any questions or complaints concerning personal information, or requests for information on any third party in a foreign country to which personal information is provided if there is any such third party, details of the measures taken in the handling of personal information by such third party, or notification of the Purpose of Use, disclosure, correction, addition, deletion, discontinuance of use, erasing, discontinuance of provision to any third party, etc. of retained personal data should be directed to the following contact. Information regarding required procedures, etc. will be provided, and action taken in response appropriately in accordance with the Personal Information Protection Act. Consultations or complaints, etc. concerning NBFM’s handling of personal information, including security control measures, may also be directed to the following contact.
|Name||Nippon Building Fund Management Ltd.
President and CEO: Eiichiro Onozawa
Risk Management & Compliance Department,
Corporate Operation Group
|Address||3-1, Nihonbashi Muromachi 2-chome, Chuo-ku, Tokyo|
|Business Hours||9 a.m. to 5 p.m. (excluding Saturdays, Sundays, national holidays and Company holidays)|
Furthermore, NBFM is a member of The Investment Trusts Association, Japan, an authorized organization for protection of personal information which accepts consultations or complaints, etc. concerning handling of personal information by its member companies.
|Name||The Investment Trusts Association, Japan Investors Consultation Office|
|Business Hours||9 a.m. to 11:30 a.m. and 12:30 p.m. to 5 p.m. (excluding Saturdays, Sundays, national holidays and Association holidays)|
For corrections, additions, deletions, etc. of matters set forth in the Register of Unitholders of NBF, please contact the following Manager of NBF’s Register of Unitholders.
|Name||Sumitomo Mitsui Trust Bank Ltd.
Stock Transfer Agency Business Planning Dept.
|Address||8-4, Izumi 2-chome, Suginami-ku, Tokyo|
|Telephone||0120-782-031 (toll-free in Japan)|
|Business Hours||9 a.m. to 5 p.m. (excluding Saturdays, Sundays, national holidays and Bank holidays)|
Established on February 29, 2008
Amended on June 12, 2009
Amended on April 1, 2012
Amended on January 4, 2013
Amended on May 30, 2017
Amended on April 1, 2022