Kenedix, Inc. and the companies belonging to its corporate group (collectively, the “Group”) recognize that the protection and proper management of personal information constitute a social responsibility. Accordingly, the Group has established the following Privacy Policy (the “Policy”), and will implement, maintain, and endeavor to continuously improve it.

However, where any Group company has separately established its own privacy policy, such company shall comply with and implement its own policy.

1. Basic Policy

The Group recognizes the importance of personal information and respects and complies with the Act on the Protection of Personal Information, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (the “My Number Act”), related laws and regulations, relevant guidelines including the guidelines concerning the Act on the Protection of Personal Information, and social order. The Group endeavors to properly handle and protect personal information. The Group will also endeavor to continuously improve its personal information protection management framework by reviewing it from time to time.

2. Acquisition and Use of Personal Information

The Group acquires personal information by appropriate means and publicly announces or notifies the purposes of use thereof (including public announcement by means of this Policy). Except as otherwise provided by law, the Group will not acquire or use personal information beyond the scope of the purposes of use without the consent of the individual concerned.

3. Purposes of Use of Personal Information

The Group uses acquired personal information (excluding individual numbers and personal information containing individual numbers (collectively, “Specific Personal Information”); the same shall apply in this Article) for the following purposes.

3-1. Personal information concerning customers and others (in the case of corporations, their officers and employees)

1. Provision of guidance, proposals, performance of contracts, marketing activities (including requests to participate in questionnaires), and provision of various information and services in relation to the following businesses conducted by the Group;
   1. Businesses related to transactions involving the sale and purchase, management, brokerage, leasing, administration, operation, planning, development, and other activities concerning real estate and similar assets (including trust beneficiary interests; the same shall apply hereinafter);
   2. Businesses related to transactions involving investments, loans, and similar activities in private funds and other vehicles backed by real estate and similar assets as underlying assets;
   3. Businesses related to transactions involving the sale and purchase, brokerage, management, and other activities concerning claims and similar assets;
   4. Businesses related to advisory and similar services concerning real estate and similar assets, claims and similar assets, and other matters;
2. Performance of contracts and provision of information and services in relation to due diligence services conducted by the Group (valuation services for real estate and similar assets, claims and similar assets, and other assets);
3. Guidance, operation and management, sending of materials, response to inquiries, improvement of content, and other activities in relation to events, seminars, and similar activities held by the Group;
4. Management of business partners of the Group;
5. In addition to the foregoing, use in connection with the performance of business related or incidental to the businesses conducted by the Group.

3-2 Personal information concerning shareholders (in the case of corporations, their officers and employees)

1. Shareholder administration of the Group, including preparation of records based on various laws and regulations;
2. Exercise of rights and performance of obligations under the Companies Act.

3-3 Personal information concerning applicants for recruitment and hiring activities

1. Recruitment and selection of officers, employees, contract employees, and others of the Group (collectively, “Officers and Employees, etc.”);
2. Communications and provision of information for the achievement of the above purpose, and other use necessary for recruitment and hiring activities.

3-4 Personal information concerning officers and employees, etc.

1. Management of Officers and Employees, etc. of the Group;
2. Business communications to Officers and Employees, etc.;
3. Payment of remuneration (including wages, bonuses, and various allowances) to Officers and Employees, etc., performance of personnel and labor management, and provision of welfare benefits;
4. Health management of Officers and Employees, etc.;
5. Other use necessary for employment management or corporate operations.

3-5 Other

Provision of personal information to third parties to the extent necessary to achieve the purposes of use set forth in 3-1 through 3-4 above.

4. Purposes of Use of Specific Personal Information

When acquiring Specific Personal Information, the Group publicly announces or notifies the purposes of use thereof (including public announcement by means of this Policy), and will not use Specific Personal Information other than for uses permitted under the My Number Act. The purposes of use of Specific Personal Information by the Group are as follows.

4-1 Administrative affairs related to individual numbers concerning officers and employees, etc. (including dependent family members) (including administrative affairs related to the following)

1. Administrative affairs related to withholding tax, preparation of payroll payment reports, and preparation of notifications of changes in employment status of salary income earners in relation to special collection of inhabitant tax from payroll payments;
2. Administrative affairs related to preparation of declarations for exemptions for dependents, etc. (including changes), declarations for insurance premium deductions and special deductions for spouses of salary income earners, and applications for switching to special collection;
3. Administrative affairs related to preparation of payment records by recipient for retirement allowances, etc., and preparation of declarations concerning retirement income;
4. Administrative affairs related to health insurance, employees’ pension insurance, and corporate pension notifications; applications and claims for health insurance, employees’ pension insurance, and corporate pensions; and notifications for Category III insured persons under the National Pension system;
5. Administrative affairs related to employment insurance notifications, and employment insurance applications and claims;
6. Administrative affairs related to the preparation and provision of statutory documents concerning financial instruments transactions under stock option plans.

4-2 Administrative affairs related to individual numbers concerning individuals other than officers and employees, etc. (including administrative affairs related to the following)

1. Administrative affairs related to preparation of payment records for remuneration, fees, and similar payments;
2. Administrative affairs related to preparation of payment records for dividends, distributions of surplus, and interest on funds;
3. Administrative affairs related to preparation of payment records for real estate rent and similar payments;
4. Administrative affairs related to preparation of payment records for consideration paid for the acquisition of real estate and similar assets.

5. Provision of Personal Data to Third Parties

The Group will not provide personal data acquired by the Group (excluding Specific Personal Information) to third parties without obtaining the prior consent of the individual concerned, except as permitted under this Policy and laws and regulations. The Group will not provide Specific Personal Information except as permitted by laws and regulations.

6. Joint Use of Personal Data

For the purpose of providing various information and services through strengthened cooperation among Group companies, and implementing and strengthening management across the Group as a whole, the Group jointly uses personal data (excluding Specific Personal Information; the same shall apply in this Article) as described below.

1. Items of personal data to be jointly used
   • Items of personal information concerning the individual and the individual’s family members, such as name and address, acquired in connection with the recruitment and similar activities for Officers and Employees, etc. of the Group;
   • Names, contact information, affiliations, and positions of customers and others (in the case of corporations, their officers and employees);
2. Scope of parties jointly using the personal data
   • Each company of the Group;
3. Purposes of use by parties jointly using the personal data
   • The purposes of use set forth in 3-3 “Personal Information Concerning Applicants for Recruitment and Hiring Activities” and 3-4 “Personal Information Concerning Officers and Employees, etc.” above;
   • Performance of contracts and provision of information and services in relation to the sale and purchase, management, brokerage, leasing, administration, operation, planning, development, and other activities concerning real estate and similar assets;
   • Performance of contracts and provision of information and services in relation to investments and loans concerning real estate and similar assets;
   • Guidance, operation and management, sending of materials, response to inquiries, improvement of content, and other activities in relation to events, seminars, and similar activities held by the Group;
   • Management of business partners of the Group;
   • In addition to the foregoing, use in connection with the performance of business related or incidental to the businesses conducted by the Group;
4. Person responsible for management.
   The Company shall be responsible for the personal data jointly used.

   【Person Responsible for Management】 Kenedix, Inc.

   2-1-6 Uchisaiwaicho, Chiyoda-ku, Tokyo
   For the name of the Representative Director and President, please refer to the Company Profile.

7. Security Control Measures for Personal Data

Personal data held by the Group is properly and carefully managed in accordance with the Company’s regulations, and the Group implements necessary and appropriate security control measures to prevent unauthorized access to, loss, falsification, leakage, and other incidents involving personal data.

8. Entrustment of Handling of Personal Data

The Group may entrust the handling of personal data concerning personal information held by the Group to external parties. In such cases, the Group selects parties that have taken sufficient measures for the protection of personal information and exercises necessary and appropriate supervision over such entrusted parties.

9. Procedures for Disclosure, Correction, etc. of Retained Personal Data

Requests from individuals for disclosure, correction, suspension of use, and similar actions concerning retained personal data and other data held by the Group will be handled without delay in accordance with procedures separately established by the Company.

10. Contact for Inquiries Regarding Personal Information

For requests regarding disclosure, correction, suspension of use, and similar actions concerning retained personal data and other data, as well as opinions and questions concerning this Policy and the Company’s handling of personal information, including security control measures for personal data, please contact the following.

In addition, Kenedix, Inc. is a covered business operator of Investment Management Association of Japan(“IMAJ”), an accredited personal information protection organization. IMAJ accepts complaints and consultations concerning the handling of personal information by covered business operators.

11. Revision of this Policy

This Policy will be reviewed from time to time and revised as necessary in response to requirements under laws and regulations and for further improvement of personal information protection.