PRIVACY POLICY
Kasumigaseki REIT Advisors Co., Ltd (hereinafter referred to as "the Company") recognizes the social responsibility it has in handling customers' personal information appropriately in compliance with the Act on the Protection of Personal Information and any other related laws and regulations. As such, the Company has established the following basic policy regarding the handling of personal information and will make every effort to protect personal information.
1. Basic Policy
- (1)The Company will comply with all laws and regulations regarding the proper handling of personal information.
- (2)The Company will specify the purpose for using personal information and will not use such personal information beyond the extent necessary, except when prior consent has been given by the customer, or when permitted by laws or regulations.
- (3)The Company will acquire personal information by lawful means to the extent necessary to achieve the purpose of use.
- (4)The Company will take all necessary measures to ensure that personal information is managed appropriately and not leaked or lost. The Company will also train and supervise employees in the handling of personal information.
- (5)When the handling of personal information is outsourced, the Company will supervise the contractor as necessary.
- (6)The Company will review and improve its Privacy Policy as required in conjunction with changes to laws and regulations.
- (7)The Company will make every effort to respond appropriately and promptly to requests to disclose, amend, delete, or suspend use of any personal information it possesses.
- (8)The Company will make every effort to respond promptly and in good faith to any questions, opinions, or complaints users have regarding the handling of their personal information.
2. Proper Acquisition of Personal Information
The Company will acquire personal information only to the extent that it is necessary for business use in order to achieve the intended purpose of use. Moreover, the Company will not acquire or use sensitive information, nor will it provide sensitive information to a third party, except when permitted by laws or regulations.
3. Purpose of Use of Personal Information
The Company shall use personal information for the purpose of conducting the asset management business of the investment corporation for which the Company has been entrusted with asset management (hereinafter, "Kasumigaseki Hotel REIT") and related operations, and within the scope necessary to achieve the following purposes:
- For the exercise of rights by unitholders pertaining to Kasumigaseki Hotel REIT (hereinafter referred to as the "Unitholders"), and/or for the fulfillment of obligations of Kasumigaseki Hotel REIT to the Unitholders
- For the analysis of Unitholder attributes, preparation of various statistical data, and other purposes related to information management
- For the execution of operations related to asset management conducted by Kasumigaseki Hotel REIT in accordance with applicable laws and regulations, including the acquisition, disposition, leasing, and management of real estate and other assets
- For the execution of the Company's operations related to investor relations (IR) activities and general administrative affairs
- For the Company Group's personnel and labor management, recruitment and selection, and other administrative procedures concerning officers, employees, temporary staff, and others (including prospective employees and retirees)
- For the proper and smooth execution of other operations incidental or related to the above purposes
4. Proper Management of Personal Information
The Company has appropriate safeguards in place to ensure that personal information is not leaked, lost, or tampered with, and that there is no unauthorized access of users' personal data.
5. Providing Personal Data to Third Parties
In accordance with laws and regulations, the Company will not disclose or provide personal data to third parties without obtaining prior consent from the owner of the personal data, except when permitted by laws and regulations, such as when outsourcing the handling of personal data to the extent necessary to achieve the purpose of use.
6. Outsourcing the Handling of Personal Data
In order to smoothly carry out the operations necessary for the purpose of use, the Company may outsource all or part of the operations and provide the contractor with the personal data necessary to carry out the outsourced operations. In such cases, the Company will conduct necessary and appropriate supervision of the contractor, including the supervision of any subcontractors.
7. Sharing Personal Data
The Company may share customer personal data as follows:
- (1)Personal data that can be shared includes customer names, addresses, dates of birth, telephone numbers, e-mail addresses, family information, information about customers' workplaces, information about customers' transactions, information on customers' business cards or in e-mail signatures, etc.
- (2)Customer personal information may be shared and used within the Company and its parent company
- (3)Customer personal information may be shared and used in the provision of services, client management, and business management by Group companies and to consider new services, new products, and new businesses
- (4)Kasumigaseki Capital and the Company are responsible for the management of customers' personal data.
8. Publicly Disclosed Information Regarding Personal Data
(1) The name, address and representative of the business handling customers' personal data is as follows:
Masaya Sato, President and CEO
Kasumigaseki REIT Advisors Co., Ltd.
36th Floor Kasumigaseki Building, 3-2-5 Kasumigaseki, Chiyoda-ku, Tokyo 100-6003
(2) For the purpose of the use of personal information, please refer to "3.Purpose of Use of Personal Information" above.
(3) Customers have the right to request notification of the purpose of use of the personal data the Company possesses regarding them.
They also have the right to request a copy of their personal data, or request that their personal data be amended, added to, deleted, or its use is suspended. When the Company has been instructed by a customer or their representative to provide the said notification of the purpose of use or to provide a copy, amend, add, delete, or suspend the use, etc., of their retained personal data, the Company will confirm all necessary matters and respond in writing within a reasonable period of time. Customers or their representatives may however be asked to pay a fee for any disclosure requests, etc., pertaining to personal information. For contact details, please refer to section (5) below.
(4) Measures to safeguard the personal data the Company holds about customers are as follows:
Basic policy
In order to ensure the proper handling of personal data, the Company has formulated a basic policy on compliance with laws and regulations and the handling of questions and complaints.
Rules regarding the handling of personal data
The Company has established rules on the acquisition, use, retention, provision, deletion, and disposal of personal data, and the parties responsible for these actions.
Organizational safety management measures
The Company regularly carries out self-inspections and internal audits regarding the handling of personal data.
Personnel safety management measures
Employees submit a pledge to the Company regarding the confidentiality of personal data.
Physical safety management measures
In areas where personal data is handled, the Company controls employees' room access, restricts the equipment that is used, and takes measures to prevent unauthorized persons from viewing personal data.
Technical safety management measures
The Company has introduced mechanisms for protecting information systems that handle personal data from any external unauthorized access or unauthorized software.
(5) For any questions, opinions, or complaints regarding the handling of personal data the Company holds about you, customers are requested to use the Contact form on this website.
9. Authorized Personal Information Protection Organization
The Company is a member of the Investment Trusts Association, Japan a personal information protection organization certified by the Personal Information Protection Commission.
The Japan Investment Trusts Association's personal information help desk accepts complaints and consultations regarding association members' handling of personal information.
| Contact | Japan Investment Trusts Association help desk |
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| Tel. | 03-5614-8440 |
| Hours of operation | 9:00 a.m. – 11:30 a.m. and 12:30 p.m. – 5:00 p.m. (excluding Saturdays, Sundays, and national holidays) |
10. Use of Cookies
The Company's website (hereinafter "the Website") places cookies* on users' computers for the purposes of improving user convenience and tracking website usage. If a customer's browser settings allow the use of cookies, a cookie will be created by their browser and automatically sent to our server when they access the Website again. Usage data is only used for statistical purposes. Cookies do not contain any personally identifiable information.
Customers who do not wish to allow cookies can disable the storage of cookies on their computer through their browser settings.
- *Cookies are data sent to the customer's browser from our server and stored in the customer's computer's storage and/or RAM.
11. Acquisition of Information from Google Analytics
The Website uses Google Analytics, a service provided by Google, to track and analyze website usage. User information collected, recorded, and analyzed by Google Analytics does not contain any personally identifiable information.
Data obtained from Google Analytics cookies is managed by Google in accordance with its privacy policy.
Please refer to the Google Analytics website for the Google Analytics Terms of Service and the Google website for the Google Privacy Policy.
| Google Analytics Terms of Service | https://marketingplatform.google.com/about/analytics/terms/us/ |
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| Google Privacy Policy | https://policies.google.com/privacy?hl=en-US |
Customers wishing to disable the collection of information by Google should use the Google Analytics Opt-out Browser Add-on provided by Google to opt out. Note that disabling Google Analytics will cause it to be disabled for every website the customer visits. However, Google Analytics can be re-enabled by changing the browser's add-on settings.
| Google Analytics Opt-out Browser Add-on | https://tools.google.com/dlpage/gaoptout?hl=en |
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