Star Asia Investment Corporation

Privacy Policy

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Star Asia Investment Corporation (SAR) shall comply with the Act on the Protection of Personal Information, the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the “Number Act”) and other relevant laws and regulations and such, and endeavor to protect personal information based on the following policies.

Policy

Recognizing the extreme importance of honoring individual privacy, SAR shall strive to properly handle and safely and reliably manage/use personal information in addition to ensuring using such for only predetermined purposes and appropriately handling complaints, etc. of such, by adhering to the Act on the Protection of Personal Information, the “Number Act” and other related laws and regulations as well as norms (including guidelines concerning the protection of personal information and other guidelines in the financial sector) and internal rules among others.

Collection of Personal Information

SAR shall collect personal information within the scope necessary for the achievement of the purposes of use described below, through legitimate and proper means.

Purposes of Use of Personal Information

Purposes of use of personal information collected by SAR are as follows.

(1) To execute the rights and fulfill obligations, pursuant to the Act on Investment Trusts and Investment Corporations (the “Investment Trusts Act”) and other laws and regulations applicable to SAR.
(2) To conduct tasks necessary for the unitholders of SAR as defined under the laws and regulations (the “Unitholders”) to exercise their rights; and to provide information and other services to the Unitholders.
(3) To prepare various reports pursuant to the Investment Trusts Act and other applicable laws and regulations and data concerning the Unitholders; and to manage the Unitholders using the data.
(4) To respond to inquiries, etc. from those considering the purchase of securities issued by SAR.
(5) To issue/offer investment corporation bonds/investment units by SAR; and to borrow funds
(6) To acquire, transfer and lease investment assets
(7) To implement various tasks in line with survey/research, collection/analyses of information and provision/notification of information that are necessary for the management of assets
(8) To properly and smoothly implement other operations of SAR in addition to (1) through (7) above.
(9) To disclose/provide personal information to third parties to the extent necessary to achieve the purposes of use set forth in (1) through (8) above.

However when upon provision of personal information a purpose of use other than the above is notified or clearly specified to the information provider (the individual), the purpose of use shall prevail over the above purposes of use. As for specific personal information (as defined in the Number Act; the same shall apply hereinafter) collected, used, stored pursuant to the Number Act, purposes of use for affairs related to the individual number (as defined in the Number Act) or other purposes of use permitted under laws and regulations shall prevail over the above purposes of use.

Disclosure/Provision to Third Parties

Required items of personal information collected by SAR, such as address, name, real estate information or contents of correspondence, may be provided to a third party through direct delivery, mail, phone, internet, e-mail, advertising medium, etc. in the following cases. Disclosure/provision will be halted if such request is made by the information provider (the individual). However, there may be requests that cannot be complied with

(1) When consent has been obtained from the relevant individuals
(2) When disclosure or provision is based on laws and regulations
(3) When it is necessary to do so for protecting people's lives, bodies or estates, in cases when it is difficult to obtain consent from the relevant individuals for disclosure/provision of the personal information.
(4) When it is necessary to do so particularly for improvement in public health or sound development of children, in cases when it is difficult to obtain consent from the relevant individuals
(5) When it is necessary to cooperate with national administrative agencies, local governments or parties entrusted by such entities in conducting administrative operations designated by laws and regulations, in cases when obtaining consent from relevant individuals for disclosure/provision of the personal information may cause problems in conducting such operations.
(6) When the information is disclosed/provided to a third party to the extent rationally necessary to achieve the purposes of use.
(7) When the information is disclosed/provided in non-personally identifiable form such as statistical data.
(8) In addition to (1) through (7) above, when disclosure/provision is approved by laws and regulations.

Examples of third parties to which personal information may be disclosed/provided

Star Asia Investment Management Co., Ltd. (Asset Manager), an asset management company of SAR
Counterparties and potential counterparties of contracts regarding real estate transactions
Financial institutions and non-insurance companies (including insurance agents) involved in tasks contingent to transactions of real estate, etc.
Building lots and buildings business operators
Attorneys at law, judicial scriveners and real estate appraisers
General administrative agent and transfer agent

However, specific personal information collected, used and stored pursuant to the Number Act shall not be provided to third parties regardless of consent from the information provider (the individual), except when such provision is pursuant to laws and regulations.

Supervision of Consigned Parties

When personal information is disclosed/provided to parties to which SAR consigns operations, SAR shall conduct necessary and appropriate supervision of the consigned parties, such as requiring strict safety management measures, in order to prevent loss, misuse, alternation, etc. of personal information.

Inquiries Relating to Personal Information

Questions concerning the general handling of personal information or personal information individuals have provided; inquiries on disclosure, corrections, suspension of use, etc.; or complaints on handling of personal information by SAR are accepted at the Financial Management Department of the Asset Manager (phone: +81-3-5425-1340). Inquiries on information included in unitholders' register and handling of such is accepted at Stock Transfer Agency Business Planning Department of Sumitomo Mitsui Trust Bank, Limited (phone: 0120-782-031 (main number; toll-free within Japan). However, there may be requests that cannot be complied with.

Established on April 19, 2016

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