PRIVACY POLICY

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PRIVACY POLICIES

PRIVACY POLICY

PRINCIPLE 1 : BASIC POLICY
Takara Asset Management Co., Ltd. (hereinafter referred to as “the Company”) complies with the Personal Information Protection Law, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter referred to as the “Number Act”), other relevant laws and regulations, guidelines (hereinafter referred to as “laws and regulations”), and internal rules. The Company strives to handle personal information appropriately, not to use it for purposes other than its intended use, and to handle complaints and other issues adequately. Furthermore, the Company endeavors to ensure proper and secure management and operation. The definitions of terms used in this Privacy Policy are based on the Personal Information Protection Law and the Number Act.
PRINCIPLE 2 : PURPOSE OF USE

1. Purpose of Use of Personal Information
The personal information obtained by the Company mainly consists of information about the holders of securities issued by Takara Leben Infrastructure Investment Corporation (hereinafter referred to as “the Investment Corporation”), as well as information about tenants of the Investment Corporation’s managed assets and other business partners. The purposes of use of personal information by the Company are as follows:
(1) To exercise the rights of the investment corporation’s shareholders (hereinafter referred to as “shareholders”) and fulfill the obligations of the investment corporation, and to respond to shareholders and other related matters.
(2) To provide information on business operations to shareholders.
(3) To prepare and submit various reports, including the investment corporation’s various filings and reports, based on the Investment Trust and Investment Corporation Act, the Financial Instruments and Exchange Act, and other related laws and regulations.
(4) To create shareholder registers and manage shareholder information.
(5) To provide guidance, notifications, and marketing regarding the securities issued by the investment corporation (investment units, investment corporation bonds, and new investment unit reservation rights).
(6) To handle the issuance of publicly offered investment units, publicly offered investment corporation bonds, and new investment unit reservation rights, as well as other fundraising activities and IR activities of the investment corporation.
(7) To implement rental and management of the investment corporation’s managed assets and other related business operations, grasp the rental status of managed assets, and accumulate, analyze, and statistically process data related to this.
(8) To carry out business related to the acquisition of assets by the investment corporation, including pre-acquisition investigations.
(9) To carry out business related to the sale of assets by the investment corporation, including solicitation of buyers.
(10) To perform tasks or administrative work necessary or related to the purposes of use listed in (1) to (9) above, and to execute transactions strictly after conducting a thorough examination of the appropriateness of the consideration and other contract conditions.
(11) To provide personal information to third parties within a reasonable and necessary scope to achieve the purposes of use listed in (1) to (10) above.

2. Purpose of Use of Individual Numbers
Regardless of the above, the purposes of use of individual numbers by the Company are as follows:
(1) For creating withholding tax certificates for salary income and retirement income.
(2) For reporting employment insurance.
(3) For reporting health insurance and employees’ pension insurance.
(4) For reporting the insured status of the spouse of officers and employees for national pension.
(5) For creating payment statements, fee payment certificates, etc.
(6) For creating payment statements for dividends, surplus distribution, and fund interest.
(7) For creating payment statements for rent and other real estate usage fees.
(8) For creating payment statements for consideration of the transfer of real estate, etc.
(9) For creating payment statements for interest, etc.
(10) For administrative work related to the above (1) to (9) concerning the investment corporation.
(11) For creating other payment statements.
The Company uses personal information within the scope necessary to achieve the purposes of use stated above for the asset management operations of the investment corporation and does not use personal information for purposes other than those stated. Furthermore, the Company does not change the purpose of use of personal information beyond a reasonable range that is relevant to the previous purpose of use.

3. Notification or Publication of Purpose of Use of Personal Information
Except in cases where the purposes of use have already been publicly disclosed, the Company promptly notifies the individuals concerned of the purposes of use of the personal information by presenting or providing a written document at its office, publishing it on its website on the internet, or notifying by written document, postal mail, email, etc., depending on the circumstances of the acquisition of personal information.
In the event that the Company changes the purposes of use of personal information, it will notify the individuals concerned of the changed purposes or disclose them as stated above.

PRINCIPLE 3 : ACQUISITION

1. Acquisition of Personal Information
The acquisition of personal information is carried out through lawful and appropriate means within the necessary limits to achieve the purposes of use. The Company does not acquire personal information through deception or other fraudulent means, nor does it acquire personal information from third parties engaged in unauthorized acts of obtaining personal information or other illicit activities, knowing that such information has been leaked. When the Company directly receives personal information from individuals through documents, electronic methods, etc., it will clearly indicate the purpose of use of the personal information in advance. However, in cases where the purpose of use is obvious from the circumstances of the provision or where permitted by other laws and regulations, the notification of the purpose of use may be omitted. The Company also does not use personal information through methods that are likely to facilitate or induce illegal or unreasonable acts.

2. Acquisition of Individual Numbers
Regardless of the above, the Company may request the provision of individual numbers to the individuals themselves or to other persons engaged in individual number-related operations or use of individual numbers when it is necessary to process individual number-related operations or use for the purposes allowed by Article 2-2 of the Number Act.

3. Identity Verification
When receiving the provision of individual numbers, the Company verifies the identity of the individual by the methods specified in the relevant laws. Regarding agents, the Company confirms the identity of the agent, confirms the authority of the agent, and confirms the individual number of the principal, following the methods specified in the relevant laws.

PRINCIPLE 4 : PROVISION TO THIRD PARTIES

1.Provision of Personal Data to Third Parties
Except for the following cases, the Company does not provide or disclose personal data to third parties:
(a) When there is consent from the individual concerned.
(b) When providing or disclosing statistical data or other data that cannot identify the individual concerned.
(c) When required by law.
(d) When necessary for the protection of a person’s life, body, or property, and obtaining consent from the individual concerned is difficult.
(e) When necessary for the improvement of public health or the promotion of healthy growth of children, and obtaining consent from the individual concerned is difficult.
(f) When it is necessary to cooperate with national institutions, local governments, or persons entrusted by them in performing tasks specified by laws and regulations, and obtaining consent from the individual concerned may hinder the performance of such tasks.
(g) In other cases where disclosure or provision is permitted by laws, etc.
When providing personal data to a third party within a reasonable and necessary scope for the achievement of the purposes of use mentioned above, the Company creates and keeps records of the provision to third parties.

2.Provision of Specific Personal Information to Third Parties
Regardless of the above, except in cases specified in Article 19 of the Number Act, the Company does not provide specific personal information to third parties. The Company also does not engage in joint use of personal data based on the Personal Information Protection Law.

PRINCIPLE 5 : SECURITY MEASURES
The Company manages personal data appropriately and securely and takes necessary and appropriate measures to prevent unauthorized access to personal data from external sources, as well as its unauthorized use, loss, destruction, alteration, leakage, etc.
PRINCIPLE 6 : HANDLING OF PERSONAL DATA BY CONTRACTORS
In some cases, the Company may outsource the handling of personal data it holds to external parties. When the Company outsources all or part of the handling of personal data to external parties, it selects and concludes outsourcing contracts with the parties based on the condition that they have established and implemented a management system to appropriately protect personal data. The Company also provides necessary and appropriate supervision to the outsourced parties to ensure the secure management of personal data.
PRINCIPLE 7 : CONTINUOUS IMPROVEMENT
The Company establishes internal rules regarding personal information, including this Privacy Policy, and continuously reviews and strives for improvements. Additionally, the Company may revise this Privacy Policy as necessary due to changes in laws or other reasons.
PRINCIPLE 8 :
NOTIFICATION OF PURPOSE
OF USE AND OTHER REQUESTS FOR HELD PERSONAL DATA
The Company manages the acquired personal information as accurately and up-to-date as possible. Regarding the held personal data, if the individual concerned makes a request, the Company will carry out the appropriate procedures for identity verification in accordance with the law, and provide the necessary response, such as notification, disclosure, correction, addition, deletion, suspension of use, erasure, and cessation of provision to third parties concerning the personal information, as well as the disclosure of records of provision to third parties. Please contact the inquiry desk stated below.
PRINCIPLE 9 :
HANDLING REQUESTS FOR NOTIFICATION, ETC.,
REGARDING PURPOSE OF USE OF HELD
Individuals may make requests to the Company’s inquiry desk for notification of the purpose of use of their own personal data, disclosure (including disclosure by providing electronic records), correction, addition, deletion, cessation of use or erasure of personal information by the Company, cessation of provision of personal data by the Company to third parties, or inquiries regarding complaints, etc. In such cases, after verifying the identity of the applicant (submitting a copy of a driver’s license, etc.), the Company will respond within a reasonable period (in the case of an agent, after confirming that the person is an agent, the Company will respond within a reasonable period). However, in cases where it would violate other laws or regulations, etc., the Company may not be able to comply with the aforementioned requests. In such cases, the Company will strive to explain the reasons to the individuals concerned. In addition, when making requests for notification of the purpose of use, disclosure, or disclosure of records of provision to third parties concerning held personal data, there may be cases where a prescribed fee is required to be paid by the individual concerned.
For questions regarding the contents of this Privacy Policy, please contact the Company’s inquiry desk.
[Inquiry Desk]
Address: 16th Floor, Otemachi Nomura Building, 1-1-1 Otemachi, Chiyoda-ku, Tokyo 100-0004, Japan
Company Name: Takara Asset Management Co., Ltd., Management Administration Department
Phone: +81-3-6262-6402
Email: info@takara-am.co.jp
Reception hours:
From 9:00 a.m. to 5:30 p.m..(JST) (excluding Saturdays, Sundays, national holidays, and year-end and New Year holidays)
Regarding matters related to the shareholder register, please contact the Registrar.
[Registrar]
Address: 8-4 Izumi 2-chome, Suginami-ku, Tokyo, Japan
Company Name: Mizuho Trust & Banking Co., Ltd., Securities Agency Department
Phone: 0120-288-324
URL: http://www.mizuho-tb.co.jp/
Reception hours:
From 9:00 a.m. to 5:00 p.m. .(JST)(excluding Saturdays, Sundays, national holidays, and year-end and New Year holidays)
PRINCIPLE 10 :
CERTIFIED PERSONAL INFORMATION PROTECTION ORGANIZATION
The Company is a subject business operator under the following certified personal information protection organization. The certified personal information protection organization accepts complaints and consultations regarding the handling of personal information by subject business operators. In such cases, please contact the inquiry desk stated below.
[Inquiry Desk]
Organization Name: Investment Trusts Association, Japan, Investor Consultation Office
Phone: +81-3-5614-8440
Reception hours: From 9:00 a.m. to 11:30 a.m. and from 12:30 p.m. to 5:00 p.m. JST(excluding Saturdays, Sundays, national holidays, and year-end and New Year holidays).

That’s all.Enacted on March 23, 2016
Partially revised on June 21, 2022