Recognizing the importance of personal information, MORI TRUST Sogo Reit, Inc. (MTR) declares that it will comply with the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter the “Personal Information Protection Act”) and other related laws, regulations and guidelines, etc. and work for the appropriate handling, management and protection of personal information.

1. Acquisition of personal information

MTR will acquire personal information through legitimate and appropriate means. If MTR acquires personal information through a third party, MTR will not accept personal information that the third party may have acquired illegally or unduly.
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 will not be acquired or used except for cases stipulated in the Guidelines in Financial Field.

2. Procedures for notice and announcement, etc. of the purpose of use of personal information

（1）	When MTR acquires personal information, MTR will announce the purpose of use beforehand or give the person concerned notice of or announce the purpose of use immediately after the acquisition. If MTR acquires personal information directly from the person concerned in writing, MTR will clearly specify the purpose of use beforehand.
（2）	If MTR changes the purpose of use of personal information, MTR will give the person concerned notice of or announce the purpose of use after the change.
（3）	If MTR notifies the person concerned of the purpose of use of personal information, MTR will do so in writing in principle. When MTR announces the purpose of use of personal information, MTR will do so on its website or by other appropriate means.
（4）	Notwithstanding the provisions in (1) and (2) above, if the purpose of use of personal information is thought to be obvious, judging from the situation of the acquisition thereof or if it is allowed under the Personal Information Protection Act, MTR may omit the notice, announcement or specification of the purpose of use.

3. Purpose of use of personal information

Unless otherwise stipulated by laws and regulations, MTR will not handle personal information beyond the extent necessary to achieve the purpose of use stated below without obtaining the consent of the person concerned.

(i)	To exercise the rights of investors and perform the obligations of MTR,
(ii)	To implement measures to facilitate the relationship between MTR and investors,
(iii)	To manage investors using data such as the investors’ registry prepared in accordance with the Act on Investment Trusts and Investment Corporations (Act No. 198 of 1951), the Companies Act (Act No. 86 of 2005) and other related laws and regulations,
(iv)	To borrow loans and issue investment corporation bonds and additional investment units by MTR,
(v)	To implement business related to the acquisition, examination and consideration of acquisition of assets under management and sale and other disposal of assets under management by MTR,
(vi)	To implement the leasing business of assets under management by MTR,
(vii)	To implement business incidental or related to (i) through (vi) above, and
(viii)	To provide personal information to a third party to achieve the purpose of use listed in each preceding item.

MTR will not use personal information in any manner that may encourage or provoke illegal or unjust acts.

4. Disclosure and provision of personal information to third parties

MTR will not provide the personal information it acquires to any third party without the consent of the person concerned, except in cases where the provision of the information is based on laws, where the information is provided through the entrustment in whole or in part of the handling thereof within a scope necessary for achieving the purpose of use, where the provision thereof is based on other legal provisions or where the consent of the person concerned is obtained in advance.
When providing Personal information to a third party in a foreign country, MTR will comply with the obligations stipulated by the Act on the Protection of Personal Information and other related laws, regulations and guidelines, etc.

5. Safety management of personal information

MTR will make efforts to keep personal information accurate and up to date within the scope necessary for achieving the purpose of use. At the same time, MTR will make efforts to delete personal information without delay when its use becomes unnecessary and implement appropriate safety management measures to prevent the loss, leak and falsification, etc. of personal information.
Since MTR has entrusted its asset management services, etc. in accordance with the Act on Investment Trusts and Investment Corporations, MTR makes every effort to properly and carefully manage personal data retained by MTR, and takes all adequate measures necessary to prevent unauthorized access, loss, leakage or tampering etc. of personal information.
If MTR entrusts the handing of all or part of personal information to a third party, MTR will exercise necessary and appropriate supervision to the third party.

6. Continuous improvement of the personal information protection system and initiatives

In addition to acting when changes are made, such as in the Act on the Protection of Personal Information and other related laws, regulations and guidelines, etc., MTR will review its privacy policy as necessary and take steps to strengthen and improve the personal information protection system and initiatives.

7. Inquiries about personal information

For questions and complaints about the personal information retained by MTR and a request for disclosure, revision, suspension, suspension of provision to a third party or disclosure of provision record to a third party of the use thereof, please make an inquiry to the point of contact for the Asset Management Company below.

(Contact for Inquiries)
■ MORI TRUST Asset Management Co., Ltd. Business Administration Department

Tel.	03-6435-7011
Reception hours	9 a.m. – 5:45 p.m. (Excluding Saturdays, Sundays, public holidays and holidays designated by the Company)

The Asset Management Company is a member of the Investment Trusts Association, Japan, an authorized personal information protection organization, and the Investment Trusts Association, Japan handles complaints and provides consultation about the handling of personal information of its members.

(Contact for Inquiries)
■ Investment Trusts Association, Japan, Investor Consultation Section

Tel.	03-5614-8440
Reception hours	9 a.m. – 11:30 a.m. and 0:30 p.m. - 5:00 p.m. (Excluding Saturdays, Sundays, public holidays and holidays designated by the Association)

For inquiries about matters written in the investors’ registry, please consult with the transfer agent.

(Transfer agent)
■ Sumitomo Mitsui Trust Bank, Limited, Stock Transfer Agency Business Planning Department

Tel.	0120-782-031

8. Name, Address and Name of Representative of Business Operator Handling Personal Information

Name	MORI TRUST REIT, Inc.
Address	3-1 Toranomon 4-chome, Minato-ku, Tokyo
Name of Representative	Hiroshi Naito

Last updated : June 30, 2023