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Privacy Policy

I. Basic Policy

Hoshino Resort REIT, Inc. (hereinafter “HRR”) complies with the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter the “Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (Act No. 27 of 2013; hereinafter the “Number Use Act”), other related laws, regulations and guidelines of competent authorities, and strives for proper handling of personal information (including individual numbers and specific personal information).

II. Collection of Personal Information

1. Collecting Personal Information
HRR collects Personal Information in an appropriate and legal manner on an as-required basis for purposes specified below, and shall not collect Personal Information through deceptive or illegal means. Moreover, HRR shall not collect Sensitive Information without consent from the relevant individual except in the cases stipulated in the Personal Information Protection Act and the guidelines. Prior to collecting Personal Information, HRR discloses on its Website the purpose and intended use of collected Personal Information. When HRR collects Personal Information directly through written form, etc., HRR shall clearly state the purpose and intended use of the Personal Information beforehand. However, when the purpose and intended use is obvious at the time from conditions of the Personal Information being provided, or it is permissible under other laws and regulations, such disclosure may be omitted.
2. Collecting Individual Numbers
Notwithstanding the above 1., HRR may request the individual or operators handling individual numbers related administration of the provision of individual numbers, to the extent necessary for processing the administration stipulated in III. 2. below. Furthermore, HRR shall request the provision of individual numbers at the time when it is necessary to process the said administration, or when it is projected to the occurrence of the said administration.
3. Identity Verification
When accepting individual numbers, HRR shall identify individuals by using the methods designated in Article 16 of the Numbers Act. As for provision of individual numbers by proxies, HRR shall identify the relevant proxies, confirm their authority of proxy, and check their individual numbers based on the methods designated in the said Article.

III. Purpose and Intended Use

1. Purpose and Intended Use of Personal Information
HRR shall use collected Personal Information to the extent necessary for achieving the following purposes.
  • To exercise the rights of unitholders and fulfill the obligations of HRR under the Act on Investment Trusts and Investment Corporations, and other related laws and regulations
  • To manage HRR’s unitholders’ information, such as compiling data for the unitholders’ register, etc.
  • To facilitate borrowings and the issuance of corporate bonds and offering of investment units by HRR
  • To respond to inquiries and requests for materials made to HRR
  • To make investigation and analysis, and to hold discussions for the purpose of managing HRR’s assets
  • To execute property acquisitions, sales and to conduct businesses related to leasing, maintenance and management of real estate by HRR
  • To appropriately and smoothly facilitate businesses related to HRR’s IR activities and unitholder special benefit plan, and other HRR businesses
  • To facilitate other businesses related to or incidental to preceding items
2. Purpose and Intended Use of Specific Personal Information
Notwithstanding the above 1., HRR may use Specific Personal Information for the following purposes.
  • Specific Personal Information of directors of HRR and their relatives
    To handle work related to tax withholding, etc. and conduct filings and applications for social insurance, labor insurance or corporate pension, etc. and other operations incidental or related to such.
  • Specific Personal Information of customers and clients
    To prepare statutory reports, etc. in which individual numbers must be indicated due to legal requirements.

IV. Restrictions on Provision of Personal Information to Third Parties

1. Provision of Personal Data to Third Parties
HRR shall not provide or disclose Personal Information to any third parties without prior consent from the relevant individual except in the cases specified below.
  • When it is required by laws and regulations
  • When it is necessary to protect human life or personal property, and obtaining consent from the relevant individual is difficult
  • When it is especially necessary for the improvement of public health or the promotion of sound upbringing of children, and obtaining consent from the relevant individual is difficult
  • When it is necessary to cooperate with national or local governments or a party entrusted by the government to carry out operations required by laws or regulations, and obtaining consent from the relevant individual may be a hindrance to carrying out such operations
  • Based on the description in vii., when HRR entrusts Personal Information handling to a third party
  • When HHR provides or discloses the Personal Information in a manner that does not allow identification of individuals, such as in statistical data
  • When provision or disclosure is approved by the Personal Information Protection Act, other laws and regulations and guidelines.

Items of Personal Information that may be provided are name, address, telephone number, e-mail address, contract information, status of use of HRR’s assets, and other items necessary for achieving the purpose for use of collected Personal Information.

2. Provision of Specific Individual Information to Third Parties
Notwithstanding the above 1., HRR shall not provide Specific Individual Information to any third parties unless otherwise provided in items of Article 19 of the Number Use Act.

V. Securing of Accuracy, etc.

HRR shall strive to keep Personal Data both accurate and updated to the extent required for the above purposes, and to delete such data without delay when its use is no longer necessary.

VI. Safety Control Measures

HRR shall manage Personal Data retained by HRR properly and carefully and take necessary and appropriate safety control measures pursuant to laws, regulations and guideless, etc. to prevent unauthorized access to Personal Data, leakage, loss and damage of Personal Data and to ensure safe management of other Personal Information.

VII. Entrustment of Personal Information Handling

HRR may entrust the handling of Personal Data to third parties (including Hoshino Resort Asset Management Co., Ltd., and Hoshino Resorts Inc. and its subsidiaries) to any extent reasonably necessary for achieving the purpose of use of Personal Data. In such cases, HRR shall take necessary and appropriate measures to ensure appropriate supervision over such third parties.

VIII. Procedures for Disclosure, Alteration, Suspension, etc. of Use of Personal Information

Please contact the desk stated in IX. below for requests concerning disclosure, alternation, suspension, etc. of Personal Information retained by HRR. HRR shall provide further details about procedures necessary for such disclosure, alternation, suspension and termination, etc. according to laws and regulations, etc., after confirming identification of the relevant individual through designated procedures. Please note that actual costs for such disclosure may be incurred.

IX. Contact Desk for Inquiries Relating to Personal Information and for Filing Complaints

[ Contact desk ]
3-6-18, Kyobashi, Chuo-ku, Tokyo 104-0031
Hoshino Resort Asset Management Co., Ltd.
TEL: +81-3-5159-6338
Hours: 9:30 a.m. to 5:00 p.m.
(excluding Saturdays, Sundays, National holidays, year-end and New Year holidays)

Please contact the unitholders’ register manager below for inquiries and requests concerning alternation, addition or deletion of items in the register, and other matters related to the register.
[ Unitholders’ register manager ]
7-10-11, Higashisuna, Koto-ku, Tokyo 137-8081
Stock Transfer Agency Business Planning Department
Mitsubishi UFJ Trust and Banking Corporation
TEL: +81-3-6701-5000
Hours: 9:00 a.m. to 5:00 p.m.
(excluding Saturdays, Sundays, National holidays, year-end and New Year holidays)

X. Ongoing Improvements

HRR shall strive to further improve measures for Personal Information protection through ongoing review of the Privacy Policy, in the case amendment or abolishment of laws and regulations, etc., or as needed.