Privacy Policy|Nippon Prologis REIT, Inc.

Nippon Prologis REIT, Inc.

Privacy Policy

Name of the Investment Corporation and other related information
Nippon Prologis REIT, Inc.
Satoshi Yamaguchi, Executive Director
Tokyo Building 21F, 2-7-3 Marunouchi, Chiyoda-ku, Tokyo

1. Basic Policy on Protection of Personal Information

Nippon Prologis REIT, Inc. (hereinafter “NPR”) recognizes the importance of personal information, and is committed to appropriately handling personal information by complying with the Act on the Protection of Personal Information (hereinafter the “Personal Information Protection Act”) and the Act on the Use of Numbers to Identify Specific Individuals in Administrative Procedures (hereinafter the “Numbers Act”) as well as other related laws and regulations, guidelines and the like. The terms used in this Privacy Policy that are the same as the terms defined in the related laws and regulations shall have the meanings defined therein.

2. Acquisition of Personal Information

2.1 Acquisition of Personal Information
NPR will acquire personal information through appropriate means. If personal information is acquired directly from the individual concerned in written form, via the Internet or the like, the purpose of use of such information shall be disclosed in advance to the individual concerned; provided, however, that in the event that the purpose of use is considered to be clear from the circumstances of such acquisition, then such disclosure may not be conducted. NPR will not use personal information in any manner that may encourage or provoke illegal or unjust acts.

2.2 Acquisition of Individual Numbers
Notwithstanding Article 2.1 above, NPR may request the individual concerned or another person in charge of a process related to an individual number to provide the individual number of the individual concerned only if it is necessary for handling the general administrative operations provided for in Article 4 below. In addition, a request for the provision of an individual number will be made at the time when it becomes necessary to do so in order to conduct such general administrative operations or when they are expected to arise.

2.3 Verification of Identity
When an individual number is provided, NPR will verify the identity of the individual concerned who provided his or her individual number in the manners provided for in Article 16 of the Numbers Act. In the case where an individual number is provided by an agent for the individual concerned, NPR will verify the identity of the agent, its authority to represent the individual concerned, and the individual number of the individual concerned in the manners provided for in the same Article.

2.4 Acquisition, Use or Provision of Sensitive Personal Information
NPR will not acquire, use or provide sensitive personal information to any third parties unless permitted by related laws and regulations, guidelines, and the like.

3. Management of Personal Data

NPR strives to manage acquired personal data to be accurate and up to date to the extent possible, and to delete personal data without delay when the use of the personal data is no longer necessary. In order to prevent leakage, loss, damage or the like of personal data (hereinafter “Leakage, etc.”), NPR will implement adequate security control measures for each stage such as the acquisition, use, storage and the like of such data. NPR has delegated business pertaining to the management of assets to Prologis REIT Management K.K. (hereinafter the “Asset Manager”) and has requested the Asset Manager to take adequate security control measures. Specifically, the Asset Manager takes the following measures.

Specific security control measures taken by the Asset Manager are as follows:

  1. Organizational Security Control Measures
    The Asset Manager appoints a person responsible for handling personal data and establishes rules for each stage of the handling of personal data. Based on those rules, the Asset Manager inspects and reviews the handling of personal data by regularly updating the registration records to conform with the personal data list. Furthermore, the Asset Manager constructs the system for handling emergency situations such as the Leakage, etc.
  2. Human Security Control Measures
    The Asset Manager provides its officers and employees with education and training with respect to adequate handling and security control of information properties in order to improve their awareness of information security.
  3. Physical Security Control Measures
    The Asset Manager restricts access to devices used for handling information properties and the like by locking the office, controlling entry into and exit from the office, as well as setting up a room dedicated to housing servers. Also, the Asset Manager takes measures to prevent theft, loss and the like through the control of information devices to be taken out and other similar means. The Asset Manager sets out the procedures for the disposal of information devices and information properties and takes necessary measures to ensure that they are disposed of properly.
  4. Technical Security Control Measures
    The Asset Manager grants access authorities to the persons in charge so that the scope of personal data to be handled by those persons in charge will be limited, and conducts a user authentication whenever the personal data is accessed. The Asset Manager strives to take necessary measures to prevent cybersecurity incidents such as unauthorized access from the outside.

4. Purposes of Use

4.1 Purposes of Use of Personal Information

NPR will use the acquired personal information for the following purposes:

  1. To enable unitholders to exercise their rights and to perform NPR's obligations under the Act on Investment Trusts and Investment Corporations and other related laws and regulations (the "Investment Trust Laws");
  2. To manage unitholder information, such as in the preparation of the unitholder registry required under the Investment Trust Laws, and to provide information to unitholders;
  3. To respond to or confirm inquiries or visits to NPR;
  4. To conduct an asset management through acquisition, disposition and leasing of properties, and conduct other activities related to NPR's business, as well as to conduct the necessary analyses, data collection and reporting related to such business;
  5. To offer units of NPR and issue investment corporation bonds;
  6. To verify the identity of persons whose names are stated in applications, contracts and the like in order to conduct NPR's business; and
  7. To conduct general administrative operations as well as other activities related to or incidental to NPR's business, besides the aforementioned purposes ① through ⑥.

4.2 Purposes of Use of Individual Numbers

Notwithstanding Article 4.1 above, NPR will use individual numbers for the following purposes:

  1. To conduct general administrative operations for the preparation and submission of payment records concerning payments of remuneration, fees, contract amounts, prize money, or any other payments of consideration for services or rights;
  2. To conduct general administrative operations for the preparation and submission of payment records concerning payments for usage or acquisition of real estate;
  3. To conduct general administrative operations for the preparation and submission of payment records concerning payments of dividends, surplus, interest or the like, or any other distributions of profits;
  4. To conduct general administrative operations for the preparation and submission of withholding receipts from employment income or salary payment reports;
  5. To conduct any other general administrative operations related to the aforementioned purposes (1) through (4); and
  6. To conduct general administrative operations for the preparation of statutory records which require individual numbers to be stated pursuant to the provisions of laws and regulations.

5. Disclosure or Provision of Personal Data to Third Parties

5.1 Disclosure or Provision of Personal Data to Third Parties

NPR will not disclose or provide personal data to third parties except in the following cases:

  1. Consent is obtained from the individual concerned;
  2. The disclosure or provision of personal data is based on the applicable laws and regulations;
  3. The disclosure or provision of personal data is necessary for the protection of the life, body or property of any person (including corporations) and it is difficult to obtain the consent of the individual concerned;
  4. The disclosure or provision of personal data is particularly necessary for improving public health or for promoting the sound growth of children, and it is difficult to obtain the consent of the individual concerned;
  5. The disclosure or provision of personal data is necessary in order to cooperate with national or local government agencies, or with individuals or business operators entrusted by those agencies to execute affairs as required by laws and regulations, and consent from the individual concerned may impede the execution of such affairs;
  6. The disclosure or provision of personal data is necessary to verify the identity of persons whose names are stated in applications, contracts and the like in order to conduct NPR’s business;
  7. NPR provides personal data to its contractors under NPR's appropriate supervision, to the extent necessary for the purposes of use; and
  8. The disclosure or provision of personal data is permitted by laws regarding the protection of personal information and other related laws, guidelines and the like.

5.2 Provision of Specific Personal Information to Third Parties

Notwithstanding Article 5.1 above, NPR will not disclose or provide specific personal information to any third parties except for the cases prescribed in each item of Article 19 of the Numbers Act.

6. Supervision of Contractors

NPR will appropriately supervise contractors to whom personal information has been disclosed or provided, in order to ensure adequate security control measures.

7. Disclosure, Correction, Deletion and Suspension of Use, etc. of Retained Personal Data, etc.

In the event of a claim or request made by the individual concerned with respect to retained personal data, NPR will, after verifying the identity of the individual concerned, take measures such as disclosure (including disclosure by means of provision of electromagnetic records), correction, deletion, suspension of use, etc. in accordance with applicable laws and regulations. The same applies to the disclosure of records on provision or receipt of personal data to or from any third parties.

8. Inquiries Concerning Personal Information

For inquiries regarding the disclosure, correction or suspension of use of personal information that has been provided, please contact Prologis REIT Management K.K. at the following address. In addition, complaints and the like will be received at the same address:

Address Tokyo Building 21F, 2-7-3 Marunouchi, Chiyoda-ku, Tokyo 100-6421 Japan
Prologis REIT Management K.K. (Asset Manager)
Telephone +81(0)3-6867-8585
Business Hours 9:00 a.m. to 5:30 p.m. Japan Standard Time (Closed on weekends and national holidays)

For inquiries regarding the unitholder registry and other related matters, please contact our transfer agent:

Address 2-8-4 Izumi, Suginami-ku, Tokyo 168-0063 Japan
The Transfer Agent Division of Sumitomo Mitsui Trust Bank, Limited
Telephone 0120-782-031 (toll-free, available within Japan only)
Business Hours 9:00 a.m. to 5:00 p.m. Japan Standard Time (Closed on weekends and national holidays)

9. Amendments

In addition to the review required by the revision or abolition of laws and regulations, NPR will continuously review this Privacy Policy as necessary and strive to further improve our efforts to protect personal information.

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