Privacy Policy (Personal Information Protection Declaration)

I. Basic Policy

1. GAR will comply with the Act on the Protection of Personal Information and other related laws/ordinances and administrative guidelines of the competent authorities.
2. GAR will acquire personal information through appropriate and fair means in accordance with laws/ordinances, and will endeavor to ensure that the information is accurate and up-to-date.
3. GAR will not use personal information beyond the scope necessary to achieve the purposes of use without the consent of the person concerned, unless otherwise required by laws/ordinances. Furthermore, GAR will not disclose or provide personal information to a third party without the agreement of the person concerned, unless there is a legitimate reason to do so, such as a legal obligation to disclose the information to a third party.
4. GAR will establish internal rules necessary for the safe management of personal information and thoroughly educate its officers and employees in order to prevent leakage, loss, damage, or unauthorized use of personal information. Furthermore, GAR will designate a person to be responsible for management/inspections, and take other steps to establish a structure for safe management that is necessary and appropriate for the protection of personal information.
5. If GAR outsources the handling of personal information, GAR will responsibly supervise the outsourcee as necessary and appropriate to ensure that personal information is protected.
6. GAR will, at the request of the person concerned, disclose, correct, cease use, etc. of retained personal data or disclose records of its provision to third parties in accordance with laws/ordinances. In such a case, GAR may charge an amount equivalent to the actual costs it incurred to fulfill the request.
7. GAR will periodically review and continuously improve its management structure and other programs related to the protection of personal information.

II. Purposes of Use of Personal Information

GAR will use personal information (name, address, date of birth, place of employment, annual income, telephone number, e-mail address, etc.) it acquires in the course of conducting Investment Corporation Asset Management Business, Discretionary Investment Management Business, Investment Advisory and Agency Business, and other businesses of GAR for the following purposes:

1. To exercise rights and perform obligations of GAR in accordance with the Financial Instruments and Exchange Act, the Act on Investment Trusts and Investment Corporations, the Companies Act, and other relevant laws/ordinances.
2. To respond to and confirm inquiries and visits to businesses conducted by GAR.
3. To conduct research and analysis, collect data, and provide various types of information as necessary for the execution of businesses conducted by GAR.
4. To verify the identities of parties on application forms, contracts, etc. for the execution of businesses conducted by GAR.
5. To perform general administration and other related or incidental work involved in businesses conducted by GAR.

III. Matters Concerning Measures for Safe Management

1. To prevent leakage, loss, or damage of personal data handled by GAR and to otherwise ensure the safe management of personal data, GAR takes the following organizational, personnel-related, physical, and technical measures for safe management at each stage, namely personal data acquisition/input, use/processing, storage/preservation, transfer/transmission, disposal/erasure, and response to incidents of leakage etc.
2. As organizational safe management measures, GAR has clearly defined the responsibilities and authority of officers and employees with respect to measures for the safe management of personal data, and has put in place structures and takes measures such as establishing and implementing rules etc. for safe management and conducting inspections and audits of the status of adherence to such rules etc.
3. As personnel-related safe management measures, GAR requires its officers and employees to submit a written pledge to protect and properly handle personal information, and takes measures to provide education and training to officers and employees.
4. As physical safe management measures, GAR controls the access of officers and employees to rooms at sales offices, strictly manages the devices, electronic media, etc. used for the handling of personal data in controlled areas, and takes measures to prevent personal data from being taken out of offices or viewed by unauthorized persons.
5. As technical safe management measures, GAR conducts strict management with respect to controlling access to information systems and personal data and identifying/authenticating persons with access, such as by restricting access privileges.

IV. Contact Desk for Inquiries Concerning Personal Information

Please use the following contact for requests for disclosure, correction, addition, deletion, cessation of use or provision to third parties, or erasure of retained personal data, requests for disclosure of records of its provision to third parties, or other questions, opinions, or complaints concerning personal information. Our staff will be happy to guide you through the necessary procedures.

4-1 Kojimachi, Chiyoda-ku, Tokyo 102-0083
Personal Information Consultation Desk, Planning & General Affairs Department, Global Alliance Realty Co., Ltd.
Tel: 03-3262-1471 (available 9:00 a.m. to 5:00 p.m. except Saturdays, Sundays, national holidays, and other holidays)

V. Procedures for Disclosure etc. of Retained Personal Data or Records of Its Provision to Third Parties

1. Requests for disclosure etc.

If we receive a request for disclosure, correction, addition, deletion, cessation of use or provision to third parties, erasure, or disclosure of records of provision to third parties of personal data retained by GAR (hereinafter collectively referred to as "disclosure etc."), we will respond appropriately without delay in accordance with laws/ordinances as soon as we have confirmed that the request was made by the person concerned or their legitimate representative.

2. Contact desk for requests for disclosure etc.

To make a request for disclosure etc., please send GAR's prescribed request form together with an identification document such as a copy of a driver's license to the Personal Information Consultation Desk above by mail (registered mail, simplified registered mail, etc.) or courier service with recorded delivery.

3. Method of response to requests for disclosure etc.

We will respond to you within a reasonable period of time by sending an electromagnetic record to the address you provided in the request form, or by any other method specified in the Personal Information Protection Commission Rules that you request (or by delivering a paper document if disclosure by such a method would cost a large amount of money or be difficult to perform).

VI. Name of Accredited Personal Information Protection Organization and Contact Details for Resolution of Complaints

GAR is a business operator under the purview of the following accredited personal information protection organization:

1. Investment Corporation Asset Management Business-related

Investor Consultation Office, The Investment Trusts Association, Japan
Tel: 03-5614-8440 (available 9:00 a.m. to 5:00 p.m. except Saturdays, Sundays, national holidays, and other holidays)

2. Discretionary Investment Management Business / Investment Advisory and Agency Business-related

Personal Information Manager, Complaint Consultation Office, Secretariat Office, Japan Investment Advisers Association
Tel: 03-3663-0505 (available 9:00 a.m. to 5:00 p.m. except Saturdays, Sundays, national holidays, and other holidays)

Note that this Privacy Policy may be revised to reflect changes etc. in laws/ordinances.

Revised on April 1, 2022