Privacy Statement

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Privacy Statement

1. Scope

This privacy statement applies to personal data processed by HHRAM in its activities at its offices within the European Economic Area (EEA).

2. General Principles of Processing Personal Data

HHRAM shall process personal data in accordance with the following general principles:

  • Process personal data lawfully, fairly and in a transparent manner in relation to a data subject.
  • Process personal data only to the extent necessary for achieving the purpose of use specified in advance.
  • Store personal data for the period necessary for achieving the purpose of use.
  • Maintain personal data accurately and update data to the extent necessary for the purpose of use.
  • Process personal data by implementing appropriate technical and organizational measures.

3. Purpose of Use of Personal Data

HHRAM shall handle personal data obtained for the proper execution of asset management operations and incidental operations entrusted by Hankyu Hanshin REIT, Inc. (hereinafter ""HHR"") pursuant to the ""Act on Investment Trusts and Investment Corporations"" (hereinafter the ""Investment Trust Act""). Unless otherwise provided by laws and regulations, HHRAM shall handle such personal data solely within the scope necessary to achieve the following purposes of use. Furthermore, HHRAM shall not revise the purpose of use of personal data beyond the scope reasonably acceptable for the purpose of use before the revision.

  1. to exercise rights of the holders of securities issued by HHR and performance of obligations of HHR pursuant to the Investment Trust Act and other laws and regulations;
  2. to conduct IR activities concerning HHR;
  3. to prepare and submit various reports, etc., as well as prepare various data for management of unitholders' register and other unitholders' information of HHR pursuant to the Investment Trust Act, other laws and regulations, and rules of Tokyo Stock Exchange, Inc., etc.;
  4. to respond to inquiries, etc., to HHR or HHRAM;
  5. to conduct debt financing by HHR, and issuance of investment corporation bonds for subscription, investment units for subscription and other securities issued by HHR;
  6. for HHRAM to acquire and sell assets under management and lease assets under management as part of its entrusted asset management operations, as well as survey and review, collect and provide information and execute various other business operations involved in asset management conducted under the Investment Trust Act;
  7. to appropriately and smoothly execute other business operations of HHRAM or the asset management operations entrusted by HHR to HHRAM
  8. for administrative work related to notifications for employment insurance and worker's accident compensation insurance, and applications for benefits, etc;
  9. for administrative work related to notifications for health insurance and employees' pension insurance, and applications for benefits, etc;
  10. for administrative work related to notifications for Category III insured persons of the National Pension, etc.;
  11. for administrative work related to income tax withholding for salaries, bonuses, and year-end adjustments, etc. (including administrative work to receive submissions from employees, etc., of declarations for spousal deductions, etc. (changes), declarations for spousal deductions (changes) for secondary salaries, and declarations for insurance premiums and special spousal deductions);
  12. for administrative work related to the preparation and submission of withholding slips (including salary payment reports);
  13. for administrative work related to the preparation and submission of salary payment reports/salary earner change notifications for special collection, etc.;
  14. for administrative work related to the preparation and submission of withholding slips for retirement income. (including submission of declarations concerning receipt of retirement income, preparation and submission of special collection slips for retirement income, and preparation and submission of payment records by recipient of retirement allowance, etc.);
  15. for administrative work related to the provision of information to joint trustees and joint trustee insurers who perform benefit administration for recipients of retirement annuities;
  16. for administrative work related to the preparation and submission of payment records concerning remuneration, fees, contract money, and prizes paid by HHRAM to lecturers, lawyers, tax accountants, or social insurance labor consultants, etc.;
  17. for administrative work related to the preparation and submission of payment records concerning dividends, distribution of surplus, and fund interest paid by HHRAM to shareholders who received such payments;
  18. for administrative work related to the preparation of membership lists, etc., for members of shareholding associations and the provision of such lists to shareholding associations;
  19. for administrative work related to the submission of declarations, notifications, and application forms concerning property accumulation housing savings or property accumulation pension savings;
  20. for administrative work related to the preparation and submission of payment records for property use fees, etc., concerning real estate lessors to whom HHRAM paid rent, etc.;
  21. for administrative work related to the preparation and submission of payment records for the consideration of acquisition of real estate, etc., concerning persons to whom HHRAM paid the consideration for the transfer of real estate, etc.;
  22. for administrative work related to the preparation and submission of payment records for brokerage fees for the sale or lease of real estate, etc., concerning persons to whom HHRAM paid such fees
  23. to conduct affairs of preparing records of financial instruments transactions, etc.
  24. to prepare payment records concerning payment of compensation, fees, signing bonuses, bonuses and other remuneration for services or rights.
  25. to prepare payment records concerning payment of remuneration for use or incoming transfer of real estate, etc.
  26. to prepare payment records concerning payment of distributions, surplus or interest, etc., and other distribution of income.
  27. to prepare records concerning granting or exercise of subscription rights to investment units or allotment of investment units without contribution of HHR's investment units.
  28. to prepare statutory records, etc., for which the entry of Individual Numbers is required by the provisions of other laws and regulations.

4. Legal Basis of Processing Personal Data

HHRAM shall process personal data based on one of the following legal bases.

  • When HHRAM has obtained the consent of the data subject, or when notices of necessary matters are made to the data subject.
  • The processing is necessary to execute a contract with the data subject.
  • The processing is necessary for HHRAM to fulfil its legal obligations.
  • The processing is necessary to secure legitimate interests pursued by HHRAM.

5. Providing Personal Data to a Third Party

  • If HHRAM provides personal data to a third party as part of the processing of personal data based on the applicable legal basis, it shall communicate the information of the recipient to the data subject.
  • If HHRAM transfers personal data from the territory of EEA to outside the EEA, it shall implement safeguards required under applicable laws and regulations.

6. Taking Action on the Rights of Data Subjects

HHRAM shall take appropriate actions on the data subject’s requests on the processing of personal data concerning him or her in accordance with applicable laws and regulations. These shall include:

  • Access to the personal data
  • Rectification or erasure of the personal data
  • Restriction on the processing of the personal data
  • Lodging a complaint against the processing of the personal data
    The data subject may lodge a complaint with the supervisory authority.
  • Data portability of the personal data
  • Withdrawal of consent on the processing of the personal data
  • Contest against the processing of the personal data

7. Measures for the Protection of Personal Data

  • HHRAM shall implement appropriate, necessary measures including measures against, including but not limited to, illegal access, computer viruses to prevent incidents such as loss, destruction, manipulation or leakage of personal data. HHRAM shall also provide appropriate and necessary supervision over its employees, contracted processors, etc. to ensure the protection of personal data.

8. Inquiry Contacts

HHRAM shall respond sincerely to questions, complaints, etc., regarding the handling of personal information. Please inquire to the contact below for any questions, requests for notification of purpose of use, requests for disclosure, correction, discontinuance of use, discontinuance of provision to any third party, complaints, etc., regarding personal information.

Hankyu Hanshin REIT Asset Management, Inc. Human Resources and General Affairs Department

Address 19-19 Chayamachi, Kita-ku, Osaka
TEL +81-6-6376-6821
Business hours 9 a.m. to 5 p.m.(except Saturdays, Sundays, national holidays, and company-designated holidays)

Mitsubishi UFJ Trust and Banking Corporation Osaka Corporate Agency Division

Address 3-6-3 Fushimimachi, Chuo-ku, Osaka
TEL +81-42-204-0303
Business hours 9 a.m. to 5 p.m.(except Saturdays, Sundays, national holidays, and company-designated holidays)

Contact（EEA and UK residents）

As we are based outside of the EU/UK, Article 27 GDPR/UK GDPR required that we appoint an EU representative/UK representative to handle certain data subject requests and queries. In compliance with this, we have appointed DataRep to act as our representative. Any queries requiring the input of our representative, should please be directed to them as follows: contacting us on our online webform at https://www.datarep.com/data-request, or mailing your inquiry to this address:

DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

PLEASE NOTE: when mailing inquiries, it is ESSENTIAL that you mark your letters for 'DataRep' and not 'Hankyu Hanshin REIT, Inc.', or your inquiry may not reach us. Please refer clearly to Hankyu Hanshin REIT, Inc. in your correspondence.

Revised on April 1, 2026