United Urban Investment Corporation

Securities Code
8960

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Privacy Policy

United Urban Investment Corporation (“United Urban”) recognizes the importance of personal information protection and its proper management as key issues in fulfilling corporate social responsibility. To this end, United Urban has established the following privacy policy.
With regard to protection of the Personal Numbers and the Specific Personal Information defined by the ”Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure,” United Urban’s policy is stipulated in "Guidelines on Protection of the Personal Numbers and the Specific Personal Information."

1. Basic Policy

United Urban shall comply with the Act on the Protection of Personal Information and other laws and regulations and guidelines, etc. relating thereto, and endeavors to properly handle personal information.

2. Acquisition and Use of Personal Information

(1) United Urban shall acquire personal information only by appropriate methods, and shall disclose, notify or clarify the purpose of use for acquiring personal information in compliance with the laws and regulations. In addition, United Urban shall not use personal information in a manner that may encourage or induce illegal or improper acts.
(2) Unless provided in the laws and regulations, United Urban shall not acquire “special care-required personal information” (meaning personal information comprising a principal’s race, creed, social status, medical history, criminal record, fact of having suffered damage by a crime, or other descriptions etc. prescribed by Article 2 of the Cabinet Order to Enforce the Act on the Protection of Personal Information (Cabinet Order No. 507, 2003) as those of which the handling requires special care so as not to cause unfair discrimination, prejudice or other disadvantages to the principal) unless the consent of the relevant principal is obtained.
(3) Unless provided in the laws and regulations, United Urban shall handle personal information to the extent necessary to fulfill its purpose of use unless the consent of the relevant principal is obtained.
(4) United Urban shall endeavor to properly and promptly process any and all complaints as to the personal information.

3. Purpose for Using Personal Information

United Urban shall use the acquired personal information for the following purposes:

(1) Personal Information related to the unitholders
(i) To ensure the exercise of the rights of its unitholders and fulfill its obligations pursuant to the Act on Investment Trusts and Investment Corporations of Japan (the “Investment Trust Act”), the Financial Instruments and Exchange Act (the “FIEA”) and other related laws and regulations.
(ii) To notify its unitholders of information, etc. regarding its business.
(iii) To prepare and submit reports and other documents under the Investment Trust Act, the FIEA, other related laws and regulations, and the rules of the Financial Instruments Exchange, and to prepare data for its unitholders.
(iv) To respond to inquiries and requests for MRA or United Urban for provision of information material.
(v) To facilitate borrowings, issuance of investment corporate bonds and additional issuance of investment units.
(vi) To facilitate the smooth and efficient operation of United Urban in any way in addition to the above.
(vii) To provide personal information to third parties to the extent necessary for fulfillment of the above.
(2) Personal Information related to asset management
(i) To facilitate borrowings, issuance of investment corporate bonds and additional issuance of investment units by United Urban.
(ii) To acquire investment assets, scrutinize and review such acquisition, and implement services related to disposition of investment assets by United Urban.
(iii) To facilitate leasing activity on the assets by United Urban.
(iv) To facilitate the smooth and efficient operation of United Urban in any way in addition to the above.
(v) To provide to personal information to third parties to the extent necessary for fulfillment of the above.

4. Measures for Security and Control of Personal Data

United Urban makes every effort to properly and carefully manage personal data retained by United Urban, and takes all adequate measures necessary to prevent unauthorized access, loss, leakage or tampering etc. of personal data (in addition, in the event that United Urban handles personal data in a foreign country, United Urban takes such measures for security and control based on understanding of the systems for the protection of personal information in such foreign country). In addition, since United Urban has entrusted its asset management services, etc. in accordance with the Investment Trust Act, with respect to (2) through (6) below, measures for security and control have been substantially implemented by the asset management company of United Urban. For specific details of the measures for security and control on personal data of United Urban, please contact the following address or number mentioned in 11. below.

(1) Formulation of Basic Policy
Please refer to 1. Basic Policy above.
(2) Guidelines for the Handling of Personal Data
United Urban has formed the “Rules on Personal Information Management” as an internal rule in order to realize security of the appropriate handling of personal data and the appropriate security of information assets and information security and stipulations and regulations are in place to ensure the handling of personal data regarding responsible person and method of handling at each stage of response, etc. for cases of acquisition, use, storage, transfer, disposal and leakage, etc. of personal information.
(3) Organization Safety Management Measures
United Urban has established an “Personal Information Management Manager” as the person responsible for the handling of personal data and has appointed the executive officer of United Urban as the “Personal Information Management Manager.” “Personal Information Management Manager” is responsible for establishing and maintaining United Urban’s personal information management system and managing the handling of information assets, etc. Moreover, United Urban establishes a procedure of report, etc. in the case where a leakage, etc. of personal data occurred or likely to occur. In addition, United Urban has a system in place for periodic self-inspections of the status of the handling of personal data, as well as internal audits and verifications.
(4) Physical Security Management Measures
United Urban strictly controls the areas where officers of United Urban and officers and employees of the asset management company of United Urban can enter and exit, and takes measures to prevent theft or loss of equipment, electronic media, and documents containing personal data.
(5) Technical Safety Management Measures
United Urban appropriately manages the scope of personal information databases, etc. handled by officers of United Urban and officers and employees of the asset management company of United Urban by adopting systems to protect against unauthorized external and internal access and unauthorized software to information systems that handle personal data, as well as by implementing access control.
(6) Human Security Management Measures
United Urban conducts training and other educational activities as necessary to familiarize officers of United Urban and officers and employees of the asset management company of United Urban with matters to be noted concerning the handling of personal data. In addition, matters concerning confidentiality and secrecy of personal data are stipulated in the “Rules on Information Management” and the “Work Rules” of the asset management company of United Urban.

5. Entrustment of the Handling of Personal Information

United Urban may entrust the handling of personal data to external parties. In this event, United Urban shall select a party that have taken sufficient measures to protect personal data and provide necessary and appropriate supervision of such entrusted party.
Entrusted party mentioned above may include entities located outside Japan who can satisfy certain requirements under the “Act on the Protection of Personal Information” and other laws, regulations and guidelines, etc.

6. Provision of Personal Data to Third Parties

United Urban shall not disclose or provide personal data to third parties except in the following cases.

(i) The consent of the principal has been obtained;
(ii) The applicable laws and regulations require disclosure;
(iii) It is necessary to protect life, health or property of a person and it is difficult to obtain the relevant principal’s consent;
(iv) It is particularly necessary in order to enhance public health or to promote the sound nurturing of children and it is difficult to obtain the relevant principal’s consent;
(v) It is necessary to cooperate with the national or local government, or service providers contracted by them, in order to fulfill matters prescribed by the laws and regulations and obtaining the consent of the relevant principal may disrupt the execution of such affairs;
(vi) Personal data is provided to an academic study institution, etc., and in the case where such academic study institution, etc. needs to handle such personal data for academic study purposes (including the case where part of the purpose of handling such personal data is for academic study purposes, but excluding cases where there is a risk of unjustified infringement on the rights and interests of individuals);
(vii) United Urban provides personal data to an entrusted party under appropriate supervision by United Urban within the scope necessary to achieve the purpose of use; and
(viii) It is permitted under the “Act on the Protection of Personal Information” and other laws, regulations and guidelines, etc.

7. Acquisition of Sensitive Information, etc.

Unless provided in the Guidelines for Protection of Personal Information in the Finance Sector, in the finance sector, United Urban is not to acquire, use or provide to a third party any personal information requiring special care and information on individuals’ membership in a labor union, family origin, registered domicile, healthcare, and sex life (among these, excluding the matters falling under the category of the personal information requiring special care) (excluding any information made public by the person in question themselves or by a national government organ, local public entity, academic study institution, etc. or any of those set forth in the Act on the Protection of Personal Information or the Enforcement Rules for the Act on the Protection of Personal Information, and seemingly-clear information acquired by visual observation, filming or photographing of the person in question).

8. Procedures for the Disclosure, etc. of Retained Personal Data

In case of requests for disclosure, alteration, addition, deletion, suspension or termination of use or elimination, termination of provision to a third party or disclosure of third party provision records (the “Disclosure, etc.”) or requests for notice of purpose of use of the retained personal data of United Urban, please contact the following address or number mentioned in 11. below. United Urban shall provide details of prescribed procedures for the Disclosure, etc. or notice of purpose of use of personal information. United Urban shall accept such requests with applications in prescribed form, and shall ask for submission of documents to prove the identity or evidencing authority of the proxy. In addition, there is the prescribed fee for the disclosure of the retained personal data, disclosure of the third party provision record or the notice of purpose of use. (There are no fees for requests for alteration, addition, deletion, suspension or termination of provision to a third party of the retained personal data.)

9. Report on Leakage, etc.

In the event of leakage, loss, or damage of personal data handled by United Urban, or any other situation related to the security of personal data that is specified by the Enforcement Regulations of the Act on the Protection of Personal Information as being highly likely to harm the rights and interests of individuals, United Urban shall, as specified by the Enforcement Rules for the Act on the Protection of Personal Information, report to the supervisory authorities, etc. to the effect that the situation has occurred. In such cases, United Urban shall notify to the relevant principal of the occurrence of such a situation in accordance with the Enforcement Regulations of the Act on the Protection of Personal Information. This, however, shall not apply in cases where it is difficult to notify the relevant principal and when necessary alternative action is taken to protect the relevant principal’s rights and interests.

10. Continuous Improvement

United Urban shall review its privacy policy continuously and shall make every effort to improve measures for the protection of personal information.

11. Inquiries Relating to Personal Information, etc.

For specific details of measures taken by United Urban for the security management of personal data and other inquiries regarding United Urban’s handling of personal information, requests for the Disclosure, etc. of the retained personal data, requests for the notice of purpose of use and requests for complaints, please contact the below address or number:

Name Marubeni REIT Advisors Co., Ltd. (Attn. General Affairs Dept.)
Address 18F Shiroyama Trust Tower, 4-3-1 Toranomon, Minato-ku, Tokyo 105-6018
Tel +81-3-5402-3189
(Office hours: 9:00 a.m. to 5:00 p.m., Monday to Friday, excluding holidays (including year end and new-year holidays) designated by the company)

In case of inquiries regarding contents of the unitholders’ registration, please contact the below mentioned United Urban’s Transfer Agent:

Name Sumitomo Mitsui Trust Bank, Limited (Attn. Stock Transfer Agency Department)
Address 2-8-4 Izumi, Suginami-ku, Tokyo 168-0063
Tel 0120-782-031(toll-free within Japan)
(Office hours: 9:00 a.m. to 5:00 p.m., Monday to Friday, excluding holidays designated by the company)

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

Name United Urban Investment Corporation
Address 18F Shiroyama Trust Tower, 4-3-1 Toranomon, Minato-ku, Tokyo 105-6018
Name of Representative Kenmin Asatani

December 2023

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