Ichigo Personal Information Protection Policy

Ichigo Inc. and its 100% consolidated subsidiaries – Ichigo Investment Advisors Co., Ltd., Ichigo Estate Co., Ltd., Ichigo ECO Energy Co., Ltd., Ichigo Marche Co., Ltd., Miyako City, Co., Ltd., and Ichigo Owners Co., Ltd.– (collectively “Ichigo”), hereby establish this Policy Concerning The Protection Of Personal Information And National Identification Number (“Policy”) in furtherance of their commitment to complying with the Personal Information Protection Law, National Identification Number Law, and all other applicable laws and ordinances regarding the protection and handling of personal information in Japan.

  • Ichigo’s Commitment
    All Ichigo directors and part- and full-time employees, regardless of their employment status (“Ichigo Employees”), shall be made aware of the contents of this Policy. Ichigo shall establish and maintain this Policy through the implementation of an appropriate corporate governance and internal rule framework.
  • Acquisition and Use of Personal Information
    Ichigo establishes herewith that personal information shall be acquired and used only to the extent necessary to effect legitimate business purposes. However, Specific Personal Information as defined under Japanese law shall be acquired and used only to the extent prescribed in relevant laws and regulations.
  • Purpose of Use of Personal Information (Note 1)
    Ichigo shall indicate the purpose for its use of personal information through public disclosure or written notification. Ichigo shall use personal information only in accordance with such stated purpose and in no case shall the use of personal information exceed the scope of consent received from the relevant person. However, Specific Personal Information shall not be used for any purpose beyond those permitted by law.
  • Provision of Personal Information to Third Parties (Note 2) (Note 4)
    Ichigo shall not provide personal information to third parties without the consent of the relevant person unless required by applicable law. As for Specific Personal Information, Ichigo will not provide or disclose the information to third parties unless permitted by law.
  • Delegation of Handling of Personal Information
    Ichigo may delegate the handling of personal information to third parties that handle personal information in a compliant and appropriate manner. In such case, Ichigo shall supervise such delegated parties as necessary.
  • Sharing of Personal Information (Note 3) (Note 4)
    Ichigo may share and mutually use personal information within Ichigo companies in accordance with both applicable law and stated purpose of use. However, under no circumstance will Ichigo share Specific Personal Information within Ichigo companies.
  • Measures for Protection of Personal Information
    Ichigo shall take appropriate technical and organizational measures to secure personal information from unauthorized access, loss, destruction, manipulation, and/or disclosure to any third parties.
  • Internal Rules and Training Regarding the Protection of Personal Information
    Ichigo shall establish internal rules with respect to protection of personal information, and provide appropriate training to Ichigo Employees to ensure awareness and compliance.
  • Disclosure, Amendment, and Cessation of Use of Personal Information
    In the event the relevant person so requests, Ichigo shall immediately disclose, amend and/or cease the use of personal information in accordance with procedures established separately by Ichigo.
  • Continual Review of Internal Governance Structure
    Ichigo shall, in accordance with all relevant laws and ordinances, continually review and improve its internal governance structure for protecting Personal Information.
  • Inquiries Concerning Personal Information
    Please direct inquiries or concerns regarding the use of personal information to the following:
    • Ichigo Inc. President Takuma Hasegawa
      Compliance Department
      2-6-1 Marunouchi, Chiyoda-ku, Tokyo, 100-6920
      TEL: 03-4485-5515

      For inquiries regarding the Shareholder Registry, etc.:
      Mizuho Trust & Banking Co., Ltd.
      Custody Services Division
      2-8-4 Izumi Suginami-ku, Tokyo 168-8507
      TEL: 0120-288-324 (Japanese only)
    • Ichigo Investment Advisors Co., Ltd. President & Executive Officer Hiroshi Iwai
      Risk Management & Compliance Division
      2-6-1 Marunouchi, Chiyoda-ku, Tokyo, 100-6920
      TEL: 03-4485-5230

      For inquiries regarding the Shareholder Registry and other share-related operations of Ichigo Office REIT Investment Corporation (“Ichigo Office,” 8975),Ichigo Hotel REIT Investment Corporation (“Ichigo Hotel,” 3463), and Ichigo Green Infrastructure Investment Corporation (“Ichigo Green,” 9282) :
      Mizuho Trust & Banking Co., Ltd.
      Custody Services Division
      2-8-4 Izumi Suginami-ku, Tokyo 168-8507
      TEL: 0120-288-324 (Japanese only)

      Ichigo Investment Advisors is a member of the Investment Trust Association of Japan.
      Please direct any inquiries or complaints concerning the Policy of Ichigo Investment Advisors to:
      The Investment Trust Association of Japan
      Investment Advisory Desk
      TEL: 03-5614-8400 (Japanese only)
    • Ichigo Estate Co., Ltd. President & Representative Director Yasuhide Hosono
      Compliance Department
      2-6-1 Marunouchi, Chiyoda-ku, Tokyo, 100-6920
      TEL: 03-4485-5240
    • Ichigo ECO Energy Co., Ltd. President & Representative Director Eiichiro Gotoh
      Administration
      2-6-1 Marunouchi, Chiyoda-ku, Tokyo, 100-6920
      TEL: 03-4485-5260
    • Ichigo Marche Co., Ltd. President & Representative Director Kazunori Kurita
      Administration
      30 Matsudo Shinden, Matsudo Chiba, Chiba 270-2241
      TEL: 047-363-2222
    • Miyako City, Co., Ltd. Chairman, President & Representative Director Minoru Ishihara
      Compliance Department
      4-6-28 Oyodo, Miyazaki City
      Miyazaki, 880-0902
      TEL: 0985-51-1311
    • Ichigo Owners Co., Ltd. President & Representative Director Masahiko Koketsu
      Administration
      2-6-1 Marunouchi, Chiyoda-ku, Tokyo, 100-6920
      TEL: 03-4485-5250

This Policy is effective as of January 1, 2012, and has been revised as of December 1, 2022.

(Note 1)

1. Personal information acquired by Ichigo shall be used for the following purposes:

  • To solicit, sell and manage Ichigo’s real estate products, including quasi-partnership (tokumei kumiai) agreements for real estate funds, and to provide services related thereto;
  • To provide information regarding the solicitation, sale and management of real estate products for Ichigo and affiliated companies;
  • To assess the appropriateness of providing products and services to clients;
  • To verify the identity of the related person and any agents of the related person;
  • To report deposit balances and asset management results to clients;
  • To carry out business with clients and counterparties;
  • To carry out legal obligations and contract rights of Ichigo;
  • To use in research and data gathering and analysis in the course of Ichigo’s business;
  • To dispose of personal information in an appropriate manner in case of being delegated to do so by third parties;
  • To provide appropriate information to shareholders and investors and manage shares in the course of Ichigo’s investor relation services;
  • To report and exchange information with government authorities as necessary;
  • To contact job applicants and keep and manage employee records; and
  • To carry out transactions with clients and counterparties as appropriate.

2. In addition to the above, the following purposes shall apply to Ichigo Investment Advisors:

  • To exercise rights and execute duties with respect to entities managed by Ichigo Investment Advisors under the Investment Trust and Corporation Law, including Ichigo Office, Ichigo Hotel, and Ichigo Green;
  • To properly manage inquiries and visitors to Ichigo Office, Ichigo Hotel, and Ichigo Green;
  • To carry out business operations of Ichigo Office, Ichigo Hotel, and Ichigo Green in the normal course of business;
  • To engage in matters such as data gathering and analysis, sending notices, and supplying information as necessary to execute the businesses of Ichigo Office, Ichigo Hotel, and Ichigo Green;
  • For identification purposes for any applications, contracts, and other documents necessary in the normal course business of Ichigo Office, Ichigo Hotel, and Ichigo Green; and
  • To delegate the handling of, to share, and to provide personal information to third parties as necessary to carry out (1) to (5) above.

3. Notwithstanding the stipulations above, Specific Personal Information acquired by Ichigo shall be used only for the following purposes. Specific Personal Information involved in the following (1) to (6) refers to only those of Ichigo Employees and their families.

  • Operations related to the registration, application, and claiming of employment insurance
  • Operations related to the registration, application, and claiming of health insurance and welfare annuity insurance
  • Operations related to the registration for Category III of the National Pension Service
  • Operations related to the preparation of certificates of employment income (declaration of exemption for dependents, declaration of exemption for insurance premium and special exemption for spouses)
  • Operations related to the preparation of income tax withholding
  • Operations related to the preparation and submission of legal documents for stock options.
  • Operations related to Ichigo preparing payment records for the payment of compensation, fees, contractual fees, or reward to lawyers, certified public accountants, tax accountants, judicial scriveners, administrative scriveners, real estate appraisers, property researchers, licensed social insurance consultants, etc.
  • Operations related to the preparation and submission of payment records of dividends, dividend in excess of earnings, and interest regarding dividends paid by Ichigo to its shareholders
  • Operations related to the preparation and submission of payment records of rent paid by Ichigo to its lessors for the use of real estate
  • Operations related to the preparation and submission of payment records with respect to payments made by Ichigo to sellers of assets to Ichigo
  • Operations related to the preparation and submission of payment records of payment for real estate or loan mediation by Ichigo to its agent
  • Operations related to the above (1) to (11)

(Note 2)
Ichigo shall not provide any personal information to third parties without prior consent received from the relevant person except for the following (1) to (4).

  • In the event where disclosure is required by applicable law or ordinance;
  • In the event receiving timely consent is difficult and disclosure is necessary to protect life or property;
  • In the event receiving timely consent is difficult and disclosure is necessary to enhance public health or promote the development of children;
  • In the event necessary to cooperate with government or local authorities in their execution of official work where the acquisition of consent from the affected person may interfere with such official work;
  • In the event where third parties are research and educational institutions and disclosure is particularly necessary for research and educational purposes (including cases where reserch and educational purpuses comprise part of the objectives and excluding cases where personal rights and interests might be unjustifiably infringed).

2. Notwithstanding the above, in the event Ichigo provides personal information (excluding sensitive personal information or personal information that requires special attention, persornal information acquired through deceit and other fraudulent means, and personal information disclosed through opt-out actions via other entities pursuant to Artticle 7, Paragragh 2 of the Personal Information Protection Law) to third parties, Ichigo will cease to provide information that can be used to identify the affected person if so requested, and pursuant to the rules of the Personal Information Protection Commission will either pre-notify the affected person or make readily accessible on its website the following items. Ichigo shall also notify the Personal Information Protection Commission of any such disclosure to third parties.

  • Company name, address, and name of the representative of the company
  • Purpose of use includes disclosure to third parties
  • Personal information to be disclosed to third parties
    Name, address, and property information of persons engaging in real estate or debt transactions
  • Methods of acquiring personal information to be disclised to third parties
  • Methods of disclosure to third parties
    Written materials, mail correspondence, telephone, FAX, electromagnetic mediums, or advertising channels
  • Disclosure to third parties can be ceased upon request
  • Method for receiving requests
  • Other rules stipulated in the Personal Information Protection Commission necessary to protect personal rights and interests

3. Ichigo shall immediately notify the relevant person of any changes of stipulations in item (1) in Article 3 or termination of disclosure to third parties. Ichigo shall pre-notify the relevant person of any changes in stipulations in items (3) (4) (5) (7) or (8) or make the content of changes readily accessible, and will also notify the Personal Information Protection Commission of such changes.

4. Immediately upon the Personal Information Protection Committee officially announcing information with respect to notifications made pursuant to Articles 2 and 3, Ichigo shall disclose via its website or other appropriate methods the content of each items as per the following:

  • If notification is made pursuant to Article 2: Each item of Article 2
  • If notification is made pursuant to Article 3: All amended items of Article 3
  • If notification is made pursuant to Article 3 regarding the termination of disclosure of personal information

5. Where personal information is provided under the following cases, the recipient will not be deemed a third party with respect to each article above:

  • In the event Ichigo delegates the handling of all or part of personal information within the scope of its purpose of use
  • In the event personal information is provided as a result of merger, business succession, sale of an Ichigo owned/ managed asset to a third party, etc.
  • In the event personal information is provided pursuant to Note 3 below and the following items have either been pre-notified to the relevant person or made readily accessible: the fact that personal information would be shared, the scope of users, the items of personal information to be shared, purpose of use, the name and address of the person responsible for managing relevant personal information, and the name of the representative of the organization, in case of a corporate entity.

(Note 3)
Ichigo may share and mutually use personal information within Ichigo companies in accordance with both applicable law and stated purpose of use.

  • Information Sharing Entities
    All Ichigo companies (including Ichigo Office, Ichigo Hotel, and Ichigo Green)
  • Subject Information
    Names, addresses, building information, etc.
  • Purpose of Use
    As specified in Note 1
  • Manager Responsible for Supervision of Personal Information
    Compliance Officer
    Name of Company: Ichigo
    Name of President: Takuma Hasegawa
    Address of Company: 2-6-1 Marunouchi, Chiyoda-ku, Tokyo, Japan

2. Ichigo and its subsidiaries shall pre-notify the relevant person of all stipulations above or make the stipulations readily accessible. Changes to the Purpose of Use or the Manager Responsible for Supervision of Personal Information shall be pre-notified or made readily accessible. Changes to the name of the Manager Responsible for Supervision of Personal Information, Name of President, or the Address of the Company shall be notified without delay or made readily accessible .

(Note 4) Notwithstanding Note 2 and Note 3, Ichigo will not provide Specific Personal Information to third parties unless required by law.

(Note 5)
Ichigo’s measures for the protection of personal data are as follows:

  • Ensuring Accuracy of Personal Information
    Ichigo shall maintain accurate and up-to-date personal information in accordance with the purpose of use.
  • Establishment of Basic Policies
    Ichigo’s Personal Information Protection Policy is established to ensure the proper handling of personal data via compliance with relevant laws, regulations, and guidelines, and the setting of measures for secure management of personal data and handling of inquiries and concerns.
  • Rules for Handling of Personal Data
    Ichigo shall establish rules with respect to handling procedures and the duties and responsibilities of Manager Responsible for Supervision of Personal Information, persons managing personal information, and users of personal data, that cover all stages including the acquisition, use, storage, provision, and deletion of personal data.
  • Organizational Measures for Secure Management
    a) Ichigo shall establish an organizational structure to allow for the secure management of personal data including assigning Manager Responsible for Supervision of Personal Information and persons managing personal information, and determining the scope of users of personal data along with their roles and responsibilities. Ichigo shall also establish reporting procedures for situations in which either a breach or a suspected breach of the Personal Information Protection Law, personal information protection rules, or rules for the handling of personal information occurs.
    b) Ichigo shall periodically inspect its handling of personal data, and internal auditors shall conduct audits.
  • Employee Measures for Secure Management
    Ichigo shall stipulate measures for the handling of personal information in its compliance manual and enforce strict adherence to this by Ichigo Employees handling personal data.
  • Physical Measures for Secure Management
    a) Ichigo shall establish roles and responsibilities with respect to users carrying personal data outside of designated areas, and ensure the awareness of Ichigo Employees.
    b) Ichigo shall minimize the number of people carrying personal data outside of designated areas and shall further minimize the scope of personal data that can be carried outside of designated areas.
    c) Any act of carrying personal data outside of designated areas will be subject to Ichigo’s information security management rules.
  • Technical Measures for Secure Management
    When personal data is stored and managed in IT systems, access control for the acquisition, use, storage, provision, and deletion of personal data as well prevention of unauthorized access will be conducted in accordance with Ichigo’s information security management rules and basic information system rules.
  • Responsibilities of Ichigo Employees Regarding Non-Disclosure of Personal Information
    Ichigo Employees involved in the acquisition, use, or provision to a third party or delegated party of personal information must comply with all rules and regulations as well as rules and instructions set by Ichigo’s Board of Directors and the manager responsible for the supervision of personal information, and shall use utmost care in ensuring the secure management of personal information.
  • Measures for Delegated Handling of Personal Information
    In the event that Ichigo delegates the handling of personal information to a third party, Ichigo shall select a party with sufficient personal information protection standards and include in the delegation agreement the right for Ichigo to supervise, inspect, and receive reports from the delegated party, the requirement that the delegated party comply with instructions from Ichigo’s manager responsible for the supervision of personal information, the requirement that the delegated party keep any personal information confidential, a prohibition on the delegated party providing personal information to any further third party, and a definition of the scope of responsibilities in the event of a violation. During the agreement period, Ichigo will periodically and as necessary check the delegated party’s compliance with the measures stipulated in the agreement, and make any revisions as needed. Paper copies and electronic records of the agreement shall be kept while the delegated party remains in possession of personal information.