Privacy Policy
1. Basic Policy on Handling Personal Information
Mitsui Bussan & IDERA Partners Co., Ltd. (hereinafter the “Asset Manager”) shall comply with the Act on the Protection of Personal Information (Act No. 57 of 2003, including subsequent amendments, hereinafter the “Personal Information Protection Act”) and the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of 2013, including subsequent amendments, hereinafter the “My Number Act”) and other laws, regulations, and guidelines related to the protection of personal information when handling personal information (including personal identification numbers and specific personal information (hereinafter “specific personal information, etc.”). Unless otherwise specified in this Privacy Policy, the same shall apply hereinafter.)
The Asset Manager shall store and maintain acquired personal information in an accurate and up-to-date manner at all times, and shall endeavor to delete such personal information without delay when use is no longer necessary. In addition, in order to prevent unauthorized access, leakage, loss, damage, or alteration of personal information, the Asset Manager thoroughly educates our employees and takes necessary and appropriate security measures to ensure the safety of personal information.
If the Asset Manager receives any complaints regarding the handling of personal information, we endeavor to respond appropriately and promptly within a reasonable period of time. For inquiries regarding the measures taken by the Asset Manager to ensure the security of personal information in our possession, or regarding our handling of personal information, please contact the inquiry desk listed in Section 12 below.
2. Acquisition of Personal Information
The Asset Manager shall acquire personal information by lawful and fair means within the scope necessary for business purposes, and shall not acquire personal information by fraudulent or other unlawful means. In addition, except as required by law, the Asset Manager does not acquire sensitive personal information (as defined in the Personal Information Protection Law; the same shall apply hereinafter) without the consent of the individual concerned.
When acquiring personal information directly from the individual in writing, the Asset Manager clearly indicates the purpose of use to the individual in advance. However, the purpose of use may be omitted in cases permitted by law, such as the purpose of use is deemed to be clear based on the circumstances of the acquisition.
3. Purpose of Use of Personal Information
The Asset Manager uses the personal information (excluding specific personal information, etc.; the same applies throughout the “3. Purpose of use of personal information”) acquired for the purposes specified in “A.” below. The Asset Manager does not use personal information in any manner that may encourage or induce illegal or improper conduct. The Asset Manager handles specific personal information only to the extent necessary to achieve the purposes of use specified in “B.” below except in exceptional cases permitted by laws and regulations. The Asset Manager does not use personal information for purposes beyond the scope of the following purposes without obtaining the prior consent of the individual concerned except as permitted by laws and regulations. The Asset Manager does not use specific personal information acquired beyond the scope of the purpose of use, even with the consent of the individual except in cases permitted by the My Number Act.
A. Purpose of use of personal information
| (1) | To exercise the rights of unitholders and fulfill the obligations of MIRAI Corporation (hereinafter “MIRAI”), an investment corporation whose asset management the Asset Manager is entrusted with, in accordance with the Act on Investment Trusts and Investment Corporations and other relevant laws and regulations; |
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| (2) | To provide information about MIRAI’s business to unitholders; |
| (3) | To manage information of unitholders, such as generating data for MIRAI’s unitholder register; |
| (4) | For the issuance of investment corporation bonds and additional issuance of investment units by MIRAI; |
| (5) | To respond to inquiries or requests for materials from MIRAI; |
| (6) | For research, analysis, and consideration related to asset management of MIRAI; |
| (7) | For acquisition and sale of assets by MIRAI, and operations related to the leasing, management, and operation of real estate (including, but not limited to, identity verification, credit investigation, and investigation of rights and interests); |
| (8) | For other matters necessary for the appropriate and smooth execution of MIRAI’s business; |
| (9) | To provide personal information to third parties within the scope necessary for the purposes of use described in the preceding items; and |
| (10) | For other matters necessary for the proper and smooth execution of the asset management business of MIRAI by the Asset Manager. |
B. Purpose of use of specific personal information
| (1) | To carry out tax-related filing procedures for employees, etc., in accordance with the Income Tax Act and other relevant laws and regulations; |
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| (2) | To carry out reporting procedures related to withholding taxes, social insurance, and labor insurance for employees, etc.; |
| (3) | To carry out the preparation of tax returns, notifications, and applications related to employee property accumulation housing savings and property accumulation pension savings; |
| (4) | For the purpose of preparing payment records for remuneration, fees, etc.; |
| (5) | For the purpose of preparing payment records for dividends and distribution of surplus; |
| (6) | For the purpose of preparing payment records for real estate usage fees, etc.; |
| (7) | For the purpose of preparing payment records for the consideration paid for the acquisition of real estate, etc.; |
| (8) | For the purpose of preparing statutory documents related to business partners; and |
| (9) | For the purpose of performing related administrative tasks associated with the preceding items. |
4. Sources and Means of Acquisition of Personal Information
Examples of ways in which the Asset Manager acquires personal information are as follows:
| (1) | Unitholders and prospective investors of securities issued by MIRAI: The Asset Manager acquires information on unitholders such as their name, address, and number of investment units, by accessing the unitholders’ registry submitted by the transfer agent. The Asset Manager may acquire information on prospective investors of securities issued by MIRAI such as their name, address and phone number from an inquiry from brokerage firms that handle securities issued by MIRAI or from such individuals directly. The Asset Manager may otherwise acquire personal information on unitholders or creditors of MIRAI such as their name and address, in connection with the exercising of rights or performance of obligations by such unitholders or creditors; |
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| (2) | Sellers and purchasers of MIRAI’s investment assets or prospective sellers and purchasers thereof or other persons related to the sale and purchase thereof: If individuals, the Asset Manager may acquire personal information on such individuals such as their name and address stated on a seal registration certificate or certified copy of registry, etc. which the Asset Manager obtains as an identity verification document for an agreement on the sale and purchase of investment assets. The Asset Manager may also acquire personal information on an owner of a neighboring property such as their name and address, in order to confirm the boundary therewith; |
| (3) | Lessees of MIRAI’s investment assets or prospective lessees: If individuals, the Asset Manager acquires personal information on such individuals such as their name, address, phone number, employer and income, from real estate brokers whom such individuals ask to lease investment assets on their behalf or from property management companies in charge of managing properties. The Asset Manager may also acquire personal information similar to that stated above from guarantors. The Asset Manager acquires personal information on lessees of investment assets such as the property name, room number, name of lessees, amount paid and unpaid that comprise rent collection information from property management companies. The Asset Manager may otherwise acquire personal information on lessees or prospective lessee and other individuals related thereto, in order to conduct operations related to each of the foregoing; and |
| (4) | Other: In addition to cases stated in Subsection (1) to Subsection (3) above, the Asset Manager may acquire personal information such as names, addresses, and phone numbers, employers and titles, for the purpose of use stated in Section 3 above. The Asset Manager may also acquire personal information such as names, addresses, and phone numbers as contact information for individuals that make inquiries or file complaints, etc. |
5. Shared Use of Personal Information
Personal information held by the Asset Manager (excluding personal information related to specified personal information, etc. The same applies throughout the “5. Shared use of personal information.”) may be jointly used with Mitsui & Co. Asset Management Holdings Ltd. and IDERA Capital Management Ltd., which are our sponsors, to the extent necessary to achieve the purposes of use described in Section 3 above. The department responsible for managing personal information shared for joint use is the Accounting & Administrative Division of the Asset Manager.
6. Provision of Personal Information to Third Parties
The Asset Manager does not provide personal information (excluding personal information related to specified personal information, etc.; the same applies throughout the “6. Provision of personal data to third parties”) held by the Asset Manager to third parties except in the following cases.
The Asset Manager does not provide personal information to third parties located in foreign countries without the prior consent of the individual concerned, except in cases permitted by laws and regulations. When obtaining the consent of the individual, the Asset Manager shall provide information such as the name of the foreign country, the system for protecting personal information in that country, the measures taken by the third party to protect personal information, and other relevant information. If the Asset Manager is unable to identify the foreign country where the third party to whom the information is provided is located at the time of obtaining his or her consent, and if the Asset Manager is able to identify the foreign country at a later date, the Asset Manager provides additional information at his or her request. In addition, when providing personal information to a person who has established a system that complies with the standards specified in the Enforcement Rules for the Act on the Protection of Personal Information in order to continuously implement measures equivalent to those a business operator handling personal information is required to take under the Act on the Protection of Personal Information (hereinafter referred to as “appropriate measures”), the Asset Manager provides information on such measures at the request of the individual concerned.
The Asset Manager does not provide specific personal information to third parties without the consent of the individual concerned, except in cases specified by the My Number Act.
| (1) | where the Asset Manager obtains consent from the individual concerned; |
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| (2) | where provision is in accordance with laws and regulations; |
| (3) | where provision is necessary for the protection of human life, body, or property, and when it is difficult to obtain consent from the individual concerned; |
| (4) | where provision is necessary especially for the improvement of public health or the healthy development of children, and when it is difficult to obtain consent from the individual concerned; |
| (5) | where it is necessary to cooperate with any national government agencies, local government, or persons entrusted thereby with performing the functions prescribed by laws and regulations, and when obtaining consent from the individual concerned may interfere with performance of these functions; |
| (6) | where personal information is provided to a third party as part of the outsourcing of all or part of its handling to a contractor under appropriate supervision by the Asset Manager, within the scope necessary to achieve the intended purpose of use; |
| (7) | where provision is in connection with a business succession due to a merger, etc.; |
| (8) | where provision to a specific party is in the course of shared use of personal data as outlined in item 5 above; |
| (9) | where the individual has been notified in accordance with Article 27, Paragraph 2 of the Act on the Protection of Personal Information. |
7. Acquisition of Sensitive Information, etc.
Except in cases stipulated by the ‘Guidelines on the Protection of Personal Information in the Financial Sector’, the Asset Manager shall not collect, use, or provide to third parties any sensitive personal information or information concerning union membership, lineage, registered domicile, health and medical care, or sexual life (excluding those that fall under sensitive personal information), unless such information has been made public by the individual concerned, a national agency, a local government, an academic research institution, or other entities listed in the Act on the Protection of Personal Information or Enforcement Rules for the Act on the Protection of Personal Information, or is clearly identifiable from the individual's appearance by direct observation or photography.
8. Outsourcing and Supervision of Contractors
The Asset Manager may outsource the handling of personal data obtained to external parties within the scope necessary to achieve the intended purpose of use. When outsourcing all or part of the handling of personal data to a third party, the Asset Manager will exercise necessary and appropriate supervision over the third party to ensure the secure management of the entrusted personal data.
9. Reporting of Data Breaches, etc.
In the event of a data breach, loss, damage, or any other incident involving personal data handled by the Asset Manager that may significantly infringe on an individual’s rights and interests as defined by the Enforcement Rules for the Act on the Protection of Personal Information, the Asset Manager will report such an incident to the Personal Information Protection Commission as stipulated in the Enforcement Rules for the Act on the Protection of Personal Information. However, if the Asset Manager has been entrusted with all or part of the handling of the relevant personal data by another personal information handling business operator, and the operator is notified of the incident in accordance with the Enforcement Rules for the Act on the Protection of Personal Information, this shall not apply.
In the above case (except when the above-mentioned notification has been made), the Asset Manager will notify the individual concerned of the occurrence of such an incident in accordance with the provisions of the Enforcement Rules for the Act on the Protection of Personal Information. However, if it is difficult to notify the individual, and alternative measures necessary to protect the individual's rights and interests are taken, notification may be omitted.
10. Procedures for Disclosure of Retained Personal Data
When an individual, through submission of designated request form prescribed by the Asset Manager along with identification documents specified, requests disclosure of retained personal data, correction, addition, or deletion of its content; suspension of use or its erasure, cessation of its provision to third parties, disclosure of records of third-party provision, or provision of information in the event of transfer of personal data to a third party located in a foreign country as described in Section 6 above (hereinafter “Disclosure, etc.”), or requests notification of the purposes of use of retained personal data, the Asset Manager will respond appropriately after verifying the identity of the individual through designated procedures. Notification or disclosure, etc. of the purposes of use of retained personal data will be provided in writing or by other means agreed upon by the individual. For further details regarding the procedures, please contact the inquiry desk listed in Section 12 below. Please note that a prescribed fee may be applied for requests for notification or disclosure, etc. of purposes of use of retained personal data.
11. Continuous Improvement
The Asset Manager will review the contents of this policy as necessary and strive for the ongoing enhancement and improvement of its personal information management system.
12. Contact Information
For inquiries or complaints regarding the measures taken by the Asset Manager to ensure the secure management of personal data retained, as well as other matters related to the handling of personal information by the Asset Manager, please contact the following office.
| Address | 2-1, Nishi-Kanda 3-chome, Chiyoda-ku, Tokyo 101-0065, Japan |
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| Name | Mitsui Bussan & IDERA Partners Co., Ltd. |
| Telephone | +81-3-6632-5950 |
| Business Hours | 9:15 to 17:00 Japan standard time (excluding Saturdays, Sundays, national holidays and year-end through New Year holidays) |
For inquiries regarding the details listed in the unitholders’ registry or specific personal information related to unitholders, please contact the unitholders’ registry administrator below.
| Address | 8-4, Izumi 2-chome, Suginami-ku, Tokyo 168-0063, Japan |
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| Name | Mitsui Trust Bank, Limited, Securities Agency Division |
| Telephone | 0120-782-031 (toll-free within Japan) |
| Business Hours | 9:00 to 17:00 Japan standard time (excluding Saturdays, Sundays, national holidays and year-end through New Year holidays) |
In addition, the Asset Manager is a member of the Investment Trusts Association, Japan, which is an authorized personal information protection organization. The Association accepts consultations and complaints regarding the handling of personal information (excluding specific personal information, etc.) by member companies.
| Name | The Investment Trusts Association, Japan |
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| Telephone | +81-3-5614-8440 |
| Business Hours | 9:00 to 11:30 and 0:30 to 17:00 Japan standard time (excluding Saturdays, Sundays, national holidays) |
13. Name, Address and Representative of Personal Information Handling Business Operator
| Name | Mitsui Bussan & IDERA Partners Co., Ltd. |
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| Address | 2-1, Nishi-Kanda 3-chome, Chiyoda-ku, Tokyo 101-0065, Japan |
| Representative | Representative Director, President Michio Suganuma |
(Last updated: May 1, 2022)