Privacy Policy

Privacy Policy

Tokyu Land Capital Management Inc. (18th Floor, SHIBUYA SOLASTA Building, 21-1 Dogenzaka 1-chome, Shibuya-ku, Tokyo, Japan; Tsuyoshi Tsuneyoshi, President & CEO; hereinafter referred to as "TLCM") recognizes the importance of handling personal information of our clients and other persons carefully and promises to provide better products and services for them by carrying out the following measures to dutifully protect such information. TLCM will separately draft and comply with a basic policy on the proper handling of individual numbers and specific personal information defined in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.

1. (Execution Policy)
TLCM recognizes that the proper protection and use of personal information is an important social responsibility and in the due course of carrying out its various business activities, promises to comply with the Act on the Protection of Personal Information (hereinafter referred to as "the Privacy Protection Act") and other relevant laws, with guidelines and other regulations formulated by competent government agencies, and with this Privacy Policy.
1. (Company-wide System)
With regard to privacy protection and the system of handling personal information, TLCM will not only set down company-wide regulations and necessary rules for each business activity, but also assign a supervisor in each department, etc. and construct a compliance system for the protection of privacy.
2. (Proper Acquisition)
TLCM will acquire personal information from any of our clients and other persons by proper and legal means. After clearly stating, communicating or publishing the purposes for use, TLCM will acquire it within the scope necessary to fulfillment of the said purposes. TLCM will not acquire special care-required personal information (as defined in the Privacy Protection Act; hereinafter the same shall apply) without obtaining prior consent from the client or other person except in the cases stipulated by laws.
3. (Specification and publication of purposes of use)
TLCM will specify the purposes of use of personal information of clients and other persons it has acquired as detailed as possible and publish it. In the case of acquiring personal information stated in contract documents or other written documents directly from clients and other persons, not via any third party, TLCM will clearly state the purposes of use in advance to them. For the purposes of use, refer to [Purposes of use of personal information].
4. (Use within scope of purposes of use)
TLCM will use personal information solely within the scope necessary to fulfillment of the purposes of use and will not use it in excess of the scope necessary to fulfillment of the purposes of use except in the case where prior consent is obtained from the client or other person or in cases stipulated by laws.
5. (Joint use)
TLCM may jointly use the personal information it has obtained from clients and other persons with other companies in the Tokyu Fudosan Holdings Group and others as set out in [Joint use of personal data] below. Any client or other person wishing for suspension of use is asked to contact the address specified in [Contacts for applications and inquiries on personal information] below.
6. (Restrictions on disclosure to third parties)
Except in the case where prior consent is obtained from the client or other person and in cases stipulated by laws, TLCM will not provide or disclose their personal information to any third party.
7. (Notice of purposes of use, disclosure, correction and other modification of possessed personal data and suspension of use and other treatment thereof in accordance with the Privacy Protection Act)
Any client or other person wishing to take procedures for requesting notification of purpose of use, disclosure, correction or other modification, suspension of use or other treatment of their personal information possessed by TLCM (hereinafter "request for disclosure and other treatment") is asked to follow [Procedures for request for disclosure and other treatment of possessed personal data] set out below.
8. (Safety Management Measures)
TLCM will endeavor to keep personal information of clients and other persons accurate and up-to-date, and will implement necessary and appropriate security management measures for protecting the information from unauthorized access, falsification, leakage, loss and damage. TLCM will put personal information of clients and other persons under strict management and delete it as soon as it becomes unnecessary to use. Major security management measures currently implemented by TLCM are as follows.
■Organizational security management measures including appointment of general administrators of personal information and establishment of internal rules
■Physical security management measures including gate control and treatment area management
■Technical security management measures including access control and restrictions on equipment that can be brought into specific areas
9. (Staff Education)
TLCM will give education and training on protection of personal information to its officers, employees and other personnel to make it fully known across the company. TLCM will implement necessary and appropriate supervision against its officers, employees and other personnel to ensure security management for clients and other persons.
10. (Supervision of contractors)
TLCM will outsource all or part of the treatment of personal information within the scope of the purposes of use. In this case, TLCM will select a contractor that it expects to treat personal information properly, formulate proper provisions for security management, non-disclosure and subcontracting conditions and other treatment of personal information in the outsourcing contract and implement necessary and appropriate supervision against it.
11. (Constant reexaminations of company-wide system)
With regard to the regulations and organizational structure related to the handling of personal information, TLCM will constantly reexamine and revise them to ensure that effective and reasonable operations are continuously carried out.
12. (Exemption)
Links to external homepages are provided on our homepage, but TLCM bears no responsibility for any contents related to the protection of privacy, etc. found in these homepages.

Purposes for the Use of Personal Information

1. TLCM will use personal information that it has acquired for the purposes of operating businesses specified in (i) below and performing operations specified in (ii) below (hereinafter referred to as "the purposes of use").
  • (i) Business Description

  • (1)

    Transactions, exchanges or renting of real estate or acting as an agent or broker for transactions, exchanges or renting of real estate

  • (2)

    Owning, management, operation and disposal of real estate

  • (3)

    Owning, management, operation and disposal of trust beneficiary interests

  • (4)

    Fund arrangement that invests mainly in real estate, trust beneficiary interest in real estate and renewable energy power generation projects

  • (5)

    Investment advisory, management and consultancy services related to funds invested mainly in real estate, trust beneficiary interests in real estate and renewable energy power generation projects

  • (6)

    Consultancy and other services related to real estate securitization

  • (7)

    Investment advisory, management and consultancy services related to investment in and financing for funds invested mainly in real estate, trust beneficiary interests in real estate and renewable energy power generation projects

  • (8)

    Consultancy and other services related to receivables securitization

  • (9)

    Trust beneficiary interests sales

  • (10)

    Investment trust settlor services

  • (11)

    Asset management for investment corporations

  • (12)

    Specified joint real estate venture business

  • (13)

    Transactions of securities

  • (14)

    Acting as a broker or agent for transactions of securities

  • (15)

    Owning, management, operation and disposal of securities

  • (16)

    Investment advisory services

  • (17)

    Services under discretionary investment contract

  • (18)

    Financial instruments services

  • (19)

    Any and all services incidental to or connected with each of the foregoing items

  • (ii) Main Business

  • (1)

    Receiving of applications for inquiries on products and services

  • (2)

    Offering of different proposals on products and services (including those by phone, electronic mail and other means)

  • (3)

    Verifying identity and eligibility for use of products and services in accordance with the Act on Prevention of Transfer of Criminal Proceeds and other laws

  • (4)

    Carrying out management for continuous transactions, including due date control for transactions concerned with investment management services, investment advisory and agency services, other services that TLCM may engage in as well as services incidental to them

  • (5)

    Making applications for transactions in association with investment management services, investment advisory and agency services, other services that TLCM may engage in as well as services incidental to them and judgments on continuous use of these services

  • (6)

    Making judgments on appropriateness of offering products and services, including judgments in the light of the principle of suitability and suchlike

  • (7)

    Offering personal information to third parties within the scope necessary to proper implementation of investment management services, investment advisory and agency services, other services that TLCM may engage in as well as services incidental to them

  • (8)

    Carrying out commissioned work appropriately, when commissioned by another company or service provider, etc., to process all or part of its personal information

  • (9)

    Exercising rights and fulfill obligations pursuant to laws and contractual agreements with clients and other persons

  • (10)

    Conducting research and development of products and services through market research, data analyses and questionnaires

  • (11)

    Implementing identification and control of various risks that are necessary for management of TLCM and group companies and implementing transactions and contracts in an appropriate and orderly manner in TLCM's operations

2.TLCM may use personal information that it has properly acquired from the following media open to the public for the purposes of use specified in 1. above.
  • (1) Real estate registers
  • (2) Cadastral maps
  • (3) Business registers
  • (4) Credit Bureaus
  • (5) Other appropriately and legally disclosed personal information

Joint use of personal data

TLCM may jointly use personal data including personal information acquired from clients and other persons as set out below.

1. Personal data items
Address, name, postal code, telephone number, fax number, e-mail address, and other information of clients and other persons
2. Scope of joint users
Companies in the Tokyu Fudosan Holdings Group and others
3. Purpose of use
Identical with those specified in [Purposes for the Use of Personal Information] set out above
4. Name of party responsible for managing personal data
Tokyu Land Corporation is responsible for managing personal data with respect to this joint use. For inquiries on the joint use of personal data, contact the address specified in [Contacts for applications and inquiries on personal information].

Procedures for request for disclosure and other handling of personal data held

1.If you wish to file a request for disclosure and other handling of personal data held, please contact TLCM's address stated in [Contacts for applications and inquiries on personal information] below by electronic mail. Enter the phrase of [Request for disclosure and other treatment] alone in the subject field of the electronic mail. In response, TLCM will send a form for requesting disclosure and other handling of personal data held (hereinafter referred to as "request form"). Complete the form and submit it. For the purpose of sending the request form, please enter the name of the person requesting disclosure and whether they or their agent will file the request in the body of the electronic mail. If you want the request form sent by postal service, additionally enter your postal address.
2. Complete the request form and file the request. In this event, additionally submit the documents specified below for the purpose of verifying the identity of the requesting person and their information.
  • (1) When you file a request in person

  • ・ An original of your seal registration certificate (with the current address and submitted within three months of the date of issue)

  • ・ A photocopy of your driving license or your health insurance certificate

  • (2) When your agent files a request

  • ・ Documents for verifying your identity specified in (1) above

  • ・ An original of the agent's seal registration certificate (with the current address and submitted within three months from the date of issue)

  • ・ A photocopy of the agent's driving license or health insurance certificate

  • ・ When a statutory agent files a request, an original of the document certifying their authority of statutory representation (i.e. certificate of all the matters in a family register)

  • ・ In the case of mandate, a power of attorney with your and your agent's registered seal impressions

3. Response method
TLCM will check and study the request for disclosure and other handling filed and respond to you on a later date. If the request is filed by an agent, TLCM will respond to the agent only when it verifies at its discretion that your rights and interests will not be infringed. TLCM will in principle respond by electronic mail. It may respond in writing at its discretion. TLCM may not be able to fulfill your request for disclosure and other handling if fulfillment of the request could damage your or any third party's life, health, property or other rights or interests, where it could severely hamper proper implementation of its business, or where it would constitute a violation of any other law. In this case, TLCM will give you a notice together with the reasons.
4. Fees
You will incur a fee of 1,100 yen, inclusive of consumption tax, for each disclosure or other handling requested. Transfer the fee to the bank account designated by TLCM. The bank transfer fee will be at the expense of the requesting person. Please note that TLCM will check and study the request for disclosure and other handling after confirming that the bank transfer has been received.

Contacts for applications and inquiries on personal information

1. To apply for procedures for requesting disclosure and other handling of personal data held, and for any other inquiry on personal information or any complaint about treatment of personal information, please contact the following.
Personal Information Enquiries,
Corporate Planning & Administration Department,
Tokyu Land Capital Management Inc.
E-mail: madoguchi@tokyu-tlcm.co.jp
2.TLCM is a member of the accredited personal information protection organization specified below. This organization receives complaints and inquiries on handling of personal information by any of its members.
Helpdesk (personal information),
Administration Office,
Japan Investment Advisors Association
Telephone number: 03-3663-0505
Opening Hours: 9:00 a.m. to 5:00 p.m. on Mondays through Fridays (excluding national holidays)
Tokyu Land Capital Management Inc.
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