NOMURA REAL ESTATE MASTER FUND, INC.

TSE code :3462

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Privacy Policy

Recognizing the extreme importance of honoring individual privacy, Nomura Real Estate Master Fund, Inc. (hereinafter referred to as the “Fund”) has established and closely adheres to a Privacy Policy that ensures strict compliance with the Act Concerning the Protection of Personal Information (Act No.57, 2003), other related laws and regulations, and guidelines provided by competent government agencies.

1. Basic Personal Information Protection Policy

Based on respect for individual privacy, the protection of personal information shall be positioned as a priority. In line with this, the following basic framework has been established to ensure the proper handling of personal information.

(1) The Fund shall not acquire personal information by deception or other wrongful means. When acquiring personal information from a third party, the Fund shall not infringe the rights of the individuals whose personal information is received.
(2) The Fund shall not handle personal information beyond the scope necessary for the achievement of the purposes of utilization specified in advance without obtaining the prior consent of the relevant individual or individuals, except for cases in which the handling of personal information is based on laws and regulations.
(3) The Fund shall not provide personal data to any third party without obtaining the prior consent of the relevant individual or individuals, except for cases in which the provision of personal data is based on laws and regulations or stipulated by 4 below, “Provision and Disclosure of Personal Data to a Third Party.”
(4) The Fund shall endeavor to maintain personal data in an accurate and current state within the scope necessary for the achievement of the purposes of utilization.
(5) The Fund shall take necessary and proper measures to prevent leak, loss, or damage, and other security controls for the protection of personal data.
(6) The Fund shall exercise necessary and appropriate supervision over employees to ensure the security of personal data.

2. Source and Collection of Personal Information

The Fund shall acquire personal information within the scope necessary for the achievement of the purposes of utilization by legal and fair means through, for example, the following sources:

(1) Contracts or other documents in which personal information is provided directly by individuals; or
(2) Third parties including those who have been entrusted with business affairs that involve the appropriate transfer of personal information.

(For example, a lease contract entered into by a person leasing property owned by the Fund)

3. Use of Personal Information

The Fund was established to invest in and manage real estate and other properties, and real estate-backed securities in accordance with the Act on Investment Trusts and Investment Corporations, and uses personal information to perform said business in an appropriate and efficient manner. However, the Fund shall not use personal information beyond the scope necessary for the achievement of the purposes of utilization described below, except for cases in which the utilization of personal information is based on laws and regulations.

(1) To facilitate the exercise of investor rights and to fulfill the Fund’s obligations to investors in accordance with the provisions of the Financial Instruments and Exchange Act, Act on Investment Trusts and Investment Corporations, Companies Act and other related laws and regulations;
(2) To convey information regarding the Fund’s business and to provide a wide range of other benefits to investors;
(3) To implement measures to facilitate the relationship between the Fund and investors or individuals considering the purchase of securities that the Fund issues;
(4) To manage information on investors, analyze their attributes, and disclose such data, utilizing the Investors’ Registry and other documents, which are created in accordance with the provisions of the Financial Instruments and Exchange Act, Act on Investment Trusts and Investment Corporations, Companies Act and other related laws and regulations;
(5) To ascertain the credit standing of lessees or individuals considering the lease of the properties that the Fund owns or considers the acquisition of;
(6) To investigate and consider the acquisition, sale, maintenance and management, leasing, etc. of the assets under management of the Fund (including fund procurement), and to fulfill the obligations thereof;
(7) To respond to inquiries or requests for material from the individuals considering purchase of securities that the Fund issues;
(8) To issue securities by the Fund;
(9) To borrow funds for the Fund;
(10) To perform account settlement and other business regarding accounting and tax affairs;
(11) To check customer information regarding transactions in accordance with the Act on Prevention of Transfer of Criminal Proceeds;
(12) To conduct market trend analyses, customer satisfaction surveys, or surveys on product development;
(13) To fulfill the obligations and exercise the rights of the Fund, and to respond to the matters thereof;
(14) To provide to third parties within the scope necessary for the adequate execution of its business; and
(15) To perform business incidental or related to each item described above.

4. Provision or Disclosure of Personal Data to Third Parties

(1) The Fund shall not, except in the cases describe hereunder and in (2) below, provide or disclose personal data to a third party:
  1. Cases in which the Fund has obtained prior consent from the relevant individual or individuals;
  2. Cases in which personal data has been processed into statistical data through which specific individuals cannot be identified;
  3. Cases in which the provision or disclosure of personal data is required by laws and regulations;
  4. Cases in which the provision or disclosure of personal data is necessary for the protection of the life, limb, or property of an individual or individuals and in which it is difficult to obtain prior consent from the relevant individual or individuals;
  5. Cases in which the provision or disclosure of personal data is required for the improvement of public health or the promotion of the sound growth of children and in which it is difficult to obtain prior consent from the relevant individual or individuals; or
  6. Cases in which the provision or disclosure of personal data is required for cooperation with a state organ, a local government, or an individual or business operator entrusted thereby in executing the affairs prescribed by laws and regulations and in which obtaining prior consent of the relevant individual or individuals is likely to impede the execution of said affairs.
(2) The Fund may provide personal data to third parties within the scope necessary for the achievement of the purposes of utilization. The items of personal data, third parties and methods of transfer are as follows:
  1. Third parties to which personal data is or may be provided
    1. The Fund’s asset management companies and asset custody companies
    2. Administrative Agents entrusted by the Fund to conduct business affairs of the Fund (including the Administrator of Investors’ Registry, etc.)
    3. Counterparties to agreements regarding real estate transactions, etc. and other concerned parties (including prospective concerned parties)
    4. Real estate brokers, Type II Financial Instruments Business Operators
    5. Property management service providers (including cases in which said property management service providers also act as master lessees or sub lessors)
    6. Lawyers, certified public accountants, tax accountants, judicial scriveners, real estate surveyors, real estate appraisers, financial institutions, etc. who are involved in the Fund’s real estate transactions and management business.
    7. Insurance companies, insurance agencies, etc.
    8. Companies providing software and services related to the real estate management business
  2. The items of personal data that are or may be provided to a third party
    Name, address, telephone number, e-mail address, rental conditions, including rent and other items within the scope necessary for the achievement of the purpose of utilization
  3. The means or method of provision to a third party
    Documents, postal articles, facsimiles, telephone, e-mail and other electromagnetic means
  4. Request to discontinue the provision of personal data to a third party
    When the Fund is requested by an individual to discontinue the provision of personal data to a third party via the point of contact described in 9 below, “Contact Information,” the Fund shall discontinue the provision of the relevant personal data.

5. Disclosure, Revision, Deletion, and Suspension of the Use of Retained Personal Information

When the Fund is requested by an individual to disclose, revise, add, delete, or discontinue the use of retained personal data, the Fund shall disclose, revise, add, delete, or discontinue use of the retained personal data after confirming the identity of the relevant individual. However, revision, addition, or deletion of the matters registered in the Investor’s Registry shall be requested by the Administrator of the Investors’ Registry. See 9, “Contact Information.” The Fund may charge predetermined fees for the handling of said disclosure, etc.

6. Safe Management of Personal Information

The Fund shall to the degree possible endeavor to maintain retained personal data in an accurate and current state. The Fund shall take necessary and proper measures to prevent leak, loss, or damage, and ensure the security of personal data in accordance with laws, regulations, and guidelines, etc.

7. Supervision of Trustees Handling Personal Data

When the Fund entrusts an individual or a business operator with the handling of personal data in whole or in part, it shall exercise necessary and appropriate supervision over the trustee to ensure the security of the entrusted personal data.

8. Application and Revision of the Privacy Policy

The content of the Privacy Policy shall apply from the day it is posted on the Fund’s official website. The Privacy Policy may be revised without advance notice in response to laws and regulations, or when the Fund finds it necessary. In such cases, however, the said fact shall be posted on the Fund’s official website.

9. Contact Information

For questions and inquiries regarding the handling of personal information, requests for discontinuation of the provision of personal data to a third party, disclosure, revision, and complaints regarding personal data, and other matters, please contact the Contact Desk listed below:

Name Nomura Real Estate Asset Management Co., Ltd.
(Nomura Real Estate Asset Management Co., Ltd. is the asset management company of the Fund.)
Address 8-5-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023, Japan
Tel +81-3-3365-8767 (from overseas) / 03-3365-8767 (domestic)
Open 9:00 a.m. - 5:00 p.m. (Japan standard time)
(Closed Saturdays, Sundays, holidays, and company holidays)

However, regarding the revision, addition, or deletion of the matters described in the Investors’ Registry, please contact to the Administrator of the Investors’ Registry described below:

Name Mitsubishi UFJ Trust and Banking Corporation,
Corporate Agency Division
Address 7-10-11 Higashisuna, Koto-ku, Tokyo, Japan
Tel 0120-232-711 (toll-free, domestic only)
Open 9:00AM – 5:00PM (JST)
(Excluding Saturdays, Sundays, national holidays in Japan, and other holidays determined by the company)
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