Privacy Policy

Tosei Asset Advisors (“TAA”) ensures that all employees are fully aware of the importance of handling customers’ personal information with care. To offer high-quality products and services, TAA implements the privacy protection-related measures below while meeting corporate responsibilities.

1.Basic policy

TAA ensures to comply with the applicable laws, regulations, and guidelines relating to the protection of personal information and manage and use customers’ personal information appropriately.

2.Secure management of personal data

TAA separately defines internal standards about the handling of personal information and related systems. It appoints a manager to oversee personal information protection and implement system-related precautions and safety measures to prevent unauthorized access.
In addition, TAA maintains effective and appropriate management by continuously reviewing the Basic Policy, the standards for handling personal information, and the organizational structure.

3.Appropriate acquisition of personal information

When acquiring personal information from customers, TAA follows appropriate and legitimate processes. Moreover, TAA clearly states the purposes of such acquisitions that are required to fulfill those purposes.

4.Purpose of use

Personal information provided by customers is used only within the scope of the indicated purpose of use and not for any other purposes.

5.Restrictions on provision to third parties

Except in the cases below, TAA does not provide or disclose personal information provided by customers to any third parties.

  1. The customer provides prior consent.
  2. It is not possible to identify a disclosing individual based on the disclosed information.
  3. Disclosure is required by applicable laws and regulations
  4. National government institutions, local governments, or any parties acting on their behalf need the cooperation of TAA to carry out legally mandated duties, and there is a risk that requesting their consent could interfere with the execution of those duties
  5. The purpose is to protect the assets and interests of TAA

When TAA discloses or provides information to any third party after obtaining the customer’s consent, TAA ensures that the third party has arranged to protect personal information and that the data is provided or disclosed to appropriate persons only.

6.Disclosure, revision, addition, deletion, or termination of use of personal information

Suppose a customer wishes to verify or revise personal information provided to TAA. In that case, TAA shall handle the request promptly, to the extent that it is deemed reasonable and necessary. As part of this process, TAA may request to verify the person’s identity making the request.

7.Secure management measures relating to outsourcing

When TAA outsources the acquisition and handling of personal information to any third party, the vendor is obliged to implement stringent management of personal information, and its performance is closely monitored and supervised.

8.Internal training

TAA trains employees about personal information protection and ensures that employees are kept thoroughly informed.

9.Disclaimer

The website of TAA may include links to external websites. The company bears no liability about protecting personal information on external sites accessed via these links.

Purpose of Using Personal Information

  1. TAA uses acquired personal information for the following purposes:
    (1)To conduct solicitation and other sales activities, contract-related administrative procedures for real estate leasing-related business.
    (2)To conduct solicitation and other sales activities, contract-related administrative procedures for real estate management-related business.
    (3)To conduct solicitation and other sales activities, contract-related administrative procedures for investment advisory business relating to real estate, securities, and other financial assets
    (4)Contract-related administrative procedures for Type II financial instruments business stipulated in the Financial Instruments and Exchange Act to conduct solicitation and other sales activities.
    (5)To conduct market trend analysis, customer satisfaction surveys, or research and analysis for product development relating to the above business.
    (6)To fulfill the company’s obligations, exercise its rights, or implement measures associated with fulfilling its obligations and exercising its rights.
  2. Personal information that has been legitimately obtained from the following public sources may be used for purposes 1 to 4 above.
    (1)Real estate registers
    (2)Cadastral maps
    (3)Commercial registers
    (4)Credit information agencies
    (5)Other appropriately and legitimately disclosed personal information

Shared Use of Personal Data

The Tosei Group works to meet the diverse needs of customers by leveraging the strengths of its group companies through comprehensive management. In doing so, personal data possessed by TAA may be shared with other group companies as outlined below.

  1. Users of shared information
    Under the applicable laws and regulations, TAA may share the data with companies covered by Tosei Corporation’s consolidated financial statements. The major companies in the group are listed in “Tosei Group.”
    * N.B.: The companies are subject to change.
  2. Purposes of using shared information
    Users of shared information use it for the following purposes:

    • Development, introduction or proposal, and supply of new products and services related to real estate securitization business, real estate development business, real estate leasing business, real estate fund business, real estate management business, or alternative investment business (including sales activities such as information provision, orders, delivery, billing and receipt and holding seminars, events, etc.) and marketing analysis (including market surveys on products and services conducted via surveys, etc.)
  3. Personal information items for shared use
    TAA may share Details such as the customer’s name, address, date of birth, phone number, credit information. We shall share transaction information to the extent required for the “Purposes of using shared information” indicated above.
  4. Personal information manager
    Contact information for inquiries about personal data management:
    Tosei Asset Advisors, Inc.
    4-5-4 Shibaura, Minato-ku, Tokyo 108-0023

Contact Information for General Inquiries Concerning Personal Information, Including Requests to Disclose, Revise, or Stop using Personal Information

Tosei Asset Advisors, Inc.
Risk Compliance Office
Tel.: +81-3-5439-8712
(Hours: 9 a.m. – 6 p.m., except Saturdays, Sundays, and year-end/new year holidays)

Please get in touch with the investors ‘ registry administrator about the revision, addition, or deletion of items recorded in the investors’ registry.

Mitsubishi UFJ Trust and Banking Corporation Securities Agency Division
Address: 1-1 Nikko-cho, Fuchu-shi, Tokyo
Tel.: 0120-232-711 (toll-free only in Japan)
Hours: 9 a.m. – 5 p.m. (except Saturdays, Sundays and year-end / new year holidays)

TAA is a member of the Investment Trusts Association, Japan, and the Japan Investment Advisers Association. Inquiries or complaints regarding the handling of personal information by a member may be directed to either of these authorized personal information protection organizations.

Name: Investment Trusts Association, Japan investor support line
Tel.: +81-3-5614-8440
Hours: 9 a.m.-11:30 a.m., 12:30 p.m. – 5 p.m. (except Saturdays, Sundays, national holidays, and holidays designated by the association)
Name: Japan Investment Advisers Association Secretariat Office complaint line (personal information manager)
Tel.: +81-3-3663-0505
Hours: 9 a.m. – 5 p.m. (except Saturdays, Sundays, national holidays, and holidays designated by the association)

This privacy policy is subject to change in line with any change to laws and regulations.

Updated: September 17, 2021