Personal Information Protection Policy

Ichigo Office’s Commitment

The Ichigo Office REIT Investment Corporation (Ichigo Office) is committed to respecting and complying with Japan’s Personal Information Protection Law, the National Identification Number Law, and other applicable laws, regulations, and guidelines regarding the protection and handling of personal information.

Acquisition and Use of Personal Information

Ichigo Office will acquire personal information only through appropriate means, and will disclose, notify, or state the purpose of use if personal information is directly acquired from an individual in written form or via the Internet, etc. (However, if the purpose of use of the personal information is manifestly clear at the time it is acquired from the individual, there is no additional disclosure requirement for Ichigo Office on its purpose of use.) However, Specific Personal Information as defined under Japanese law shall be acquired and used only to the extent prescribed in relevant laws and regulations.

Purposes of Use of Personal Information

The Personal Information that Ichigo Office acquires shall be used for the following purposes:

  • To exercise rights and execute duties under the Investment Trust and Investment Corporation Law and other applicable laws and regulations;
  • To properly manage and confirm inquiries and visitors to Ichigo Office;
  • To carry out business operations of Ichigo Office 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;
  • For identification purposes for any applications, contracts, and other documents necessary in the normal course of business of Ichigo Office; 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.

Notwithstanding the above, Specific Personal Information acquired by Ichigo Office shall be used only for the following purposes:

  • Operations related to Ichigo Office 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, 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 Office to its shareholders;
  • Operations related to the preparation and submission of payment records of rent paid by Ichigo Office 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 Office to sellers of assets to Ichigo Office;
  • Operations related to the preparation and submission of payment records of payment for real estate or loan mediation by Ichigo Office to its agent;
  • Operations related to the preparation and submission of legal documents for granting and exercising of stock options, and free issuance of new shares; and
  • Operations related to the preparation and submission of legal documents requiring Specific Personal Information by applicable law.

Provision of Personal Information to Third Parties

The personal information acquired by Ichigo Office shall be provided to third parties only in the following cases. As for Specific Personal Information, Ichigo Office will not provide or disclose the information to third parties unless permitted by law.

  • In the event where consent is received from the relevant person;
  • 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 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 handling of personal information is delegated to third parties with appropriate supervision of Ichigo Office; and
  • In the event where the Personal Information Protection Law and other applicable laws, ordinances, and guidelines permit.

Measures for Protection of Personal Information

Ichigo Office shall take appropriate protection measures to prevent the unauthorized disclosure, loss, and/or destruction of personal information when acquiring, using, and storing personal information. Because Ichigo Office delegates asset management and the use of personal information to its asset management company, Ichigo Investment Advisors (IIA), pursuant to the Act on Investment Trusts and Investment Corporations, IIA shall take appropriate protection measures to prevent the unauthorized disclosure, loss, and destruction of personal information when acquiring, using, and storing personal information, under the supervision of Ichigo Office. Ichigo Office’s personal information protection measures, implemented by IIA, are as follows:

  • Ensuring Accuracy of Personal Information
    IIA shall maintain accurate and up-to-date personal information in accordance with the purpose of use.
  • Establishment of Basic Policies
    IIA’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
    IIA 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) IIA 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. IIA 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) IIA shall periodically inspect its handling of personal data, and internal auditors shall conduct audits.
  • Employee Measures for Secure Management
    IIA shall stipulate measures for the handling of personal information in its compliance manual and enforce strict adherence to this by IIA Employees handling personal data.
  • Physical Measures for Secure Management
    a) IIA shall establish roles and responsibilities with respect to users carrying personal data outside of designated areas, and ensure the awareness of IIA Employees.
    b) IIA 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 IIA’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 IIA’s information security management rules and basic information system rules.
  • Responsibilities of IIA Office Employees Regarding Non-Disclosure of Personal Information IIA 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 IIA’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 IIA delegates the handling of personal information to a third party, IIA shall select a party with sufficient personal information protection standards and include in the delegation agreement the right for IIA to supervise, inspect, and receive reports from the delegated party, the requirement that the delegated party comply with instructions from IIA’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, IIA 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.

Supervision of Service Providers Handling Personal Information

In addition to the above, when Ichigo Office delegates the handling of personal information in a compliant and appropriate manner to third parties, Ichigo Office shall supervise such delegated parties as necessary.

Inquiries Concerning Personal Information

Please direct any inquiries and/or requests for notifications, disclosures, amendments, additions, and deletions with respect to the purpose of use based on the Personal Information Protection Law, and cessation of use of personal information and provision of personal information to third parties to the following:

For inquiries regarding the Shareholder Registry and other share-related operations of Ichigo Office:
Mizuho Trust & Banking Co., Ltd
Custody Services Division
2-8-4 Izumi, Suginami-ku, Tokyo 168-8507
Toll-free from Japan: 0120-288-324 (Japanese only)
Business hours: 9am to 5pm JST (closed on weekends, and public holidays)

For all other inquiries:
Inquiries: Ichigo Office IR Desk
Representative: Hiroshi Iwai, President & Executive Officer, Ichigo Investment Advisors Co., Ltd.
The Imperial Hotel Tower, 1-1-1 Uchisaiwaicho
Chiyoda-ku, Tokyo 100-0011
Tel: +81-3-3502-4891
Business hours: 9:30am to 6:15pm JST (closed on weekends, public holidays, and company holidays)


Yoshihiro Takatsuka, Executive Director, Ichigo Office REIT Investment Corporation
1-1-1 Uchisaiwaicho, Chiyoda-ku, Tokyo 100-0011

This Personal Information Protection Policy may be amended for various reasons, such as changes in laws or regulations.