Healthcare & Medical Investment Corporation

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Privacy Policy【Tentative translation:only Japanese text is authentic】

Healthcare & Medical Investment Corporation (hereinafter, “HCM”) recognizes the importance of protection of personal information (including individual numbers and specific personal information (hereinafter, collectively the “Specific Personal Information, etc.”). The same shall apply hereafter in the privacy policy unless otherwise defined.) and strives to properly handle, manage and protect personal information while strictly complying with the Act on the Protection of Personal Information (hereinafter, the “Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (hereinafter, the “Individual Number Act”), other related laws and regulations, guidelines and such upon handling personal information.

1. Basic Policy for Handling Personal Information

HCM regards personal information as an important information asset and recognizes that not only is it required by laws but it is also HCM’s social responsibility to properly collect, manage and use collected personal information to the extent required for its operations. To fulfill this responsibility, HCM shall follow the basic policy stated below.

(1) HCM shall collect personal information by lawful and fair means to the extent required for its operations, and shall not collect personal information through deceptive or other illegal means. Moreover, HCM shall not collect personal information requiring special care without the consent from the individual except for cases prescribed in laws and regulations. HCM shall not collect sensitive information (as defined in Guidelines for Personal Information Protection in the Financial Field (hereinafter, the “Guidelines in Financial Field”)) except for cases provided in the Guidelines in Financial Field.
(2) HCM may request individuals or other administrators of operations regarding individual numbers to provide relevant Specific Personal Information, etc. only when it is necessary to do so in order to handle operations designated in 2-2 below. In addition, such requests shall be made when necessity to do so arises in order to handle the relevant operations or when occurrence of such operations is expected. When accepting individual numbers, HCM shall identify the individuals by using the methods designated in Article 16 of the Individual Number Act. When accepting individual numbers from proxies, HCM shall confirm their authority of proxy, identify the relevant proxies, and check their individual numbers.
(3) HCM shall strive to keep collected personal data both accurate and updated, and to delete such data without delay when its use is no longer necessary. In addition, HCM shall implement necessary and appropriate measures with regard to thorough employee education and development of information security management systems in order to prevent unauthorized access to and leakage, loss, damage and falsification of personal data.
(4) HCM shall manage collected Specific Personal Information, etc. appropriately based on the Individual Number Act, other related laws and regulations, guidelines and such. In addition, HCM shall implement necessary and appropriate measures with regard to thorough employee education and development of information security management systems in order to prevent unauthorized access to and leakage, loss, damage and falsification of Specific Personal Information, etc.
(5) HCM shall not handle collected personal information (excluding Specific Personal Information, etc.) beyond the scope of purpose of use specified by HCM, except for cases where prior consent from the individual is obtained or such is permitted by laws and regulations, etc. HCM shall not use collected Specific Personal Information, etc. beyond the scope of the specified purposes even when consent from the individual has been obtained, except for exceptional cases where such is permitted by the Individual Number Act. Furthermore, HCM shall use collected personal information within the minimum scope in accordance with the purpose of use. HCM shall not use sensitive information except for cases provided in the Guidelines in Financial Field.

2-1. Purpose of Use of Personal Information (excluding Specific Personal Information, etc. The same shall apply hereafter in 2-1.)

HCM shall use personal information only to the extent required to achieve any of the following purposes, except for cases where purposes of use are permitted by laws and regulations, etc.

(1) To ensure the exercise of the rights of unitholders or fulfill the obligations to unitholders, such as dispatch of asset management reports, notice of convocation of unitholders’ meetings and notice of dividend payment to unitholders, pursuant to the Act on Investment Trusts and Investment Corporations (hereinafter, the "Investment Trusts Act") and other related laws and regulations.
(2) To prepare various data or manage information regarding unitholders, such as preparation of registry for the purpose of providing information on holding of HCM’s financial results briefing and management report briefing, pursuant to the Investment Trusts Act and other related laws and regulations.
(3) To perform businesses concerning acquisition, brokerage, sale, transfer, leasing of assets under management, real estate management, or information gathering, research, analysis and discussion on these matters related to HCM.
(4) To perform IR activities and general administrative duties related to HCM.
(5) To perform duties incidental or related to the above.
(6) To seek advice or services from such outside experts as attorneys at law, certified public accountants, certified tax accountants, real estate appraisers and judicial scriveners in order to achieve the above purposes.

2-2. Purpose of Use of Specific Personal Information, etc.

Purpose of use of Specific Personal Information, etc. by HCM shall be as follows.

Operations regarding individual numbers of directors and individuals other than directors (including operations related to the following)

(i) Preparation of payment reports for remuneration, charges, etc. pursuant to the Income Tax Act.
(ii) Preparation of payment reports for dividends, distribution of surplus and interest on funds pursuant to the Income Tax Act.
(iii) Preparation of payment reports for real estate usage fees, etc. pursuant to the Income Tax Act.
(iv) Preparation of payment reports for consideration for receipt of real estate, etc. pursuant to the Income Tax Act.

HCM shall use personal information within the scope necessary to achieve the purposes of use specified in above 2-1 and 2-2, and shall not use personal information for other purposes.

3-1. Provision of Personal Data to Third Parties

HCM may provide collected personal data (excluding personal data concerning Specific Personal Information, etc.) to third parties in the following cases.

(1) When prior written consent has been obtained from the individual.
(2) When such provision is pursuant to laws and regulations.
(3) When such provision is necessary for protection of the life, body or property of an individual, and it is difficult to obtain the consent of the person.
(4) When such provision is particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person.
(5) When such provision is necessary for cooperating with a state organ or a local government, or an individual or a business operator entrusted by a state organ or a local government to execute the affairs prescribed by laws and regulations, and obtaining the consent of the person is likely to impede the execution of the affairs.

3-2. Provision of Specific Personal Information, etc. to Third Parties

HCM shall not provide Specific Personal Information, etc. to third parties regardless of the existence of consent of the individual, except in the cases listed in the items of Article 19 of the Individual Number Act.

4. Entrustment of Personal Information and Supervision of the Entrusted Parties

When entrusting the handling of personal data collected by HCM in whole or in part, HCM shall take appropriate measures giving proper attention to personal data based on laws and regulations, etc., and conduct necessary and appropriate supervision over such entrusted parties to ensure safe management of the entrusted personal data.

5. Requests for Notification of Purpose of Use, Disclosure, Correction, etc., Discontinuance of Use, etc. or for Discontinuance of Provision to Any Third Party of Collected Personal Data

HCM shall strive to keep personal data both accurate and updated within the scope necessary for achieving the purpose of use, and to delete such data without delay when its use is no longer necessary. When a request for notification of purpose of use, disclosure, correction/addition/deletion, discontinuance/erasing and discontinuance of provision to third parties (hereinafter, “Disclosure, etc.”) concerning personal data held by HCM is made by an individual, HCM shall respond accordingly based on laws and regulations and related rules, after confirming the identity of the individual or the proxy. For further details of procedure, please contact our contact desk in 7. below. Please note that a designated fee may be charged for notification of purpose of use or disclosure of personal data held by HCM.

6. Continuous Improvement

HCM shall strive to improve its personal information management system and securement of safety of the information by revising this Privacy Policy as necessary to respond to amendments to laws and regulations, etc., growing or changing societal demands and such.

7. Inquiries

Please contact the following for inquiries on handling of personal information, requesting Disclosure, etc. of personal data held by HCM and filing complaints.

Inquiries

Name Finance & Administration Department, Healthcare Asset Management Co., Ltd.
Address 3-3, Kandaogawamachi, Chiyoda-ku, Tokyo
TEL +81-3-5282-2922
Business hours 9:00~17:00 (Excluding Saturdays, Sundays, national holidays and the year-end and New Year's holidays)

For inquiries on items in the unitholders' register or on Specific Personal Information, etc. of unitholders, please contact our transfer agent below.

Inquiries

Name Stock Transfer Agency Business Planning Department, Sumitomo Mitsui Trust Bank, Limited
Mailing address 2-8-4, Izumi, Suginami-ku, Tokyo 168-0063,Japan
TEL +81-120-782-031 (toll-free within Japan)
Business hours 9:00~17:00 (Excluding Saturdays, Sundays, national holidays and the year-end and New Year's holidays)
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