Personal Information Protection Policy (Privacy Policy)

Company name: Kenedix Residential Next Investment Corporation

Location: 2-1-6 Uchisaiwaicho, Chiyoda-ku, Tokyo

CRepresentative: Tetsu Kawashima, Executive Director

1. Basic Policy on Personal Information Protection

Kenedix Residential Next Investment Corporation (hereinafter, "KDR") is committed to the appropriate processing and management of personal information in accordance with the Act on the Protection of Personal Information and other related laws, regulations and guidelines, etc.

2. Purpose of Use of Personal Information

(1) KDR uses the acquired personal information for the following purposes.

①For conducting any business operations pertaining to the exercise of the rights of the unitholders of KDR (hereinafter, the “unitholders”) and to the performance of the obligations of KDR pursuant to the Act on Investment Trusts and Investment Corporations (hereinafter, the “Investment Trust Act”) and other laws and regulations, as well as regulations of administrative agencies and financial instruments exchanges (hereinafter “Investment Trust Act, etc.”), such as providing asset management reports and issuing notices of convocation of the general meeting of unitholders or notices of payment of distributions to the unitholders;

②For managing information of the unitholders, such as preparation of data of the unitholders’ register, etc. prepared pursuant to the Investment Trust Act, etc., and for providing information to unitholders;

③For handling and confirming inquiries and visits concerning businesses conducted by KDR;

④For acquiring properties (including securities or claims underlying such properties; the same shall apply hereafter), and conducting surveys and considerations of acquisitions prior to such acquisitions;

⑤For conducting property sales, and having buyers or new real estate management companies conduct surveys and considerations of sales prior to such sales;

⑥For grasping and managing the status of leasing, management of rent income as well as conducting business operations for billing expenses pertaining to restoration costs, etc., to lessees of properties held by KDR;

⑦For confirming the status of creditworthiness of lessees of properties held by KDR or which KDR is considering acquiring or that of those considering leasing such properties (including confirmation by buyers or new real estate management companies), and conducting business operations for concluding lease agreements;

⑧For conducting business operations concerning analyses of demand, such as leasing service enhancement questionnaires, and various communications with lessees of properties held by KDR or those considering leasing such properties;

⑨For conducting a calculation of allowance for doubtful accounts in the financial results of KDR as well as other business operations concerning accounting and taxation;

⑩For conducting business operations concerning provision of all sorts of information concerning guides, etc. for KDR’s financial results briefing sessions, management status reporting sessions and property viewing sessions to unitholders, preparation of attendance data, etc.;

⑪For conducting business operations concerning inquiries, requests for materials, etc. from KDR’s unitholders and those considering buying securities issued by KDR;

⑫For claiming nonlife insurance pertaining to properties held by KDR;

⑬For confirming the identification of the persons stated on application forms, contracts, etc. for performance of the businesses conducted by KDR; and

⑭In addition to what is provided for in the preceding items, for performing business operations related or incidental to the businesses conducted by KDR

(2) KDR will not alter the purpose of use of personal information beyond the scope recognized reasonably relevant to the pre-altered purpose of use.

(3) KDR will not use the personal information in a manner that may encourage or induce illegal or unjust acts.

3. Acquisition of Personal Information

When acquiring personal information, KDR will use appropriate and fair means to the extent necessary to achieve the purpose for which the information is to be used. Where personal information is to be acquired, KDR will do so through appropriate means. Where personal information is to be acquired directly from the person in writing or via a website page, etc., KDR will clearly indicate the purposes of use in advance. However, where the purposes of use are clear given the circumstances of the acquisition of personal information or where omission of clear indication of the purposes of use is permitted under laws and regulations, etc., a clear indication of the purposes of use may be omitted.
In addition, when obtaining personal information through third parties, KDR will not obtain personal information suspected of having been obtained illegally.

4. Management of Personal Data

KDR strives to maintain personal data accurate and up-to-date within the scope necessary to achieve the purposes of use and to delete personal data that are no longer necessary.
KDR entrusts the handling of personal data to asset management companies In accordance with the guidelines for the protection of personal information set forth by the Personal Information Protection Commission and/or Financial Services Agency, at each stage of the acquisition, use, storage, etc. of personal data, the asset management companies take the following necessary and appropriate safe management measures in order to prevent leakage, loss or damage, etc. of personal data. KDR will maintain internal rules necessary for the safe management of personal data, provide education and training to a director, and exercise necessary and appropriate supervision to the director.

①Establish and comply with policies and regulations to ensure the proper handling of personal data;

②Establish and comply with rules and regulations regarding the handling of personal data at each stage of the acquisition, use, transfer, storage, deletion, etc., including handling methods, responsible persons/persons in charge and the definition of their duties;

③Appoint an information management officer and periodically inspect and audit the status of the handling of personal data. The results of the inspection and audit shall be reported to the Board of Directors and a system established for the Board of Directors to evaluate, review and improve security control measures;

④Take measures to prevent theft or loss of personal data in areas where personal data is handled;

⑤Install in the information systems handling personal data tools for the identification of, and protection against, unauthorized access from outside or the installation of unauthorized software. In addition, set access privileges as necessary, record, analyze, and store access to personal data, and monitor record of suspected fraud on a regular basis; and

⑥When handling personal data in foreign countries, implement the necessary security control measures based on an understanding of the systems for the protection of personal data in the countries and regions where personal data is handled.

5. Handling of Sensitive Information

With respect to Sensitive Information (“Special care-required personal information” defined in the Act on the Protection of Personal Information and sensitive information provided for in the “Guidelines for Personal Information Protection in the Financial Field”), KDR will not acquire, use or provide to any third parties the Sensitive Information without the principal’s consent, unless permitted under the Act on the Protection of Personal Information and other related laws, regulations and guidelines, etc..
When handling pseudonymized information, anonymized processed information and personality-related information, KDR will comply with the obligations stipulated in relevant laws, regulations, and guidelines.

6. Disclosure and Provision of Personal Data to Third Parties

(1) KDR will not disclose or provide personal data to third parties except in the following cases.

①The principal has given his/her consent;

②The disclosure or provision of personal data is based on laws and regulations;

③The disclosure or provision of personal data is required to protect life, health or assets of a person and it is difficult to obtain the principal's consent;

④It is particularly necessary in order to enhance public health or to promote the sound nurturing of children, and it is difficult to obtain the principal's consent;

⑤Cooperation is requested by national or local government agencies, or service providers contracted by those agencies to conduct matters prescribed by laws and regulations, and obtaining the principal's consent may hinder the conduct of such matters;

⑥KDR provides personal data to outside service providers under appropriate supervision by KDR within the scope necessary to carry out the applicable purpose of use of the personal data; and

⑦The disclosure or provision of personal data is permitted under the Act on the Protection of Personal Information and other laws, regulations and guidelines, etc.

(2) When providing personal data or personality-related information to a third party situated in a foreign country, KDR will comply with the obligations stipulated by the relevant laws, regulations, and guidelines.

7. Supervision of Contracted Service Providers

KDR outsources asset management services and general administration, etc. pursuant to the Investment Trusts Act as a registered investment corporation. KDR conducts necessary and appropriate supervision of such contracted service providers to prevent loss, misuse, modification, etc. of the personal data handled and in their possession.

8. Joint Use of Personal Data

KDR jointly uses certain personal data with its asset management company, Kenedix Real Estate Fund Management, Inc., and other registered investment corporations for which the latter company provides asset management business serevice, etc., in the following manner within the scope necessary to achieve the purposes of joint use:

9. Inquiries Concerning Personal Information

Please contact the following if you have requests to notify the purpose of use or other inquiries regarding disclosure, correction, addition, deletion, or suspension of use, etc. of the personal data that has been provided to KDR, or require disclosure of records of the personal data provided to third parties:

*Revision of this Policy
KDR will review and revise this Privacy Policy pursuant to amendments to and/or the abolition of laws and regulations, etc. or whenever such revisions are necessary, and will strive to protect personal information.

End

Enacted on April 10, 2012
Last amended on April 1, 2022