Privacy Policy

Based on the Act on Investment Trusts and Investment Corporations (the "Investment Trust Act"), ORIX Asset Management Corporation ("OAM") is entrusted with the management of the assets of ORIX JREIT Inc. ("OJR")

As a member of ORIX Group, OAM is committed to building strong trusting relationships by providing ORIX Group's quality services toward the various needs of our stakeholders, including our customers not just in Japan but also those overseas in the Americas, Europe, Asia, Oceania and the Middle East.

To this end, we ensure our collection of personal information is conducted in an appropriate manner that is in compliance with laws and regulations and treat, manage, and protect this information as our most valuable asset, in accordance with the disclosure below.

This Privacy Policy (this “Policy") discloses the purposes for which we process personal information and explains regarding our processing of such personal information.

1．Legal Compliance

We recognize the need for, and are fully committed to, ensuring that all officers and employees are fully aware of and comply with laws and regulations regarding the processing of personal information in order to protect personal information we process and ensure its safety.

2．Continuous Improvement of Compliance Program

We have established a compliance program that includes elements relating to the processing of personal information and periodically review those elements and strive to continuously improve them.

3．Scope of Application

This Policy applies to all personal information that we process in all countries and regions where we have business operations.

4．Types of Personal Information

We collect and process the following personal information.

  1. Contact information: name, address, telephone number, fax number, and email address;
  2. Identifying information: date of birth (age), gender, nationality, place of origin, residence, licenses, photographs, passport, visas or other government-issued identification data, background (education, job history, etc.), company name, job title, and family structure;
  3. Information for creating online accounts: username, password, and security questions and answers;
  4. Financial information: invoice address, credit or debit card number or other payment-related data, and bank account information;
  5. Details regarding use of services and details regarding inquiries made;
  6. Locational information and actions on networks: IP address, mobile device locational information, access information for our home page, device settings, log information, usage time, browser version information, operating system, browsing history, user ID, types of information viewed, and cookie and similar data;
  7. Audio and video information: The content of calls made to us to when making inquiries and images from security cameras when at our properties;
  8. Credit information: Information that must be collected pursuant to relevant laws and regulations, such as information for identity confirmation purposes;
  9. Customer preferences and hobbies; and
  10. Any other information you elect to provide directly to us in connection with your use of services we provide.

5．Methods of Acquiring of Personal Information

We collect personal information through the following means:

  1. Information provided by individuals: acquired through face-to-face, telephone, mail and e-mail interactions, acquired through the filing out of applications, contracts, online forms, and questionnaires;
  2. Information provided by others: acquired through group companies, subcontractors, business partners, company-operated stores, franchise stores, and service providers, etc.;
  3. Technical information: acquired during the use of services; and
  4. Information: acquired as a result of merger and other transactions that result in business succession:

Individuals may refuse to provide personal information to us but the decision not to provide certain personal information to us may result in OAM not being able to provide certain products and services to such individual.

6．Legal Basis for Processing

OAM’s legal basis for processing your personal information will typically be one of the following.

  1. Your consent;
  2. Necessary for the performance of a contract with you
  3. Necessary for OAM to fulfill its legal obligations;
  4. Necessary to protect vital interests; or
  5. Required for our legitimate interests or those of a third party, provided that if such interests are overridden by your interests or fundamental rights and freedoms, we will not process your personal information. Our legitimate interests are specified in more detail in Section 7 “Purpose for Processing of Personal Information” below. More information on the balancing test is available upon request.

7．Purpose for Processing of Personal Information

  1. Upon its handling of personal information, OAM will disclose the specified purpose of use of such after identifying in what business the personal information is to be used and for what purpose to the best of OAM's ability in a way that allows you rational projections, with the exception of cases where it is considered that the purpose of use is clear in consideration of the circumstances of the acquisition. OAM may use personal information within the scope of the purposes of use outlined in the below items. In cases where personal information of leaseholders or parties that are considering leasing are to be used with the purposes indicated in item 9 or items 12 to 14, or to be used with regard to these items for the purposes indicated in items 18 to 20, information pertaining particularly to place of employment, composition of family, income, and such may be used.
    1. ①To contact you, reply to your inquiries or requests for documents, etc.
    2. ②To implement measures to facilitate the relationship of OAM and/or OJR with its unitholders such as activities to provide information to unitholders concerning the operations of OAM and OJR (IR activities), etc.
    3. ③To manage unitholders with the register of unitholders, employing data created based on the provisions of the Investment Trust Act, the Companies Act of Japan and other related laws and regulations.
    4. ④To exercise the rights of its unitholders and to carry out OJR's duties based on the Investment Trust Act, the Companies Act of Japan and other related laws and regulations by sending out its asset management reports, notice of convocation of general meetings of unitholders, paying distributions and such.
    5. ⑤To provide convenience to unitholders in accordance to their status as unitholders.
    6. ⑥To invite unitholders to OJR's financial briefings, performance report meetings and other meetings hosted by OAM.
    7. ⑦To borrow funds, offer investment corporation bonds and issue additional investment units by OJR.
    8. ⑧To sign damage insurance contracts by OJR.
    9. ⑨To implement various checks related to the OJR's acquisition of Properties (including title rights checks, credit checks on leaseholders and evaluation of building conditions) and to make judgments based on such.
    10. ⑩To carry out OJR's closing of accounts and other operations related to accounting and tax practices.
    11. ⑪To conduct OJR's registration procedures.
    12. ⑫To manage the receipt of rental payments, the return of deposits and other operations related to Leasing.
    13. ⑬To seek those that may be interested in acquiring Properties.
    14. ⑭To determine the credit status of leaseholders and parties that are considering leasing Properties.
    15. ⑮To notify and contact leaseholders of Properties when conducting repairs, additional work, renovation work.
    16. ⑯To collect data on you, implement statistical processing and analysis and to create lists, etc. that reflect such that are necessary in executing OAM's operations.
    17. ⑰To request operations such as replication and binding of documents.
    18. ⑱To request the advice of specialists (attorneys, certified public accountants, certified tax accountants, real estate appraisers, judicial clerks, licensed social insurance consultants.)
    19. ⑲To conduct operations incidental or related to the above items.
    20. ⑳To provide personal information or personal data to third parties with the purpose of achieving the purposes of use in the above items.
    21. ㉑To facilitate the appropriate and efficient performance of business by OAM or business ancillary or related to such business.

    Third parties to whom personal data is provided includes OJR, Administrator of Unitholder Registry, Depository Institutions., partner financial institutions, underwriters, non-life insurance companies, specialists, Building Specialists, companies managing Properties, those interested in purchasing or renting Properties, information processing companies, survey companies, etc., and provision of information to third parties will depend on the means of delivery such as with email, mail by post, facsimile or hand delivery and may take the form of issuing originals, copies, data generated on a computer, etc.

  2. Restriction of Purpose of Use
    OAM will not handle personal information beyond the scope necessary for achieving the purposes of use specified in the above items.
  3. Change of Purpose of Use
    In the event that OAM is to make changes to the purposes of use specified in Section 1 or to the method or means of provision to third parties and such, OAM will promptly disclose the content of changes with the exception of the situations in the below items.
    1. ①When the notification or disclosure of the purpose of use to you concerned poses a risk of damage to the life, health, property or other rights and interests of you or a third party.
    2. ②When the notification or disclosure of the purpose of use to you concerned poses a risk to OJR's rights or legitimate interests.
    3. ③When it is necessary to cooperate with a national agency or a local government in executing the affairs prescribed by laws and regulations and in which notifying you of the purpose of use or disclosing it are likely to impede the execution of the affairs.
    4. ④When it is considered that the purpose of use concerned is clear in consideration of the circumstances of the acquisition.

8．Protection and Management of Personal Information

OAM takes necessary and appropriate measures to prevent leakage, destruction or damage, outflow, unauthorized external access, loss or tampering of personal data and to securely manage personal data (the "Security Control Measures").

Regarding these rules, OAM has formulated a privacy policy for the basic policies of secure management (including the Security Control Measures) and other matters.

9．Provision of Personal Information to Third Parties

Your personal information may be shared with the following third parties under certain circumstances.

  1. ORIX Group companies
    In order to meet diverse needs of our stakeholders through the comprehensive strength and consolidated management of the ORIX Group, we may share your personal information within the ORIX Group for the purposes described in this Policy.
  2. Contractors and specialists
    In order to support the provision of products and services by OAM or have others provide services on behalf of OAM, we may share your personal information with other companies, agents and contractors that we use.
  3. Business partners, directly managed stores, and franchisees
    In order to provide services jointly with other companies or to provide services to you pursuant to a contract, we may share personal information with relevant business partners, directly operated stores and franchised stores.
  4. Business successors
    We may sell of certain of our businesses to other companies in connection with reorganizations of our overall business. As a consequence of such sales, we may transfer or sell to third parties your personal information that was held in connection with the business sold.

Our website may from time to time contain links to and from websites of our business partners. Please be aware that each of these websites has its own privacy policy and OAM has no control over how each business partner uses personal information that it receives from you. Prior to providing personal information to any of our business partners, please confirm the privacy policy of the relevant third party’s website.

10．Supervision of workers

When allowing workers to handle personal data, OAM shall conduct necessary and appropriate supervision of the workers in addition to instituting appropriate internal management systems and requiring workers to sign agreements of confidentiality so that the personal data will be safely managed.

11．Supervision of Subcontractors

OAM may entrust all or part of handling of personal data to third parties prescribed in Section 9 “Provision of Personal Information to Third Parties”.

When entrusting all or part of handling of personal data, OAM shall conduct necessary and appropriate supervision of the subcontractor so that the personal data whose handling has been commissioned will be safely managed.

The entrusting of handling of personal data by OAM will be conducted within the scope necessary for the achievement of the purposes of use set forth in Section 7 “Purpose for Processing of Personal Information”.

12．Transfers to a Third Country

Your personal information may be transferred to and processed in a country or region other than the one where you are located by OAM or a third party described in Section 9 “Provision of Personal Information to Third Parties” of this Policy for the purposes set forth in Section 7 “Purpose for Processing of Personal Information” of this Policy. Such countries and regions include countries that have different standards of data protection than those of the country where you are located. OAM will take all reasonable steps required by applicable law, including the execution of appropriate contracts, to ensure that your personal information is handled in a safe and secure manner and in accordance with this Policy and applicable data-protection laws and regulations.

13．Your Rights

  1. Notice of intended use of personal information
    You can request we inform you of our intended use for your personal information that we possess. In the event you make such a request, we will respond to the request promptly and appropriately in accordance with applicable laws and regulations.
  2. Access to personal information
    You have the right to verify whether or not we process personal information about you and, if we process such personal information, you have the right to request access to it. You also have the right to obtain a copy of your personal information that we process. In the event you request we disclosure your personal information to you, we will respond to the request promptly and appropriately in accordance with applicable laws and regulations.
  3. Correction of personal information
    If your personal information is inaccurate or incomplete, you have the right to request that we correct, supplement or otherwise complete such personal information ("Rectify"). In the event you request we Rectify your personal information, we will respond to such request promptly and appropriately in accordance with applicable laws and regulations.
  4. Deletion of personal information
    You have the right to require us to delete any of your personal information that we process. Provided, however, that we are not obligated to take such action if our retention of such personal information is necessary to comply with our legal obligations or to assert, enforce or defend our legal rights.
  5. Restrictions on the processing of personal information
    If your personal information processed by us is inaccurate, the processing by us is illegal or it is no longer necessary for us to process the personal information for a particular purpose, you have the right to restrict the processing of your personal information. However, if we are unable to delete your personal information due to the need to comply with legal or other obligations or you do not request deletion of your personal information by us, we are not obligated to take such action.
  6. Data portability
    If your personal information is (1) personal information provided to us by you, and (2) we process such personal information based on your consent or in order to perform a contract with you, you have the right to obtain the personal information held by us with respect to you in a structured, commonly used and machine-readable format and the right to transmit such personal information to another controller. You also have the right to have us directly transmit such personal information to another controller, where technically feasible.
  7. Withdrawal of consent
    If you consent to processing of your personal information, you have the right to withdraw your consent at any time without charge. This includes cases where you wish to stop receiving marketing communications.
  8. Complaints
    You have the right to file a complaint about the processing of your personal information by us.

If you wish to exercise the right described above, please contact us through the phone number listed in Section 19 “Contact Information for Inquiries about Personal Information” of this Policy. In order to respond to your request and protect your privacy and security, we may request you provide information necessary for us to confirm your identity. In cases where we are unable to confirm your identity based on the information that we receive from you and information in our possession, we may request you provide additional information. Also, please note that we may require payment of a set fee. We are committed to responding to your request to exercise your rights in accordance with applicable laws and regulations.

If you believe that OAM is not in compliance with applicable laws and regulations on the protection of personal information, you have the right to file a complaint with the competent supervisory authority with oversight over data protection in accordance with applicable laws and regulations.

14．Retention Period for Personal Information

OAM will generally only retain personal information we collect for a period of time reasonably necessary to achieve the particular business purposes for which we collected the personal information. In some cases, we may need to retain personal information for longer periods of time pursuant to laws or regulations applicable to our business. Personal information that is no longer needed will be promptly deleted.

15．Compliance with Related Laws and Regulations

OAM recognizes that protecting personal information and maintaining its security requires sufficient understanding of and compliance with related laws and regulations, norms, and it shall do all in its power for this aim. Also, OAM shall respond appropriately to complaints and claims concerning the protection of personal information.

16．Continued Improvement of Privacy Policy

OAM shall comply with its Privacy Policy including the basic policies of secure management and shall review as needed and work toward its continued improvement going forward. Also, when changes are to be made to the privacy policy as a result of such reviews, the content shall be published on this website.

17．Special Provisions regarding Japan’s Act on the Protection of Personal Information

In the event the Act on the Protection of Personal Information of Japan is applicable to the processing of your personal information, the following terms apply:

  1. Shared users of personal information
    OAM will share the personal information described in Section 4 “Types of Personal Information” of this Policy for the purposes described in Section 7 “Purpose for Processing of Personal Information” of this Policy.
    The scope of shared use of personal information will be limited to ORIX Group companies as described in “1. ORIX Group companies” in Section 9 “Provision of Personal Information to Third Parties” of this Policy. Please note that this category of ORIX Group companies includes companies that do not contain “ORIX” in their name. For details regarding such companies, please see our "List of Shared Users."
    * Listed companies subject to change.

OAM will not disclose or provide your personal information to third parties without your consent, except for cases of shared use, disclosure to contractors, or where otherwise permitted by applicable law and regulations.

18．Party Responsible for Handling Personal Data (Controller)

ORIX Asset Management Corporation
Nippon Life Hamamatsucho Crea Tower, 2-3-1 Hamamatsucho, Minato-ku, Tokyo 105-0013, Japan

19．Contact Information for Inquiries about Personal Information

Requests and proposals concerning the content of this document can be made at the following contact address.

Nippon Life Hamamatsucho Crea Tower, 2-3-1 Hamamatsucho, Minato-ku, Tokyo 105-0013 Japan
ORIX Asset Management Corporation
Risk Management and Compliance Department (TEL: +81-3-5776-3324)
(Hours: 9:00 a.m. to 5:00 p.m. JST Monday through Friday; closed on national holidays, including substitute holidays, and from December 30 to January 3)

Please note, notwithstanding the provision above, requests and proposals from unitholders concerning the content of this document may be handled and responded from the following contact address on behalf of OAM.

＜Contact address of Administrator of Unitholder Registry＞
2-8-4 Izumi, Suginami-ku, Tokyo 168-0063
Stock Transfer Agency Department, Sumitomo Mitsui Trust Bank, Limited
(TEL: 0120-782-031 toll free in Japan)

Please note that depending on the content of requests and proposals, there may be cases where responses cannot be made in light of the Investment Trust Act, the Companies Act of Japan, the Financial Instruments and Exchange Law and other related laws and regulations.

20．Customer Complaints Office to Authorized Personal Information Protection Organization

OAM is a member of the Investment Trusts Association, Japan, which is a personal information protection organization authorized based on the Act on the Protection of Personal Information. The Investment Trusts Association, Japan handles complaints regarding the handling of personal information of its members.

The Investment Trusts Association, Japan, Investor Consultation Office
(TEL:+81-3-5614-8440)

Changes to this policy:
This policy may be updated. The date on which this policy was most recently updated is noted below.
Last updated : April 1, 2022

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