Personal Information Protection Policy

Basic Policy

We shall comply with the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003), related laws and regulations, guidelines, internal rules, etc., and shall strive for appropriate and safe management and operation of the Company's personal information.

Purpose of Use of Personal Information

Purpose of use of personal information

The personal information that we collect is mainly used by investment corporations, including Hoosiers PRIVATE REIT Investment Corporation, for which we are entrusted with the management of assets and real estate funds, etc. other than Investment Corporations (including, but not limited to, special purpose companies and other forms of corporations, partnerships, trustees, etc. that are investment vehicles) (hereinafter referred to as " hereinafter referred to as "the Investment Corporations, etc.").
Personal information of holders of the securities issued by the Investment Corporation, etc., borrowers of the assets managed by the Investment Corporation, etc., and other business partners of the Investment Corporation, etc.
The purposes of our use of personal information are as follows

To fulfill obligations of the Investment Corporation, etc., to holders of securities issued by the Investment Corporation, etc.
To implement measures to facilitate relationships with unitholders or investors of the Investment Corporations, etc.
To prepare registers of the Investment Corporations, etc., and to prepare various reports required by laws and regulations, and to manage information of unitholders and investors
To accumulate data, statistics, and analysis to provide certain information to those who are considering the purchase of securities issued by the Investment Corporations, etc., in the event of additional issuance of investment units or other equity interests of the Investment Corporations, etc., and to provide certain information to those who are considering the purchase of securities issued by the Investment Corporations, etc.,
To accumulate and analyze data related to the acquisition of assets under management by the Investment Corporations, etc., to conduct surveys and examinations related to acquisitions, to solicit sellers, and to facilitate sales activities.
To properly conduct the leasing business of the assets under management of the Investment Corporations, etc.(including the use of questionnaires, etc. to enhance the convenience of users of the assets under management of the Investment Corporations, etc.)
To request lawyers, certified public accountants, real estate appraisers, judicial scriveners, land and house investigators, and other professionals to perform services for the Investment Corporations, etc.
To borrow funds or issue additional investment units or other equity interests for the acquisition and management of assets of the Investment Corporations, etc.
To execute contracts and provide information and services relating to advisory services for investments, etc. (i.e., consultation services relating to investments or effective utilization of assets, etc.)
To analyze customer trends, develop products, assess prices, and conduct other research and analysis to provide the information and services described in (5), (6), (7), and (9) above
For sales and marketing activities such as visits, sending mail, solicitation by telephone, fax, e-mail, etc., for the provision of information and services in (5), (6), (7), and (9) above
To keep books and documents by Article 49 of the Building Lots and Buildings Transaction Business Law and Article 47 of the Financial Instruments and Exchange Law (obligation to keep books and documents)
To provide personal information to a third party when it is used as the "basis for an opinion" under Article 34-2, Paragraph 2 of the Building Lots and Buildings Transaction Business Law.
To select employees for recruitment to the Company's board of directors, employees, etc.
For operations incidental to the businesses and affairs described in (5), (6), (7), (9), and (14) above
To properly and smoothly execute other business of the Company or its customers
To provide personal information to third parties to the extent necessary to achieve the above purposes of use

Purpose of use of sensitive personal information

We will use sensitive personal information for the following purposes

To fulfill obligations stipulated by law for labor management
When necessary to protect the life, body, or property of an employee
To use the information for the reasons stipulated in the Personal Information Protection Law in other cases where the acquisition of sensitive personal information is permitted without the consent of the individual concerned.

To carry out asset management operations for the Investment Corporations, etc., we shall use personal information only to the extent necessary to achieve the above purposes of use, and shall not use personal information for any other purposes. We shall not change the purpose of use of personal information beyond the scope that is reasonably considered to be relevant to the purpose of use before the change.

Acquisition of Personal Information

Personal information shall be acquired by legal and fair means to the extent necessary to achieve the purpose of use.
Before acquiring personal information on our own or from property management companies, etc. that manage the assets of investment corporations or private funds, etc., we shall publicly announce the purpose of use on our website, etc., and shall use contracts and other documents (electromagnetic records (electromagnetic methods). The same shall apply hereinafter.) upon entering into a contract with the person in question.
In cases where we obtains personal information from an individual as described in the "Personal Information Protection Law" (Law No. 25 of 1948, as amended; hereinafter the same shall apply), or when we obtains personal information directly from the individual in writing, the purpose of use of the personal information shall be indicated in advance.
However, when the purpose of use is clear from the circumstances at the time the information is provided, or when permitted by law, we may omit specifying the purpose of use.

2. Acquisition of personal information requiring special consideration

Personal information requiring special consideration shall be acquired by lawful and fair means to the extent necessary to achieve the purpose of use with the consent of the individual concerned.

Provision to Third Parties

Provision of Personal Data to Third Parties

Personal data will not be provided to third parties without the consent of the individual, except as required by law.

Provision of Personal Information to Third Parties

Personal information requiring special consideration will not be provided to third parties without the consent of the individual concerned, except as required by law.

Ensuring Accuracy

We will keep personal data accurate and up-to-date to the extent necessary to achieve the purpose of use.
We will endeavor to delete personal data without delay when there is no longer a need to use such personal data.

Safety Control Measures

We will manage personal data appropriately and securely, and will not allow unauthorized access to personal data from outside or any unauthorized use of such data.
Necessary and appropriate measures will be taken to prevent use, loss, destruction, alteration, or leakage.

Entrustment of Personal Data Handling

There are cases in which we may outsource the handling of personal data held by us.
When outsourcing all or part of the handling of personal data to an outside contractor, we will carefully select the contractor and conclude an outsourcing agreement with the contractor on the condition that the contractor has established and implemented a management system to appropriately protect personal data.
In addition, we will exercise necessary and appropriate supervision over the subcontractor to ensure the safe management of personal data.

Continuous Improvement

We will establish internal rules and regulations concerning personal information, including this Personal Information Protection Policy, and continuously review and improve them.
In addition, we may revise this Privacy Policy as necessary due to legal amendments or other reasons.

Response to applications and requests for notification of purpose of use, disclosure, correction, etc., suspension of use, etc., or suspension of provision to third parties of retained personal data

you may make an application or request to the contact point of the Company on notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, or deletion of your retained personal data to the Company, suspension of use, deletion, or cessation of provision to third parties.
In such cases, we will respond within a reasonable period after confirming the identity of the applicant/claimant (e.g., by submitting a copy of a driver's license) .
In the case of a proxy, we will respond within a reasonable period upon confirmation of the proxy's identity.

Questions regarding the contents of this Privacy Policy should also be directed to our contact person.

Inquiry contact

Name	Hoosiers Capital Management,. Business Administration Department,
Address	10F Marunouchi-Nakadori Bldg, 2-2-3 Marunouchi, Chiyoda-ku, Tokyo 100-0005, Japan
Phone	03-3243-8118
Hours	Weekdays 9:00-12:00, 13:00-18:00 (except Saturdays, Sundays, national holidays and our designated holidays)

We are an authorized personal information protection organization, and we also accept complaints and consultations regarding personal information at the following contact point.

Authorized Personal Information Protection Organization

Name	The Investment Trusts Association, Japan
Phone	03-5614-8440
Hours	Weekdays 9:00-11:30, 12:30-17:00 (except Saturdays, Sundays, national holidays, and holidays designated by the association)
Name	Japan Investment Advisers Association
Phone	03-3663-0505
Hours	9:00 - 17:00 (except Saturdays, Sundays, national holidays, and holidays designated by the Association)