Privacy Policy

MCUBS MidCity Inc. (the "Company") understands the importance of the protection of personal information. In handling personal information and specific personal information (the "Personal Information, etc."), the Company is committed to ensuring compliance with the "Act on the Protection of Personal Information" (Act No. 57 of 2003, as amended; the "Personal Information Protection Act"), the "Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures" (Act No. 27 of 2013, as amended; the "My Number Act") and other laws and regulations/guidelines, internal rules, and this policy, and will strive to properly handle, manage and protect the Personal Information, etc.
In addition, the Company will make efforts to continue to review and improve the system for the protection of personal information.

I. Policy of efforts to protect personal information

1. Acquisition

(1) Proper acquisition
The Company will acquire the Personal Information, etc. by proper and legitimate means to the extent necessary for its business, and will not acquire the same through deception or other wrongful means.

(2) Acquisition of an individual number
Notwithstanding the provisions of the preceding item, the Company may only request that the relevant person or other persons in charge of affairs related to individual number provide the individual number when it is necessary to process affairs set forth in II.2 below. The Company will also request the provision of individual number when it becomes necessary to process such affairs or when such affairs can be expected to arise.

(3) Personal identification
In receiving the provision of an individual number, the Company will verify the identity of the relevant person in the manner stipulated in Article 16 of the My Number Act. With respect to agents, the Company will verify the identity of such agents, and confirm the power of attorney and the individual number of the relevant person in such manners as stipulated in said Article.

2. Use

(1) Restriction by purpose of use
Except as permitted by laws and regulations, the Company will not handle personal information acquired beyond the scope of the purposes of use specified in II.1 below without the prior consent of the relevant person.

(2) Use of specific personal information
Notwithstanding the provisions of the preceding paragraph, the Company will not use the specific personal information acquired, regardless of whether the consent of the relevant person is obtained, beyond the scope of the purposes of use set forth in II.2 below except for cases where it is necessary for the protection of the life, body or property of an individual in which the consent of the relevant person is obtained or in which it is difficult to obtain the consent of the relevant person.

3. Handling of Personal Information, etc.

In storing and using Personal Information, etc., the Company will make efforts to keep it accurate and updated, store and use it to the minimum extent necessary in accordance with the purpose of use, and delete the personal data containing such Personal Information, etc. promptly after such utilization of such personal data has become unnecessary.

4. Notice of Purpose of Use / Disclosure / Correction, etc. / Suspension of Use / Suspension of Provision to a Third Party.

If the Company receives a request from the relevant person for notice of the purpose of use of retained personal data; disclosure of retained personal data; correction, addition, or removal("correction, etc.") of retained personal data; suspension of use or deletion (“suspension of use, etc.”) of the retained personal data or suspension of provision to a third party of retained personal data pertaining to the relevant person, it will make efforts to respond to such request in an appropriate and prompt manner after verifying the identity of the relevant person. For details, please contact the consultation desk set forth in IV below.

5. Management of Personal Information, etc.

The Company will take necessary and appropriate measures for the prevention of leakage, loss or damage of Personal Information, etc. it handles and for other safe management of Personal Information, etc.

6. Supervision of contractor

The Company may from time to time outsource all or part of the handling of the Personal Information, etc. only to the extent necessary to achieve the purposes of use. In such case, the Company will, in selecting a contractor, confirm that the contractor's personal information protection system conforms to the standards of the "Guidelines for Protection of Personal Information in the Financial Sector," "Practical Guidelines on Safety Management Measures, etc. of the Guidelines for Protection of Personal Information in the Financial Sector" and "Guidelines for Proper Handling of Specific Personal Information for Financial Operations" (collectively, the "Guidelines, etc. in the Financial Sector"), and also undertake measures in consideration of the protection of personal information pursuant to the Guidelines, etc. in the Financial Sector such as executing contracts with the contractor in accordance with the Guidelines, etc. in the Financial Sector, as well as exercising necessary and appropriate supervision of the contractor.

7. Appropriate efforts to process complaints

If the Company receives any complaints about the handling of acquired Personal Information, etc., it will investigate the details in order to deal with them in an appropriate manner within a reasonable period of time.

II. Purposes of Use of Personal Information, etc.

1. Purposes of use of personal information

Except as provided by laws and regulations, the Company will use personal information only to the extent necessary to achieve the purposes of use set forth below. In acquiring personal information, if the Company further limits and notifies the purposes of use set forth below, it will use personal information only to the extent necessary to achieve such purposes of use.

(1) Personal information related to the financial instruments business of the Company

  1. Exercise of rights of holders of securities issued by the investment corporation (the "Entrusting Investment Corporation") which entrusts asset investment to the Company pursuant to the Act on Investment Trusts and Investment Corporations (Act No. 198 of 1948, as amended; the "Investment Trusts Act") and performance of obligations of the Entrusting Investment Corporation, and implementation of other measures to facilitate the relationship between the Entrusting Investment Corporation and investors who are its members;
  2. Preparation and filing of various kinds of reports of the Entrusting Investment Corporation pursuant to the Financial Instruments and Exchange Act (Act No. 25 of 1948, as amended), Investment Trusts Act, the Companies Act (Act No. 86 of 2005, as amended) and other related laws and regulations, and management of information pertaining to investors of the Entrusting Investment Corporation;
  3. Response to inquiries and requests for materials regarding issuance of investment corporation bonds and additional issuance of investment units by the Entrusting Investment Corporation and securities issued by the Entrusting Investment Corporation;
  4. Acquisition, disposition of assets under management and lease of assets under management by the Entrusting Investment Corporation, and implementation of various kinds of operations such as examination and review thereof;
  5. Collection of rents and refund of security deposits by the Entrusting Investment Corporation and implementation of other business operations related to lease of assets under management;
  6. Performance of various kinds of business operations associated with research and study, collection and analysis of information, provision of information necessary for asset investment (including financing by the Entrusting Investment Corporation carried out as part of asset investment) with which the Company has been entrusted; and
  7. Implementation of other financial instruments businesses of the Company or businesses related or incidental thereto.

(2) Personal information related to employment management

  1. Process for employment;
  2. Determination and payment of remuneration:
  3. Personnel evaluation, determination of assignment, and other personnel management;
  4. Employee training;
  5. Social insurance and employment insurance related procedures;
  6. Provision of employee benefits and welfare;
  7. Ensuring of healthy working conditions and healthcare;
  8. Business communication, emergency communication, mailing of documents, etc.;
  9. Disclosure of history;
  10. Procedures for self-education support;
  11. Various procedures required under laws and regulations;
  12. Various communications and procedures after retirement; and
  13. Other procedures necessary for employment management and performance of business.

(3) Personal information related to other businesses of the Company

  1. Exercise of rights or performance of obligations by the Company's shareholders under laws and regulations, provision of favors by the Company to the status of shareholder, implementation of various kinds of measures to facilitate the relationship with shareholders, preparation of shareholder data based on the prescribed standards pursuant to various laws and regulations and other management of shareholders;
  2. Employment screening; and
  3. Implementation of general affairs associated with corporate activities of the Company or the Entrusting Investment Corporation and other businesses related or incidental thereto.

2. Purpose of use of individual number

Notwithstanding the provisions of the preceding paragraph, the purposes of use of individual numbers by the Company are as follows:

(1) Specific personal information, etc. of customers, clients and shareholders

  1. Preparation of payment records for remuneration and fees, etc. pursuant to the Income Tax Act;
  2. Preparation of payment records for dividends, distributions of surplus and interest on funds pursuant to the Income Tax Act;
  3. Preparation of payment records for rents on real estate, etc. pursuant to the Income Tax Act;
  4. Preparation of payment records for consideration of acquisition of real estate, etc. pursuant to the Income Tax Act; and
  5. Other affairs related to a. through d. above and preparation affairs of legal records for which description of an individual number is required by the provisions of laws and regulations.

(2) Specific personal information, etc. of the Company's officers and employees and their relatives

  1. Affairs related to withholding conducted by an employer pursuant to the Income Tax Act;
  2. Affairs related to individual inhabitants tax conducted by an employer pursuant to the Local Tax Act;
  3. Affairs related to employment insurance conducted by an employer pursuant to the Employment Insurance Act;
  4. Affairs related to health insurance conducted by an employer pursuant to the Health Insurance Act (application and benefits);
  5. Affairs related to social pension insurance conducted by an employer pursuant to the Social Pension Insurance Act (application); and
  6. Other affairs related to a. through e. above and preparation affairs of legal records, etc. for which description of an individual number is required by the provisions of laws and regulations.

III. Disclosure/Provision of Personal Information, etc. to Third Parties

1. Disclosure/provision of personal data to third parties

As a rule, the Company will not disclose any acquired personal data to any third party unless:

  1. the written consent of the relevant person is obtained;
  2. such disclosure is required by laws and regulations;
  3. such disclosure is necessary for the protection of the life, body or property of an individual, in which it is difficult to obtain the consent of the relevant person;
  4. such disclosure is necessary for improving public health or protecting the sound growth of children, in which it is difficult to obtain the consent of the relevant person; or
  5. such disclosure is necessary for national government organs or local governments or their delegated persons to perform tasks provided by laws and regulations, in which obtaining the consent of the relevant person is likely to interfere with the performance of such tasks.

2. Disclosure/provision of specific personal information to third parties

Notwithstanding the provisions of the preceding paragraph, the Company will not provide specific personal information to any third party (meaning the transfer of specific personal information outside of the legal entity, and the transfer of specific personal information within the same legal entity such as transfer within the same corporation is not applicable) regardless of whether the consent of the relevant person is obtained, except for the cases set out in each item of Article 19 of the My Number Act.

IV. Consultation Desk for Handling of Personal Information, etc.

Please contact the below with any inquiries regarding a request of notice of the purpose of use, a demand of disclosure, correction, etc., the suspension of use, etc., or the suspension of provision to a third party as well as complaints, etc. regarding the handling of Personal Information, etc. of the Company:

MCUBS MidCity Inc.
Address: 2-7-3, Marunouchi, Chiyoda-ku, Tokyo
Telephone: 03-5293-4150
Reception hours: 9:15 - 17:30
(excluding Saturdays, Sundays and public holidays, and holidays designated by the Company)

With respect to the correction, addition, removal of matters stated in the investors' registry, please contact the administrator of the investors' registry.

Stock Transfer Agency Department, Mitsubishi UFJ Trust and Banking Corporation
Address: 7-10-11, Higashisuna, Koto-ku, Tokyo
Telephone: 0120-232-711 (Toll-free)

In addition, the Company is a member of The Investment Trusts Association, Japan, a recognized personal information protection organization recognized under the Personal Information Protection Act.
The said Association accepts consultation/complaints, etc. about handing of personal information of a member company.

Investors Consultation Office, The Investment Trusts Association, Japan
Telephone: 03-5614-8440

V. Revision of this Policy

This policy is subject to revision to improve the personal information protection system, or based upon changes, etc. to laws and regulations.

Date of Revision: May 30, 2017