Privacy Policy

1. Basic Policy

Starts Asset Management Company (“the Company”) shall comply with the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003; the “Personal Information Protection Act”), other related laws and regulations as well as guidelines by competent government agencies, etc. with understanding of importance of appropriate handling of personal information.

2. Collection of Personal Information

Personal information shall be obtained by lawful and fair means to the extent required for business purposes. The Company will also clarify in advance the purposes of using personal information, in the event that it acquires personal information of a customer through documents or website, etc. However, the clarification of purposes of use may be omitted in the event that the purpose of use is clear judging from the situation at the time of obtaining said information, or in the event that it is acceptable by laws and ordinances, etc.

3. Maintenance of the Accuracy and Security Control Measures
on Personal Information

The Company shall endeavor to maintain the obtained personal information accurate and to have the latest contents within the scope necessary for the achievement of the purpose of use. In addition, the Company shall take appropriate and rational security control measures for the prevention of loss, damage, falsification, leakage, etc. of personal information.

4. Purpose of Use of Personal Information

The Company shall use the obtained personal information only for the following purposes except for cases permitted under laws and regulations. In the event the necessity to use the personal information beyond the scope of the following purposes arises, the Company shall obtain the consent of the individual.

(1) To exercise the rights of the unitholders of Starts Proceed Investment Corporation (“Starts Proceed”), who entrusts its asset management to the Company, and to fulfill Starts Proceed’s obligations based on the stipulations in the Act on Investment Trusts and Investment Corporations (“the Act”), the Companies Act and other related laws and regulations.
(2) To notify the unitholders of Starts Proceed of information regarding its business and to provide other various services.
(3) To facilitate interaction between unitholders and Starts Proceed.
(4) To make unitholders’ data and manage unitholders’ information.
(5) To perform surveys related to the acquisition, sale, leasing, etc. of assets under management concerning asset management to be conducted for Starts Proceed and consideration of such.
(6) To facilitate fund procurement (borrowing of funds, issuance of investment corporation bonds and subsequent issuance of investment units) by Starts Proceed.
(7) To facilitate the rent businesses of the management properties by Starts Proceed.
(8) To appropriately and smoothly perform business operations related or incidental to the businesses conducted by the Company and Starts Proceed other than the above.

5. Sharing of Personal Information

Personal information shall be shared for use as follows:

(1) Items of personal information that shall be shared for use Name, age, address, gender, place of work and phone number
(2) Scope of users to be shared with for use Group companies of Starts Asset Management Company. However, use of personal information of unitholders shall be limited to the Company and Starts Proceed.
(3) Purpose of use of users to be shared with for use
For the purposes mentioned above in 4. (5) and (7), and to perform duties of Starts Proceed and duties incidental or related to such in an appropriate and smooth manner.
(4) Management representative Starts Asset Management Co., Ltd.

6. Supervision of Contracted Service Providers

The Company may entrust a third party(ies) with the handling in whole or in part of the obtained personal information, within the scope necessary to achieve the purposes of use. In the event of such entrustment in whole or in part of the obtained personal information, the Company shall appropriately select an entrusted third party(ies) along with exercising necessary and appropriate supervision over the entrusted party(ies), to ensure the control of security of the personal information.

7. Provision and Disclosure of Personal Information to Third Parties

The Company shall not provide personal information to any third party without prior consent of the person concerned, except when permitted under the Personal Information Protection Act and other laws and regulations.

8. Disclosure of Personal Information to the Individuals

When the Company receives requests to disclose personal information it retains from the individual of the personal information, the Company shall promptly disclose the concerned personal information it retains to the individual. However, the Company may not disclose such in whole or in part in the event the disclosure falls under any of the following. In the event of such, the Company shall promptly notify such circumstances to the individual.

(1) In the event the disclosure could potentially cause harm to the life, body, property or other rights and interests of the individual or a third party(ies).
(2) In the event the disclosure could potentially cause significant harm to the proper implementation of duties of the Company or Starts Proceed.
(3) In the event the disclosure could violate laws and regulations.

9. Procedures of Requests for Disclosure, Correction
or Discontinuance of Utilization of Personal Information

Concerning requests for disclosure, correction or discontinuance of utilization of personal information (collectively referred to as “Disclosure, etc.”) retained by the Company, please contact the inquiries office mentioned in 10. (1) below. The Company shall provide details of prescribed procedures necessary for the Disclosure, etc. Furthermore, please note in advance that the Company charges prescribed fees for the request to disclose personal information retained by the Company.

10. Inquiries of Personal Information

(1) Please contact our inquiries office as indicated below if you have any inquiries regarding this Privacy Policy.

Company: Starts Asset Management Co., Ltd.
Address: 3-1-8 Nihonbashi, Chuo-ku, Tokyo
Phone: +81-3-6202-0856

http://www.starts.co.jp/asset/

(2) The Company is a member of The Investment Trusts Association, Japan, which has been recognized as a Personal Information Protection Organization by the Financial Services Agency. The Investors Consultation Office of The Investment Trusts Association, Japan accepts complaints and provides consultation on the handling of personal information by member companies.

Investor Consultation Section, The Investment Trust Association, Japan
Phone: +81-3-5614-8440

(3) For inquiries regarding the Unitholders’ Register, please contact the Administrator for Unitholders’ Register for Starts Proceed.

Company: Stock Transfer Agency Department, Sumitomo Mitsui Trust Bank, Limited
Phone: 0120-782-031 (toll free, Japan only)
Business hours: 9:00am to 5:00pm Japan time (excluding weekends, national holidays and year end/year beginning holidays)

11. Continuous Improvement of Personal Information Protection System

The Company shall periodically review this privacy policy to improve its efforts on the protection of personal information.

12. Revision of Personal Information Protection System

The Company may revise this privacy policy in association with revisions to related laws and regulations, and for the improvement of the personal information protection structure.