Aetos Japan, LLC, Japan Branch (hereinafter “the Company”) will comply with the “Act on the Protection of Personal Information” (Act No. 57 of 2003, as amended, hereinafter, “Personal Information Protection Act”) and its related laws, ordinances, and guidelines of supervisory authorities, and disclose our privacy policy as follows.

  1. Reasonable Acquisition of Personal Information
    The Company will obtain and use personal information required for execution of business in a manner appropriate and just, within the scope of the objective to be achieved, and will not obtain personal information through falsification or other unjust means.
  2. Prohibition on Use Other than for Intended Purposes
    The Company will use personal information within the scope necessary to achieve the intended purpose.Regarding intended purposes, please refer to “Other Matters Disclosed under the Act on the Protection of Personal Information 1.”. The intended purpose can be modified within the scope reasonably deemed as being related and will be disclosed in such cases.
  3. Disclosure Procedures
    The Company will respond quickly to any requests to disclose, amend, delete, suspend use of an individual’s personal data in possession. Procedure for disclosure, amendment, elimination, and suspension of use with regards to personal data in possession by the Company, if disclosure, amendment, elimination, or suspension of use is requested, please first contact the Company’s management or the point of contact listed in “4. Contact Information for Inquiries regarding the Handling of Personal Data in Possession”. The Company will provide information on documents (such as documents to verify identity of the requester) to be prepared. Once identity is confirmed, the Company will respond as soon as possible upon investigation.
  4. Contact Information for Inquiries regarding the Handling of Personal Data in Possession
    Please contact the following for any inquiries regarding the Company’s handling of personal data in possession.
    Aetos Japan, LLC Corporate Services Division, Legal and Compliance
    16F Mita Kokusai Building, 1-4-28 Mita, Minato-ku, Tokyo, 108-0073
    Phone: 03-6275-1950
    (Business Hours: Monday – Friday 9:00 – 17:00)

Basic Policy concerning Safety Management of Personal Data

    1. Name of Business Operator Handling Personal Information and its representative Aetos Japan, LLC, Japan Branch
      Takayuki Kobayashi, Representative in Japan
    2. Contact Information for Inquiries and Complaints regarding Safety Management Measures
      Please refer to “4. Contact Information for Inquiries regarding the Handling of Personal Data in Possession” above.
    3. Safety Management Measures of Personal Data
      The Company will enforce the following safety management measures to prevent leakage, loss, or damage of personal data.

      1. Organizational safety management measures: (i) clarify employee roles and responsibilities related to information management; (ii) formulate and implement internal regulations concerning safety management; (iii) inspect/audit implementation status of internal regulations.
      2. Personnel safety management measures: (i) execute non-disclosure contracts with employees; (ii) provide continuous education/training for employees, and create an employee supervisory structure.
      3. Physical safety management measures: (i) manage entrance / exit using IC card keys; (ii) keep documents with personal data under lock and key.
      4. Technical safety management measures: (i) establish access controls on information systems handling personal data; (ii) monitor information systems; (iii) protect personal data by passwords.
      5. Understanding the external environment (i) implement safety management measures based on an understanding of the personal information system in foreign countries where the Company stores personal data.
        Furthermore, when outsourcing personal data, the Company will appropriately supervise the outsourcing company in compliance with related laws, ordinances and guidelines of supervisory authorities.
    4. Continuous Improvement of Basic Policy concerning Safety Management Measures
      The Company will review the basic policy according to revisions to the law, and changes in social environment/business, and commit to the appropriate management of personal data.
    5. Compliance with Related Laws, Ordinances and Guidelines
      The Company will comply with the “Personal Information Protection Act” and its related laws, ordinances, and guidelines of supervisory authorities and commit to appropriately managing and protecting the personal data in its possession.

Other Matters Disclosed under the Personal Information Protection Act
Matters disclosed under the Personal Information Protection Act is as follows.

  1. Intended Purpose
    The company will obtain and use personal information within the scope necessary to accomplish the intended purpose listed below.

    1. With regards to type 2 financial instruments business/investment advisory business/personal investment for real estate related investments, to purchase (including consideration of purchase)/ manage/dispose (including consideration of disposition) assets for investment, and to introduce/provide various services incidental or related, and to conduct business related to these transactions.
    2. To exercise rights and perform duties in compliance with contracts and laws and ordinances, as necessary for 1. above.
    3. To adequately and smoothly execute the Company’s business related to 1.2 above.
    4. To manage employment and hiring practices of the Company.
    5. To provide to a third party within the scope necessary to appropriately execute business, in compliance with contracts and laws and ordinances, as related to 1. to 4.  above.
  2. Matters regarding the Provision of Personal Information to Third Parties
    The Company will not provide personal information to a third party without the consent of the person concerned (including cases where consent of the person concerned can be assumed from the actual circumstances of the transaction) or as otherwise stipulated by law and regulation. Furthermore, information considered sensitive under the guidelines of personal information protection in the financial sector, unless recognized by law and such guidelines, will not be provided to a third party. However, if the handling of personal data is outsourced, for the succession (or consideration for succession) of the real estate rental business of the investment assets, where legally, it is not considered a provision to a third party, within the scope necessary to accomplish the intended purposes outlined in “1. Intended Purpose”, personal data can be provided to the outsourcing company, successor (including prospective successor), or other legally recognized party.
  3. Matters regarding Shared Use of Personal Data
    The Company could share the use of personal data obtained with specific entities, for the following reasons.

    1. Items of personal data to be shared
      • For real estate related investments, (i) name, address, sex, birthdate, age, telephone number, email address, name of employer, address of employer, work telephone number, employer industry type, income, relationship with tenant; (ii) fulfillment of rental agreement; (iii) other personal data provided to conduct real estate related investment transactions and customs.
      • For the management of employees and hiring practices, (i) name of applicable person, address, birthdate, area of employment, sex, age, contact information, and payment status of salary and taxes.
    2. Entity to be shared with
      The Company’s parent company, Aetos Capital Real Estate LP.
    3. Intended purpose of user
      Please refer to “1. Intended Purpose”.
    4. Responsibility for management of personal data to be shared
      The Company.