Privacy Policy

Invincible Investment Corporation ("INV") acknowledges the importance of personal information and complies with the Act on the Protection of Personal Information (the "Personal Information Protection Act") and other laws and regulations regarding the protection of personal information as well as the Investment Trusts Association, Japan's policy and guideline for protecting personal information with respect to handling any personal information collected. INV has established the policy of protecting personal information set out below to handle, protect and manage personal information in an appropriate manner.

INV is constantly reviewing and improving the personal information protection policy.

Unless otherwise defined in this privacy policy, terms used in the policy refer to meaning defined in the Personal Information Protection Act and other laws, regulations and guidelines regarding the protection of personal information.

1．Appropriate Handling of Personal Information

Based on the Act on Investment Trusts and Investment Corporations ("Investment Trusts Act"), INV has established "regulations on managing personal information" at its asset management company, Consonant Investment Management Co., Ltd. ("CSNT" ), which is entrusted with the management of the assets of INV. Officers and employees of CSNT are required to sign a pledge of confidentiality and the employees of CSNT (this refers to parties who are employed at CSNT including temporary personnel) and other concerned parties are kept thoroughly informed through training and daily supervision.

2. Purpose of Use of Personal Information

With the exception of cases subject to laws and regulations, INV uses personal information to the extent necessary to achieve the objectives set forth below.
When the purpose of use of personal information changes, the change is subject to the Personal Information Protect Act and reasonably considered to be within the scope fairly correlated with the purpose of use prior to the change. Moreover, the purpose of use following the change is publicly disclosed.

1. To exercise the rights of its unitholders and to carry out INV's duties based on the Investment Trusts Act, the Companies Act and other related laws and regulations by sending out its asset management reports, information about unitholder meetings, and by paying distribution.
2. To notify unitholders of information about INV's business.
3. To draft and present all manner of reports about INV based on the Act on Investment Trust and Corporations, the Companies Act and other related laws and the regulations of the financial instruments exchange.
4. To contact customers and to respond to customer inquiries, requests for reference materials or else.
5. To provide information and collect attendance data for INV's financial briefings, performance report meetings and other meetings arranged by CSNT.
6. To borrow funds, to issue investment corporation bonds and to additionally issue investment units.
7. To conduct checks related to the acquisition and sale of managed assets (including title rights checks and credit checks of the seller, tenant and buyer of managed assets).
8. To conduct registration procedures for the acquisition or sale of managed assets.
9. To determine the credit status of leaseholders or the parties who are considering leasing of managed assets.
10. To manage the receipt of rental payments, the return of deposits and other work related to the leasing and management of managed assets.
11. To carry out accounting, tax practices and other business related to the closing of accounts for INV.
12. To request contracts for damage insurance covering managed assets.
13. To notify and contact the leaseholder of the managed asset in order to carry out repairs or renovation of the managed asset, and to respond to requests from the leaseholder to INV for repairs to the managed asset.
14. To request the advice or services of specialists (attorneys, certified public accountants, certified tax accountants, real estate appraisers, judicial clerks and others) in order to achieve the purpose stated above.
15. To provide third parties with documentation including personal information in order to undertake the collaborative work needed to achieve the purpose stated above.
16. To carry out the business of INV in an effortless and appropriate way as well as any business related to paragraphs 1 through 15 above.

3. Appropriate Collection of Personal Information

INV shall collect personal information only when necessary for business reasons and within the scope necessary. In addition, personal information will be collected through legitimate and fair means, and deceitful or unfair means will not be used.
INV will not collect special care-required personal information without obtaining the consent of the individual concerned, with the exception of cases provided by laws and regulations; nor will it collect sensitive information (as defined in the Guidelines for Personal Information Protection in the Financial Field (the "Guidelines in Financial Field"), with the exception of cases provided by the Guidelines in Financial Field.
If personal information is handled in a way that exceeds the scope necessary to achieve the purpose of use, the consent of the individual shall be obtained except when the case is determined by the Personal Information Protection Act.

Personal information collected by INV

Specific personal information collected by INV is set forth below:

1.

Unitholders or parties who are considering the purchase of securities issued by INV
If an individual unitholder is included among the top 20 unitholders in INV's register of unitholders, the register of unitholders provided by the Administrator will be consulted to collect information such as name, address and number of units for the relevant unitholder.
In some cases, the name, address, telephone number and other information of persons considering the purchase of securities issued by INV may be collected in connection with direct enquiries from the securities company that handles securities issued by INV or from the individual concerned.
Moreover, name, address and other information may be collected for the purposes of use explained in clauses 1, 2, 5 and 6 of Section 2 above.

2.

Partners involved in the purchase and sale of managed assets of INV, prospective partners and other parties involved in purchase and sale
If the party concerned is an individual, personal information for the purposes of use stated in clauses 7 and 8 of Section 2 above, including name and address, may be collected from a copy of the registry or the seal registration certificate collected as proof of identity when concluding a contract for the purchase or sale of a managed asset.
Moreover, the name and address or other personal information of adjacent proprietors may be collected for the purpose of verifying boundaries.

3.

Parties who are leaseholders or parties who are considering leasing of managed assets of INV
If the customer concerned is an individual, information such as name, address, telephone number,
employment and income for the purposes of use stated in clause 9 of Section 2 above will be collected from the real estate management company in charge of managing the property, or from the real estate transaction specialist who represents the leaseholder of the managed asset. In addition, the same information will be collected from the guarantor of the customer.
In the case of a tenant of a managed asset, rental management information such as property name, apartment number, name, total receipts, unpaid receipts and other personal information will be collected from the real estate management company for the purpose of use stated in clauses 10 and 11 in Section 2 above.
In addition, for the purpose of use stated in clause 13 of Section 2 above (to respond to requests for repairs or renovation), personal information such as property name, apartment number, name and telephone number may be collected from the real estate management company.
There may be other cases when personal information about the customer concerned or relevant parties may be collected in order to carry out other related business transactions.

4.

Other parties relevant to INV's business performance
In addition, there may be cases when personal information such as a name, address, telephone number, employment information or official position is collected in connection with the business transactions of INV or for the purposes of use stated in Section 2 above.
Personal information such as name, address or telephone number may be collected as contact details in case of enquiries or complaints.

Handling of Sensitive Information

INV shall not collect, use, or provide to third parties sensitive information with the exception of the cases provided by the Guidelines in Financial Field.
With reference to clauses 2, 3 and 4 of "Personal information collected by INV," if a permanent domicile or other information is recorded on a driver's license that is photocopied as proof of identity, such information is deleted by blacking out or other means at the time of receiving the document, and the information is not collected or retained.

4. Provision of Personal Data to Third Parties

INV will not provide collected personal data to third parties with the exception of the cases set forth below. Furthermore, INV will not provide sensitive information to third parties with the exception of the cases provided by the Guidelines in Financial Field.

Cases in which personal data are provided to third parties

1. When the consent of the individual concerned has been obtained
2. When such disclosure or provision is required by laws and regulations
3. When necessary to protect life, health or property, and when it is difficult to obtain prior consent from the individual concerned
4. When necessary to cooperate with organizations of the state or local authorities or their consignees who are carrying out tasks designated by laws and regulations, and obtaining the individual's consent is likely to impede the performance of the affairs

However, INV may disclose or provide personal data to the following parties other than INV if such is not regarded as provision to third parties under the Personal Information Protection Act, including cases when providing the personal data in line with consigning the handling of all or part of personal data within the scope necessary to achieve the purpose of use.

Parties other than INV to which personal data may be provided

1. CSNT
2. Securities companies which engage in offering of investment securities of INV, securities companies or trust companies which administer the register of unitholders
3. Judicial scrivener and real estate surveyors involved in registration
4. Real estate management companies
5. Contractors who undertake back-office tasks related to the accounting services of INV
6. Specialists such as attorneys, certified public accountants, certified tax accountants or real estate appraisers who undertake professional advice and services for INV
7. Other subcontractors who work under the required and appropriate supervision of INV within the scope necessary for achieving the purpose of use.

5. Proper Management and Accurate Retention of Personal Information

To prevent personal data leakage, loss or disadvantage, or to otherwise safely manage personal data, INV takes steps to ensure CSNT has in place measures such as those for improvement of rules for data handling, persons in charge of handling personal information assignment, access management, limits on taking information out of the office, measures to prevent fraudulent access by external parties and other safety management systems or security measures set-up. In addition, INV endeavors to provide information that is accurate and up to date as needed to achieve the purpose of use.
In addition, when entrusting the handling of personal information to third parties as a consequence of subcontracting, INV will verify the systems for protecting personal information at the subcontractor, and take action to protect personal information during the term of the contract as well as to provide appropriate supervision of the subcontractor.

6. Disclosure, Correction and Discontinuance of Use of Personal Information

Based on the Personal Information Protection Act and other related laws and regulations, the individual concerned (or a representative) may submit a request according to the procedures below to INV for the disclosure, notification of purpose of use, correction (correction, addition or deletion), discontinuance of use, or discontinuance of provision to third parties of any personal data about the individual held by INV. A request for correction (correction, addition or deletion) may be made if the contents of the information held by INV are not factual.
A request for the discontinuance of use (discontinuance or cancellation) can be submitted if INV exceeds the limits of the purpose of use when handling retained personal data, or if the retained personal data has been collected by inappropriate means.
A request to discontinue the provision of information to third parties can be submitted if INV has provided retained personal data to third parties without obtaining the consent of the individual concerned.
Kindly note that when the conditions below apply, INV may be unable to reply in full or in part to the request.

Cases when INV may be unable to reply in full or in part to a request.

Disclosure

• When there is risk of damage to the life, health, property or other rights and interests of the individual concerned or a third party
• When there is risk of exceptional damage to the proper operation of INV
• When a violation of laws or regulations would occur

Notification of the Purpose of Use

• When the purpose of use of the personal data is not clear from the purpose of use statement published by INV
• When there is risk of damage to the life, health, property or other rights and interests of the individual concerned or a third party
• When there is risk of exceptional damage to the proper operation of INV
• When necessary to cooperate with organizations of the state or local authorities who are carrying out tasks designated by laws and regulations and when there is risk of impeding the execution of such tasks

Correction (Correction, Addition, Deletion)

• When special procedures for correction are provided under laws and regulations
• When correction is not necessary to achieve the purpose of use for the relevant personal data

Discontinuance of Use or Discontinuance of Providing Information to Third Parties

• When the consent of the individual concerned has been obtained in advance
• When laws and regulations apply
• When necessary to safeguard life, health or property and when it is difficult to obtain prior consent from the individual concerned
• When especially necessary to improve public health and to promote the healthy development of infants, and when it is difficult to obtain prior consent from the individual concerned
• When necessary to cooperate with organizations of the state or local authorities or their consignees who are carrying out tasks designated by laws and regulations, and when there is risk that obtaining the consent of the individual concerned will impede the execution of such tasks
• When providing the personal data in line with consigning the handling of all or part of personal data within the scope necessary to achieve the purpose of use
• When personal data is shared as a result of business succession due to mergers or other reasons
• When personal data used in collaboration with a specified party is provided to the specified party, and when the individual concerned is notified in advance, or is in a position to easily learn of the matter as well as the name and designation of the collaborating parties responsible for the particulars of personal data used, the scope of collaboration, the purpose of use and the management of the relevant personal data

Request Procedures

When submitting a request for the disclosure of personal data based on applicable laws and regulations, please enclose the designated application form obtained in advance from CSNT and proof of identity (the original or photocopies of a driver's license or other official document) and submit the request by mail or by applying at our office in person. If the request is submitted by proxy, documentation to such effect (power of attorney, residence card, seal registration certificate) must also be presented. The disclosure of personal data may require payment of a fixed fee.
When INV receives a request for disclosure, notification of purpose of use, or discontinuance of use, INV may ask you to provide information necessary to identify the personal data subject to disclosure, notification of purpose of use, or discontinuance of use.
In order to protect the privacy of the individual concerned, the reply will as a rule be submitted in writing or orally to the individual concerned even in cases when the request has been made by proxy.

7. Contact Information

Please contact the Planning and General Affairs Department for questions about how INV handles personal information, disclosure, correction, discontinuance of use and complaints.

For inquiries and applications submitted by unitholders regarding content in the register of unitholders held by INV (correction, addition or deletion of items in the register of unitholders), please contact the Administrator below.

Please note that depending on the content of the inquiry or application and, in light of applicable laws and regulations, we may not be able to reply or respond.

8. Contact for complaint/consultation at the authorized personal information protection organization

CSNT is a member of The Investment Trusts Association, Japan ("JITA"), which is a personal information protection organization authorized by the Japanese Financial Services Agency.
JITA receives inquiries and provides consultation on its member companies' handling of personal information.
For all inquiries, please see the contact details below: