Company name: KDX Realty Investment Corporation
Location: 2-1-6 Uchisaiwaicho, Chiyoda-ku, Tokyo
Representative: Hiroaki Momoi, Executive Director

1. Basic Policy on Personal Information Protection

KDX Realty Investment Corporation (hereinafter, “KDXR”) is committed to the appropriate processing and management of personal information in accordance with the Act on the Protection of Personal Information and other related laws, regulations and guidelines.

2. Purposes of Use of Personal Information

（1）	KDXR uses the acquired personal information for the following purposes. ①  For conducting any business operations pertaining to the exercise of the rights of the unitholders of KDXR (hereinafter, the “unitholders”) and to the performance of the obligations of KDXR pursuant to the Act on Investment Trusts and Investment Corporations (hereinafter, the “Investment Trust Act”) and other laws and regulations, as well as regulations of administrative agencies and financial instruments exchanges (hereinafter “Investment Trust Act.”), such as providing asset management reports and issuing notices of convocation of the general meeting of unitholders or notices of payment of distributions to the unitholders; ②  For managing information of the unitholders, such as preparation of data of the unitholders' register, prepared pursuant to the Investment Trust Act., and for providing information to unitholders; ③  For handling and confirming inquiries and visits concerning businesses conducted by KDXR; ④  For acquiring properties (including securities or claims underlying such properties; the same shall apply hereafter), and conducting surveys and considerations of acquisitions prior to such acquisitions; ⑤  For conducting property sales, and having buyers or new real estate management companies conduct surveys and considerations of sales prior to such sales; ⑥  For grasping and managing the status of leasing, management of rent income as well as conducting business operations for billing expenses pertaining to restoration costs., to lessees of properties held by KDXR; ⑦  For confirming the status of creditworthiness of lessees of properties held by KDXR or which KDXR is considering acquiring or that of those considering leasing such properties (including confirmation by buyers or new real estate management companies), and conducting business operations for concluding lease agreements; ⑧  For conducting business operations concerning analyses of demand, such as leasing service enhancement questionnaires, and various communications with lessees of properties held by KDXR or those considering leasing such properties; ⑨  For conducting a calculation of allowance for doubtful accounts in the financial results of KDXR as well as other business operations concerning accounting and taxation; ⑩  For conducting business operations concerning provision of all sorts of information concerning guides, for KDXR's financial results briefing sessions, management status reporting sessions and property viewing sessions to unitholders, preparation of attendance data.; ⑪  For conducting business operations concerning inquiries, requests for materials, from KDXR's unitholders and those considering buying securities issued by KDXR; ⑫  For claiming nonlife insurance pertaining to properties held by KDXR; ⑬  For confirming the identification of the persons stated on application forms, contracts, for performance of the businesses conducted by KDXR; and ⑭  In addition to what is provided for in the preceding items, for performing business operations related or incidental to the businesses conducted by KDXR
（2）	KDXR will not alter the purpose of use of personal information beyond the scope recognized reasonably relevant to the pre-altered purpose of use.
（3）	KDXR will not use the personal information in a manner that may encourage or induce illegal or unjust acts.

3. Acquisition of Personal Information

When acquiring personal information, KDXR will use appropriate and fair means to the extent necessary to achieve the purpose for which the information is to be used. Where personal information is to be acquired, KDXR will do so through appropriate means. Where personal information is to be acquired directly from the person in writing or via a website page., KDXR will clearly indicate the purposes of use in advance. However, where the purposes of use are clear given the circumstances of the acquisition of personal information or where omission of clear indication of the purposes of use is permitted under laws and regulations., a clear indication of the purposes of use may be omitted.
In addition, when obtaining personal information through third parties, KDXR will not obtain personal information suspected of having been obtained illegally.

4. Management of Personal Data

KDXR strives to maintain personal data accurate and up-to-date within the scope necessary to achieve the purposes of use and to delete personal data that are no longer necessary.
KDXR entrusts the handling of personal data to asset management companies In accordance with the guidelines for the protection of personal information set forth by the Personal Information Protection Commission and/or Financial Services Agency, at each stage of the acquisition, use, storage, of personal data, the asset management companies take the following necessary and appropriate safe management measures in order to prevent leakage, loss or damage, of personal data. KDXR will maintain internal rules necessary for the safe management of personal data, provide education and training to a director, and exercise necessary and appropriate supervision to the director.

（1）	Establish and comply with policies and regulations to ensure the proper handling of personal data;
（2）	Establish and comply with rules and regulations regarding the handling of personal data at each stage of the acquisition, use, transfer, storage, deletion, luding handling methods, responsible persons/persons in charge and the definition of their duties;
（3）	Appoint an information management officer and periodically inspect and audit the status of the handling of personal data. The results of the inspection and audit shall be reported to the Board of Directors and a system established for the Board of Directors to evaluate, review and improve security control measures;
（4）	Take measures to prevent theft or loss of personal data in areas where personal data is handled;
（5）	Install in the information systems handling personal data tools for the identification of, and protection against, unauthorized access from outside or the installation of unauthorized software. In addition, set access privileges as necessary, record, analyze, and store access to personal data, and monitor record of suspected fraud on a regular basis; and
（6）	When handling personal data in foreign countries, implement the necessary security control measures based on an understanding of the systems for the protection of personal data in the countries and regions where personal data is handled

5. Handling of Sensitive Information

With respect to Sensitive Information (“Special care-required personal information” defined in the Act on the Protection of Personal Information and sensitive information provided for in the “Guidelines for Personal Information Protection in the Financial Field”), KDXR will not acquire, use or provide to any third parties the Sensitive Information without the principal's consent, unless permitted under the Act on the Protection of Personal Information and other related laws, regulations and guidelines.
When handling pseudonymized information, anonymized processed information and personality-related information, KDXR will comply with the obligations stipulated in relevant laws, regulations, and guidelines.

6. Disclosure and Provision of Personal Data to Third Parties

（1）

KDXR will not disclose or provide personal data to third parties except in the following cases. ①  The principal has given his/her consent; ②  The disclosure or provision of personal data is based on laws and regulations; ③  The disclosure or provision of personal data is required to protect life, health or assets of a person and it is difficult to obtain the principal's consent; ④  It is particularly necessary in order to enhance public health or to promote the sound nurturing of children, and it is difficult to obtain the principal's consent; ⑤  Cooperation is requested by national or local government agencies, or service providers contracted by those agencies to conduct matters prescribed by laws and regulations, and obtaining the principal's consent may hinder the conduct of such matters; ⑥  KDXR provides personal data to outside service providers under appropriate supervision by KDXR within the scope necessary to carry out the applicable purpose of use of the personal data; and ⑦  The disclosure or provision of personal data is permitted under the Act on the Protection of Personal Information and other laws, regulations and guidelines.

（2）

When providing personal data or personality-related information to a third party situated in a foreign country, KDXR will comply with the obligations stipulated by the relevant laws, regulations, and guidelines.

7. Supervision of Contracted Service Providers

KDXR outsources asset management services and general administration, pursuant to the Investment Trust Act as a registered investment corporation. KDXR conducts necessary and appropriate supervision of such contracted service providers to prevent loss, misuse, modification, of the personal data handled and in their possession.

8. Joint Use of Personal Data

KDXR jointly uses certain personal data with its asset management company, Kenedix Real Estate Fund Management, Inc., and other registered investment corporations for which the latter company provides asset management business serevice, the following manner within the scope necessary to achieve the purposes of joint use:

Personal data to be jointly used	(a) Information on the unitholders • Attribute information such as name, address and number of units of investment held • Content of feedback, requests and complaints, and information related thereto • Any other information necessary to achieve the purposes of use stated in the “Purposes of use by joint users” row below (b) Information on the tenants, (including prospective tenants, former tenants and guarantors) of the properties held or considered for acquisition by KDXR • Attribute information such as name and address • Content, of feedback, requests and complaints, and information related thereto • Status of performance, of lease agreements, with the tenants, and information related thereto • Any other information necessary to achieve the purposes of use stated in the “Purpose of use by joint users” row below (c) Information on other co-contracting parties and business partners • Name, address, and other attribute information (of the subject person, or in the case of a corporation, the representative., or the person in charge) • Content of feedback, requests and complaints, and information related thereto • Status of performance, of agreements, and information related thereto • Any other information necessary to achieve the purposes of use stated in the “Purposes of use by joint users” row below
Scope of joint users	• Kenedix Real Estate Fund Management, Inc. and the registered investment corporation for which said company provides an asset management business service ＊ For information on the applicable registered investment corporation, please refer to the following. • Kenedix Private Investment Corporation（Japanese Only) https://www.kpi-reit.com/
Purposes of use by joint users	(a) Information on the unitholders • To respond to feedback, from the unitholders of each investment corporation and to otherwise respond appropriately to the unitholders • In addition to the above, to properly manage the unitholders's affairs. (b) Information on the tenants of properties held or considered for acquisition by KDXR • To perform assessments of the tenants, of each investment corporation • To respond to feedback, from the tenants. • In addition to the above, to properly manage the investment properties (c) Information on other co-contracting parties and business partners. • To respond to feedback, from co-contracting parties and business partners. • In addition to the above, to properly manage the affairs of co-contracting parties and business partners.
Person responsible for the management of personal data	The personal data handled by KDXR is managed under the responsibility of KDXR, and the personal data handled by other joint users is managed under the responsibility of such other joint users.

9. Inquiries Concerning Personal Information

Please contact the following if you have requests to notify the purpose of use or other inquiries regarding disclosure, correction, addition, deletion, or suspension of use, of the personal data that has been provided to KDXR, or require disclosure of records of the personal data provided to third parties:

Name	Kenedix Real Estate Fund Management, Inc. (Asset Management Company)
Address	2-1-6 Uchisaiwaicho, Chiyoda-ku, Tokyo 100-0011 Japan
TEL	+81-3-5157-6300
Business Hours	9:00 to 17:00 Japan Standard Time (closed on weekends, national holidays and year-end/new year holidays)

However, please contact the following administrator for the unitholders' register if you have inquiries about unitholders' register entry items and administrative affairs:

Name	The Transfer Agent Division of Sumitomo Mitsui Trust Bank, Limited
Address	2-8-4 Izumi, Suginami-ku, Tokyo 168-0063 Japan
TEL	0120-782-031 (toll-free, domestic only)
Business Hours	9:00 to 17:00 Japan Standard Time (closed on weekends, national holidays and year-end/new year holidays)

* Revision of this Policy:	KDXR will review and revise this Privacy Policy pursuant to amendments to and/or the abolition of laws and regulations, or whenever such revisions are necessary, and will strive to protect personal information.