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Personal Information Protection Policy (Privacy Policy)

1. Basic Policy on Personal Information Protection

Kenedix Residential Investment Corporation (hereinafter, "KDR") 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, etc.

2. Acquisition of Personal Information

Where personal information is to be acquired, KDR will do so through appropriate means. Where personal information is to be acquired directly from the person in writing or via a screen of the website, etc., KDR 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, etc., a clear indication of the purposes of use may be omitted.

3. Purpose of Use of Personal Information

KDR uses the acquired personal information for the following purposes.

(1) For conducting any business operations pertaining to exercise of the rights of the unitholders of KDR (hereinafter, the "unitholders") and performance of the obligations of KDR pursuant to the Act on Investment Trusts and Investment Corporations (hereinafter, the "Investment Trusts Act") and other laws and regulations as well as regulations of administrative agencies and financial instruments exchanges (hereinafter "Investment Trusts Act, etc."); 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, etc. prepared pursuant to the Investment Trusts Act, etc., and for providing information to unitholders;

(3) For handling and confirming inquiries and visits concerning businesses conducted by KDR;

(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 replacement costs, etc., to lessees of properties held by KDR;

(7) For confirming the status of creditworthiness of lessees of properties held by KDR or which KDR 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 rental housing demand, such as leasing service enhancement questionnaires, and various communications with lessees of properties held by KDR or those considering leasing such properties;

(9) For conducting calculation of allowance for doubtful accounts in the financial results of KDR as well as other business operations concerning accounting and taxation;

(10) For conducting business operations concerning provision of all sorts of information concerning guides, etc. for KDR's financial results briefing sessions, management status reporting sessions and property viewing sessions to unitholders, preparation of attendance data, etc.;

(11) For conducting business operations concerning inquiries, requests for materials, etc. from KDR's unitholders and those considering buying securities issued by KDR;

(12) For claiming nonlife insurance pertaining to properties held by KDR;

(13) For confirming the identification of the persons stated on application forms, contracts, etc. for performance of the businesses conducted by KDR; 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 KDR

4. Management of Personal Data

KDR strives to maintain personal data accurate and up-to-date within the scope necessary to achieve the purposes of use and delete personal data that are no longer necessary. KDR takes necessary and appropriate safe management measures according to each stage of acquisition, use, storage, etc. of personal data to prevent leakage, loss or damage, etc. of personal data. KDR establishes the internal regulations necessary for safe management of personal data, provides its officers with relevant education and training, and carries out necessary and appropriate supervision.

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"), KDR 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, etc.

6. Disclosure and Provision of Personal Data to Third Parties

KDR 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) KDR provides personal data to outside service providers under appropriate supervision by KDR 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, etc.

7. Supervision of Contracted Service Providers

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

8. Inquiries Concerning Personal Information

Please contact the following if you have questions and inquiries on disclosure, correction, suspension of use, etc. concerning the personal information that has been provided to KDR:

Kenedix Real Estate Fund Management, Inc. (KDR's asset manager)
2-1-6Uchisaiwaicho, 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 unitholders' register if you have inquiries about unitholders' register entry items and administrative affairs:

The Transfer Agent Division of Sumitomo Mitsui Trust Bank, Limited
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
KDR will review and revise this Privacy Policy pursuant to amendments to and abolition of laws and regulations, etc. or when such revisions are necessary, and strive to protect personal information.