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Privacy Policy

In recognition of the importance of maintaining the security of personal information, LaSalle REIT Advisors K.K. (hereinafter, "LRA") makes concerted efforts to appropriately handle, manage, and protect the personal information in its possession, and strictly complies with Japan's Act on the Protection of Personal Information and other related laws and guidelines when handling such information. Note that LRA has established and observes a separate policy entitled the "Basic Policy on the Handling of Specific Personal Information" for Individual Numbers and specific personal information (the meanings of each as provided in the "Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.")

1. Basic Policy on the Handling of Personal Information

LRA fully understands the importance of protecting personal information, and recognizes its social obligation to properly collect, manage, and use the personal information it obtains only within the scope needed for administrative purposes, in accordance with the requirements of applicable laws as well as its own basic policy, as follows.

(1) LRA shall obtain personal information through appropriate and lawful means, and only to the extent necessary for administrative purposes. Accordingly, LRA shall not collect personal information through deceptive or other dishonest means. Except as stipulated under the provisions of relevant laws and regulations, LRA shall not acquire personal information considered to be important without the consent of the individual concerned; nor shall LRA acquire sensitive information (as defined in the "Guidelines on the Protection of Personal Information in the Financial Sector"; hereinafter referred to as the "Financial Sector Guidelines") except as provided for under the Financial Sector Guidelines.
(2) LRA shall always keep the personal data it obtains and manages accurate and up to date, and shall also endeavor to delete any data that is no longer required as soon as possible. In addition, LRA shall take necessary and appropriate steps to ensure the security of the information it manages, including related training of personnel, to proactively prevent unauthorized access to or disclosure of personal data, or loss, damage, and falsification of such data.
(3) LRA shall not use the personal information it has obtained outside the scope of the intended purpose it has specified, unless it obtains prior consent from the individuals concerned, or such usage is permissible by law. Furthermore, the purpose of using such information shall be limited to the minimum extent possible. Note that, unless so prescribed in the Financial Sector Guidelines, LRA shall not use sensitive information.

2. Purpose of Using Personal Information

With the exception of certain cases permissible by law, LRA shall use personal information only within the scope of the following specific purposes.

(1) To fulfill obligations to investment unitholders and ensure that they can exercise their respective rights in accordance with the Act on Investment Trusts and Investment Corporations of Japan (hereinafter, the "Investment Trust Act") and other applicable laws and regulations, particularly by delivering asset management reports, announcements of general unitholders' meetings, and notifications of dividend payments to the unitholders.
(2) To prepare and administer the investment unitholders' data and information needed to create the register of names used for contacting the unitholders regarding presentations on financial results and other management meetings held by LRA, as required under the Investment Trust Act and other applicable laws and regulations.
(3) To perform asset management-related duties for LRA in accordance with the Investment Trust Act, namely, real estate management along with the acquisition, brokerage, sale, transfer, and leasing of properties (including asset management duties related to raising funds), as well as the information collection, research, analyses and studies needed for carrying out such duties.
(4) To perform administrative duties for LRA, including work related to investor relations and general administration.
(5) To perform work incidental or related to the duties listed above.
(6) To consult with and outsource external experts, such as lawyers, certified public accountants, tax accountants, real estate appraisers, and judicial scriveners, for the purpose of achieving the objectives listed above.

3. Provision of Personal Data to Third Parties

LRA does not provide personal data to third parties without obtaining prior consent from the individuals concerned, except in the following cases.

(1) When the provision of personal data is permitted by law.
(2) When consent is difficult to obtain from an individual concerned in a case in which providing the personal data is necessary for protecting a person's life, body or property.
(3) When consent is difficult to obtain from an individual concerned in a case in which providing the personal data is particularly important for improving public health or promoting the sound development of children.
(4) When providing personal data is necessary for cooperating with the activities of national or local government authorities, or of a representative entrusted by such authorities in accordance with laws and regulations, and obtaining the consent of the individual concerned is likely to impede the execution of such activities.

4. Outsourcing and Supervision of Contractors

In the event that LRA consigns a contractor to manage some or all of the personal data in its possession, it takes appropriate measures to handle the data in accordance with applicable laws and regulations, and conducts necessary and proper supervision of the contractor to ensure that the personal data under consignment is securely managed.

5. Demands from Individuals to be Notified of the Intended Use of Personal Data held by LRA; as well as Requests for Disclosures Etc.; Amendments; Termination of Use; and Suspension of Provision to Third Parties of Said Data

In accordance with applicable laws and regulations, LRA responds appropriately to demands for notification of intended use and requests for the personal data it possesses to be disclosed, amended, supplemented, deleted, not used, erased, or its provision to third parties withdrawn (hereinafter referred to as "Disclosures Etc.") if an individual makes such a request, upon confirming the identity of the individual or his or her representative. Individuals interested in such requests are requested to refer to "7. Contact Information," below.

(1) Contact information for Requests for Disclosures Etc.
The contact information is provided in 7. below.
(2) Format of documents to be submitted when request for Disclosures Etc. is made and methods for accepting other Requests for Disclosures Etc. When applying for Disclosures Etc., requests should be sent by mail in the written format prescribed by LRA (hereinafter referred to as the "Request for Disclosures Etc."), which includes the items listed below:

(ⅰ) The Individual's name, address and contact details

(ⅱ) In the event that the request is made by a representative: the name, address and contact details of the representative

(ⅲ) Items to identify the retained personal data connected with the application for Disclosures Etc.

(ⅳ) Which disclosure item from within the application the individual is requesting

(ⅴ) The address to which any notifications, results of surveys or responses from LRA should be sent

(3) Methods of identifying ("ID") the individual etc.
In order to allow us to identify the individual, copies of the each of the following documents should be submitted:

(ⅰ) One hard-copy form of ID such as the individual's driving license, health insurance card, alien registration card, or basic resident registration card

(ⅱ) Either the resident certificate or the original alien registration certificate Note that if the application is made by a representative, one of the following should be submitted to confirm the authority of the representative

(ⅰ) In the case of a legal representative: the representative should present or submit a document confirming eligibility to make the request, such as an official copy of the family register; an excerpt of the family register; or a certificate of registered matters

(ⅱ) In the case of a representative by proxy: a proxy signed by the individual with his/her own signature stamp and a certificate of proof of the individual's signature stamp should be submitted

(4) Amount of fees and methods of collection
The fee is 1,000 yen per disclosure request (not including consumption tax) and should be enclosed in the form of a postal order in the same envelope as the Request for Disclosures Etc. when the request is sent by mail. Please note that the individual may also be asked to pay the prescribed fee when asking to be notified of the intended use of personal data held by LRA
(5) Methods used to reply to requests for Disclosures Etc.
LRA will mail its written responses to the individual's current address, as listed in the Request for Disclosures Etc., by recorded delivery (or in the event of a request from a representative, responses will be sent the contact address for the representative provided that the proxy gives him/her the authority to receive personal information on the individual.) Written responses will be dispatched within one month of the date LRA receives the Request for Disclosures Etc.

For any other queries on detailed procedures, please contact the department listed below in "7. Contact Information."

6. Efforts to Make Continuous Improvements

LRA strives to properly manage personal information and improve the security of the data in its possession. It is also prepared to revise the contents of this privacy policy in consideration of revisions to laws and regulations, growing expectations among the public and other changes in social trends.

7. Contact Information

Please contact the following department for inquiries regarding the handling of personal information, including matters such as requests and complaints related to the Disclosures Etc. of personal data.

【Contact Information】

Contact LaSalle REIT Advisors K.K., Planning and Administration Department
Address 8th Floor, Otemachi Nomura Building, 2-1-1 Otemachi,
Chiyoda-ku, Tokyo, Japan
Telephone +81-3-6367-5600
Office Hours 9:00 a.m. to 6:00 p.m., excluding weekends, national holidays, and New Year's holidays

For inquiries regarding matters concerning the unitholders' register, please contact the following department, which currently serves as the administrator.

【Contact Information】

Contact Sumitomo Mitsui Trust Bank, Limited, Stock Transfer Agency Business Planning Department
Address 2-8-4, Izumi, Suginami-ku, Tokyo, Japan
Office Hours 0120-782-031 (toll-free, but reachable from within Japan only)
Office Hours 9:00 a.m. to 5:00 p.m., excluding weekends, national holidays, and New Year's holidays

Furthermore, LRA is a member of the Investment Trusts Association of Japan (the "Association"), an authorized organization for the protection of personal information under the Personal Information Protection Act. The Association consults and accepts complaints on how member companies handle personal information. Inquiries should be directed to the contact below.

【Contact for Inquiries at the Investment Trusts Association】

Name The Investment Trusts Association, Japan, Member Inspection Dept., Investor Inquiry Section
Telephone +81-3-5614-8440

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