Personal Information Protection Law

ADR has established a Personal Information Protection Policy by formulating the following policies and position concerning the protection of personal information to protect the rights of site visitors regarding personal information.

1. Compliance with Related Laws and Ordinances
	ADR shall endeavor to appropriately handle personal information and securely manage and use such by complying with the Personal Information Protection Law, related laws, ordinances, guidelines, internal company rules, etc.
2. Objectives for Using Personal Information
	ADR shall use personal information based on laws and ordinances and for other purposes that fall within the scope outlined below. a. For the implementation of investor rights and implementation of obligations of ADR under the Investment Trusts and Investment Corporations Law (ITL) and other laws and regulations. b. For the handling of inquiries with ADR from investors and for the provision of information to investors about the business of ADR. c. For the management of investor information regarding the preparation of various ADR reports, the preparation of data concerning investors, etc. based on the ITL, Commercial Code and other related laws and ordinances. d. For the borrowing of funds, issuing of investment corporation bonds and additional issuance of investor units by ADR. e. For the conducting of various investigations and analyses related to ADR's asset management (including leasing operations) and the making of judgments based on these. f. Other reasons that are necessary for the appropriate and smooth operation of ADR. g. For the provision of personal information to a third party that falls within a scope necessary to achieve the purposes of a.-f. above.
3. Obtaining Personal Information
	ADR shall obtain personal information to the extent necessary for the purpose using the appropriate means, and ADR shall follow the designations of laws and ordinances to announce, notify and indicate the purposes for the personal information that was obtained.
4. Providing and Disclosing Personal Information to a Third Party
	ADR shall not provide or disclose obtained personal information to a third party, such as information from which the individual can be identified excluding the following instances. a. When agreement of the individual in question has been obtained. b. When the information is to be provided or disclosed as statistical data or in some other form where the individual cannot be identified. c. When disclosure or provision of the information is demanded based on laws and ordinances. d. When it is necessary to protect the life, body or property of an individual and it is difficult to obtain the approval of said individual. e. When it is particularly necessary to improve public sanitation and to promote the healthy nurturing of children and it is difficult to obtain the approval of said individual. f. When it is essential for cooperation with the execution of administrative matters designated in laws and ordinances conducted by agencies of the country, regional local government bodies and parties entrusted by such, and there is the potential that obtaining the approval of the concerned individual will hinder the execution of said administrative affairs. g. For other reasons for which disclosure and provision are recognized by the Personal Information Protection Law.
5. Subcontracting the Handling of Personal Information
	When ADR subcontracts operations handling all or part of the personal information possessed by ADR to an outside party, ADR shall conduct necessary and appropriate monitoring of said party to ensure the safe management of personal information.
6. Safe Management of Personal Information
	ADR shall appropriately and prudently manage personal information and construct necessary and appropriate safety management measures to prevent loss, alteration, leakage and such involving personal information.
7. Disclosure, Correction, Deletion and Use Stoppage of Personal Information
	ADR shall endeavor to accurately manage and maintain up-to-date personal information. Also, when the concerned individual demands the disclosure, etc. of personal information that is possessed by ADR, the demand must be met based on laws and ordinances after confirming the identity of the individual. Please have the person submit a demand by mail or by visiting ADR with materials to verify the individual's identity (copy of driver's license, resident card, etc.). When the demand is made by an agent, materials must also be attached that verify that the person is the agent (power of attorney from said individual, certified copy [excerpt, etc.] of family register).
8. Contact
	When you have questions, claims or the like concerning the handling of personal information, please contact ADR as directed below. Name Corporate Management Department AD Investment Management Co., Ltd. (asset manager of ADR) Address Kioicho Building 8F 3-12 Kioicho, Chiyoda Ward, Tokyo 102-0094 Phone +81-3-5216-1871 Reception 9:00-17:00 (excluding Saturdays, Sundays, holidays and New Year's holidays)
9. Continual Improvement of Personal Information Protection System
	ADR shall prepare internal company rules concerning personal information and continually review and strive to improve these. (This Personal Information Protection Policy can be revised in correlation with improvements to the personal information protection system or amendments to related laws and ordinances.)