Privacy Policy

1. Collecting Personal Information
HRAM collects Personal Information in an appropriate and legal manner on an as-required basis for the purposes specified below and shall not collect Personal Information through deceptive or illegal means. Moreover, HRAM shall not collect Sensitive Information without the consent of the relevant individual except in the cases stipulated in the Personal Information Protection Act and the guidelines. Prior to collecting Personal Information, HRAM discloses on its Website the purpose and intended use of collected Personal Information. When HRAM collects Personal Information directly in written form, etc., HRAM shall clearly state the purpose and intended use of the Personal Information beforehand. However, when the purpose and intended use are obvious at the time of collection due to the conditions under which the Personal Information is collected, or it is permissible under other laws and regulations, such disclosure may be omitted.

2. Collecting Individual Numbers
Notwithstanding 1 above, HRAM may request the individuals or operators handling individual numbers to provide individual numbers, to the extent necessary for the administrative processing stipulated in III. 2 below. Furthermore, HRAM shall request the provision of individual numbers when it is necessary for said administrative processing, or when said administrative processing is projected to occur.

3. Identity Verification
When accepting individual numbers, HRAM shall identify individuals by using the methods designated in Article 16 of the Numbers Act. As for provision of individual numbers by proxies, HRAM shall identify the relevant proxies, confirm their authority of proxy, and check their individual numbers based on the methods designated in the said Article.

1. Purpose and Intended Use of Personal Information
HRAM shall use collected Personal Information to the extent necessary for achieving the following purposes.

(1)

To exercise the rights of investors in Hoshino Resorts REIT, Inc. (hereinafter "HRR") with assets for which HRAM has been entrusted with operations related to their management, and for the performance of obligations of HRAM and HRR, pursuant to the Act on Investment Trusts and Investment Corporations (hereinafter, the “Investment Trusts Act”), the Financial Instruments and Exchange Act (hereinafter, the "Finance Act"), and other laws and regulations, etc.

(2)

To manage information on investors

(3)

To carry out operations for preparation, submission, etc. of various reports, etc. of HRR pursuant to the Investment Trusts Act, the Finance Act, and other laws, regulations, and financial instruments exchange rules

(4)

To facilitate borrowings and the issuance of corporate bonds and offering of investment units by HRR

(5)

To respond to inquiries, requests for materials, etc., directed to HRAM or HRR

(6)

To perform investigation and analysis, and to hold discussions for the purpose of managing HRR’s assets

(7)

To execute property acquisitions and sales, and to conduct operations related to leasing, maintenance and management of real estate by HRR

(8)

To appropriately and smoothly perform operations related to HRR’s IR activities and other HRAM and HRR operations

(9)

To carry out operations incidental or relating to any of the operations above

2. Purpose and Intended Use of Specific Personal Information
Notwithstanding 1 above, HRAM may use Specific Personal Information for the following purposes.

(1)

Specific Personal Information of directors of HRAM and their relatives
For operations concerning withholding, etc., filing and applications related to social insurance, labor insurance or corporate pensions, and other operations, as well as operations incidental or relating to any of the operations above

(2)

Specific Personal Information of customers and clients
To prepare statutory reports. etc., which are required to include individual numbers pursuant to provisions of laws and regulations

1. Provision of Personal Data to Third Parties
HRAM shall not provide or disclose Personal Data to any third parties without prior consent from the relevant individual except in the cases specified below.

(1)

When it is required by laws and regulations

(2)

When it is necessary to protect human life or personal property, and obtaining consent from the relevant individual is difficult

(3)

When it is especially necessary for the improvement of public health or the promotion of sound upbringing of children, and obtaining consent from the relevant individual is difficult

(4)

When it is necessary to cooperate with national or local governments or a party entrusted by the government to carry out operations required by laws or regulations, and obtaining consent from the relevant individual may be a hindrance to carrying out such operations

(5)

Based on the description in viii., when HRAM entrusts Personal Information handling to a third party

(6)

When HRAM provides or discloses the Personal Information in a manner that does not allow identification of individuals, such as in statistical data

(7)

When provision or disclosure is approved by the Personal Information Protection Act, other laws and regulations and guidelines.

Items of Personal Information that may be provided are name, address, telephone number, e-mail address, contract information, status of use of HRR’s assets, and other items necessary for achieving the purpose for use of collected Personal Information.

2. Provision of Specific Individual Information to Third Parties
Notwithstanding 1 above, HRAM shall not provide Specific Individual Information to any third parties unless otherwise provided in items of Article 19 of the Number Use Act.

3. Provision of Personal Data and Personal Related Information to a Third Party in a Foreign Country
When providing Personal Data and Personal Related Information to a third party in a foreign country, HRAM shall comply with the obligations stipulated by related laws, regulations and guidelines, etc.

HRAM shall manage Personal Data retained by HRAM properly and carefully and take necessary and appropriate safety control measures pursuant to laws, regulations and guideless, etc. to prevent unauthorized access to Personal Data, leakage, loss and/or damage of Personal Data, and to ensure safe management of other Personal Information. HRAM has prepared internal rules necessary for the safe management of Personal Data, provides education and training to officers and employees, and performs necessary and appropriate supervision as follows.

(1)

In order to ensure the proper handling of Personal Data, HRAM shall establish and comply with the “Personal Information Protection Regulations” and the “Personal Information Protection Detailed Operational Rules.”

(2)

HRAM shall establish and comply with the rules for handling Personal Data at each stage of collection, use, transfer, storage, deletion, etc., including handling methods, responsible persons/persons in charge, and their duties.

(3)

HRAM shall appoint a person responsible for the handling of Personal Data, as well as periodically inspect and audit the status of the handling of Personal Data.

(4)

HRAM shall inform its employees of security control measures, ensure that they are thoroughly familiar with such measures, and provide them with education and training.

(5)

HRAM shall control workers’ entering/leaving any area where Personal Data is handled and shall implement measures to prevent theft, etc.

(6)

Information systems that handle Personal Data shall be equipped with a function to verify the identity of individuals, and shall also be protected from unauthorized external access and unauthorized software. In addition, access permissions shall be set as necessary, accesses to Personal Data shall be recorded, analyzed and stored, and the existence or non-existence of records suspected of fraud shall be periodically checked.

HRAM is a member of the following Financial Services Agency-accredited authorized personal information protection organization. This organization handles complaints and inquiries regarding the handling of members' Personal Information. Contact it using the contact information below for related complaints or inquiries.