Sumitomo Mitsui Trust Group Privacy PolicyJAPANESE

Handling of Personal Information

Our company adheres to the "Sumitomo Mitsui Trust Group Privacy Policy" regarding the handling of the personal information and the specific personal information (means the personal information that includes the Individual Number; the same shall apply hereinafter), and we make every effort to properly manage the personal information and the specific personal information.
The following is a guide about how our client's personal information or the specific personal information is handled. Regarding the handling of personal data pursuant to “The EU General Data Protection Regulation (GDPR)", please see “FAIR PROCESSING NOTICE”.

FAIR PROCESSING NOTICE

  1. 1. Inquiry Liaison for the Personal Information and the Specific Personal Information that Our Company Handles
    (1) Please contact the following for inquiries regarding the handling of the personal information and the specific personal information, consultation, and complaints.
    Customer Service
    1-4-1 Marunouchi, Chiyoda-Ku, Tokyo 100-8233
    03-6256-6000
    Office Hours  9:00 - 17:00 Weekdays
    (2) General inquiries about everything from the information contained in our shareholder registry to general inquiries about shares are accepted at the Securities Business Center of Sumitomo Mitsui Trust Bank, Limited which is our securities administrative agency (Shareholder Registry Administrator).
    0120-782-031
    Office Hours  9:00 - 17:00 Weekdays
  2. 2. Obtaining and Using Personal Information and the Specific Personal Information

    Our company, for example, obtains the personal information and the specific personal information from the following sources.
    (Examples of sources from which we obtain the personal information)

    • ·Personal Information of people who made an inquiry or request for materials through our website, etc. (name, address, company name, e-mail address, etc.)
    • ·Personal Information of Shareholders (name, address, number of stocks held, etc.)
    • ·As the bank holding company, in order to provide administrative guidance and business management to the Group companies including bank subsidiaries, etc. in accordance with Article 23 Paragraph 5 No. 3 of the Personal Information Protection Law, part of the customer transaction information held by companies in our group can be shared. (Explained below in 6. Sharing of Personal Data)
    • (Examples of sources from which we obtain the specific personal information)
    • ·Specific Personal Information of our clients that directly received by the submitted written notice
    • ·Specific Personal Information of Shareholders Received from Japan Securities Depository Center, Incorporated, etc.
  3. 3. Purpose of Using Personal Information

    In accordance to the "Act on the Protection of Personal Information" (Law No. 57, May 30, 2003), our company uses the personal information of our shareholders and clients to the extent necessary to achieve the following purposes.
    When we acquire personal information such as shareholders and clients, we will notify, announce or indicate the purpose of use.
    Furthermore, when laws and regulations limit how certain personal information is to be used then it shall not be used for any other purpose.
    Our company makes clear to the person in question how the information will be used and at the time of receiving the information we make every effort to limit the intended use.

    (1) Personal Information about Shareholders
    • 1) In order to exercise rights and fulfill obligations in accordance to the Companies Act
    • 2) In order to provide various benefits in relation to shareholder status
    • 3) In order to implement various measures to facilitate the relationship between our company and the shareholder from the perspective of both the corporation and its member.
    • 4) For administrative purposes related to shareholders such as creating shareholders data in accordance to prescribed standards based on applicable laws and regulations.
    (2) Personal Information Related to Clients (Including the Contact Person, etc.)
    • 1) For communication and business management pertaining to the said transaction
    • 2) In order to exercise rights and fulfill obligations in accordance to agreements and laws, etc.
    • 3) For the cancellation of various transaction agreements and the post-management required after the cancellation of transactions.
    • 4) Any other matters required to properly and smoothly execute the company's business transactions and contracts (Including consignment contracts, etc.)
    (3) Personal Information Obtained from Banking Subsidiaries and Other Group Companies, etc.
    • 1) In order to provide administrative guidance and business management as the bank holding company of the Group and its Bank subsidiaries, etc.
  4. 4. Purpose of Using the Specific Personal Information

    In accordance to the "Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure" (Law No. 27, May 31, 2013), our company uses the specific personal information of our shareholders and clients to the extent necessary to achieve the following purposes. Our company shall only use the specific personal information within the confines of the purpose stipulated by law.
    When our company obtains the specific personal information by our shareholders and clients, laws and regulations limit how certain personal information is to be used then it shall not be used for any other purpose.

    • 1) In order to prepare certificates of payment records of remuneration and fee
    • 2) In order to prepare certificates of payment records of dividend and surplus
    • 3) In order to prepare certificates of payment records of the fee for use of real estate, etc.
    • 4) In order to prepare certificates of payment records of the value for the transfer of real estate, etc.
    • 5) In order to prepare any other legal documents that specified by the Individual Number Law
  5. 5. Consigning the Handling of Personal Information and the Specific Personal Information

    The following cases are examples of when our company consigns the handling of the personal information and the specific personal information.
    (Examples of Consignment)

    • ·Consigning the Administration of the Shareholder Register (including the preparation of certificates of payment records of dividend and surplus)
  6. 6. Providing Personal Information and the Specific Personal Information to Third Parties

    Our company shall not provide to third parties personal information that is held by our company without obtaining consent from the client except as provided by law.
    However, we may provide client's personal information without client's consent in the case of consigning personal information to the extent necessary for achieving the purpose of use, in the case of merger etc, and in case of shared use with a specific person specified in this text.
    Our company shall not provide the specific personal information to any third party with or without obtaining consent from the client except in cases specified by law.

  7. 7. Sharing of Personal Data

    Our company, as follows, shares within the Group the personal data of our clients in accordance to Article 23, Paragraph 5, No. 3 of the Personal Information Protection Law. However, our company shall not share the specific personal information.

    (1) Category for Shared Use of Personal Data

    Category for Name, Address, Date of Birth, Telephone Number, and Information Related to Credit Management

    (2) Range of Shared Use

    Our company and the consolidated subsidiaries and affiliated companies listed in our securities report
    (If the shared use is restricted by law in accordance to the Financial Instruments and Exchange Act, etc., then it will be handled in accordance with applicable law.)

    (3) Purpose of Use

    In order to identify and manage various risks for the management of the Group

    (4) Personal Data Manager

    Sumitomo Mitsui Trust Holdings, Inc.

  8. 8. Requesting Procedures for the Disclosure of Personal Data, etc.

    Our Company shall take the following steps when a request is made by the person in question or their representative to disclose the personal data (including the specific personal information file) that we retain.
    For details of the procedure please refer to "Documents to be Submitted when Requesting Disclosure, etc."

    (How to Apply)

    If the person in question or their representative requests disclosure of their personal information that we retain then they must fill out our prescribed form and bring it or mail it in along with documents that prove their identity to "1. Inquiry Liaison for the Personal Information that Our Company Handles."

    (Fees)

    With regard to disclosure of retained personal data, the Company will collect the prescribed fee when a request is submitted. Also, please understand that the prescribed fee will be collected even if disclosure is not possible.

    (Replies)

    After the application is submitted, a written response will be mailed, etc.
    In addition, please understand that it usually takes up to 2 weeks to process a request.

  9. 9. Authorized Personal Information Protection Organization

    Our company falls under the following authorized personal information protection agency. The liaison of the following agency will also accept complaints or questions about our handling of the personal information and the specific personal information.

    All Banks Personal Data Protection Council
    http://www.abpdpc.gr.jp/  "Japanese only"
    [Complaints and Consultation Liaison]03-5222-1700 or a bank transaction counseling center near you

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