Personal Information Protection Policy

Asia Pacific Land (Japan) Limited

Amended on May 30, 2017


Article 1 (Personal Information Protection Policy)

As a corporation engaged in the financial instruments business, real estate business, and real estate investment asset management business, Asia Pacific Land (Japan) Ltd. (“APL” or the “Company”) recognizes protection of personal information as an important social responsibility of the Company. In all of our business operations that involve personal information, protection of such information is considered as one of the top-priority issues. To protect personal information in a proper, reliable manner, APL specifies the following policy and all employees of APL shall abide by this policy to properly handle and manage personal information both inside and outside the Company.


  1. Matters Relating to Collection, Use and Disclosure of Personal Information.
    • If personal information is collected, it is done in accordance with appropriate procedures and if such information is to be maintained or used in any way beyond what is needed to achieve the specified purpose (as set forth in Article 2) unless otherwise permitted by law, such information shall only be used after consent is obtained from the owner (or from the requester with the owner’s consent). Subject to certain disclosures described in Articles 3 and 4 below, a consent is also obtained when collected personal information is disclosed to a third party unless such disclosure is otherwise permitted by law.
    • If the owner (or requester with the owner’s consent) requests the information collected about the owner to be disclosed, corrected or for its use to be suspended, the applicable information will be disclosed/ corrected/ and / or suspended from use accordingly in accordance with the provisions set forth in Article 5.
    • With respect to “Specified Personal Information” (i.e., personal information which includes individual numbers (the so called “My Number”) in its contents), the same protections set forth below shall apply and internal rules shall be established in relation thereto; such numbers must be obtained and managed in accordance with the appropriate purpose of use and through appropriate methods.


  1. Matters Relating to Security of Personal Information

Our Company shall designate a Personal Information Manager and limit the number of persons handling personal information to the required minimum. Our Company shall also undertake to prevent or correct divulgement, loss or damage of personal information and implement the necessary and appropriate security management measures.


  1. Matters Relating to Complaint or Consultation from the Owner

If the owner lodges a complaint or request to or consults APL as to what we are doing to protect personal information, the Personal Information Desk will explain the details to the owner and attend to the matter diligently, while the Manager will take an appropriate action.


  1. Matters Relating to Laws, National Guidelines and Other Standards on Handling Personal Information

Our Company, in addition to abiding by the laws, national guidelines, ordinances or other standards on handling personal information, we shall also set forth internal regulations to abide by the foregoing, review these regulations as necessary and make continuous improvement thereof, and implement the regulations properly.


  1. Matters Relating to Continuous Improvement of Personal Information Protection/Management System.

Our Company shall conduct regular internal audits on the implementation conditions of 1, 2, 3 and 4 above. Should any noncompliance occur, we will identify and implement corrective measures as necessary as part of our effort to improve the system continuously.


This policy is posted in the Company and communicated to all employees including officers. We shall also work to educate and edify employees and raise their awareness of the need to protect personal information.


Article 2 (Purpose of Use of Personal Information)

The purpose and use of personal information are as follows:

  • Business relating to execution of contracts relating to acquisition, management and disposition of real estate etc. (including trust beneficial interests etc.) and provision of services and information in connection therewith
  • Business relating execution of contracts related to sales, brokerage, financing and maintenance of real estate etc. and provision of services and information in connection therewith
  • Business relating execution of contracts relating to consulting and advisory services and the provision of services and information in connection therewith
  • Business relating to execution of contracts relating to provision of due diligence services (real estate and loan valuations or pricing analysis) and the provision of services and information in connection therewith
  • Administration of the shareholders of our Company and other group companies of Asia Pacific Land Ltd. located in Hong Kong to which our Company belongs (hereinafter collectively and individually referred to as “APL Group”).
  • Administration on behalf of APL Group counterparties
  • Administration relating to APL Group directors, officers, employees and contract employees
  • Administration related to recruitment and hiring of directors, officers and employees
  • Communications and contact through written documentation, mail, telephone, fax or electronic mail in connection with all of the above
  • To provide third parties with personal information if necessary to achieve the above purposes  (as stated in Article 3; provided, however, that Specified Personal Information shall be excluded)


The information used is as follows:

  • Proprietary information of the individual concerned (Name, address, telephone number, gender, date of birth, place of employment, etc.)
  • Information relating to loan claims (Date of contract, loan claims principal, agreed amount of repayment, history of deposits, etc.)
  • Information relating to real estate-related contracts or agreements (Date of contract, terms and conditions, status of enforcement of Lease Agreements, Purchase and Sale Agreements for Real Estate, finance documents related to real estate, etc.)
  • Others, information concomitant with (a), (b) and (c) above (Real-estate evaluation information/other assets-held information, etc.)


Notwithstanding the purpose for utilizing personal information as stated in the preceding items, the purpose of using Specific Personal Information is to manage administrative matters related to our employees, our employees’ spouses and dependents, and persons other than employees related to the administration of real estate etc. within the scope of laws and regulations.


Article 3 (Disclosure of Personal Data to Third Parties)

There are circumstances from time to time where Personal Data, other than Specified Personal Information, such as real estate information, names, address and related family information, will be disclosed to third parties through written documentation, mail, telephone, fax, electronic mail,  advertisement, or by other means, as may be permitted by applicable laws and regulations and to the extent necessary to achieve the purposes outlined above.

APL will refrain from any such disclosure upon request or application via a telephone call to the contact person described in Article 6 from the persons related to such Personal Data to the extent such person has not separately agreed to permit such disclosure to third parties.

(Examples of Third Party Disclosure) * Please note that this list of examples is not intended to be exhaustive or comprehensive and is for illustrative purposes

  • Disclosure to a transaction or contractual party, or someone likely to become such party
  • Other Level 2 Financial Instruments and Exchange Law license holders and Real Estate brokerage license holders
  • Internet advertisements and other industry-related and group bulletin boards
  • Designated distribution systems (real estate registrations, notice, etc.)
  • Judicial scriveners and specialists in connection with registration matters
  • Trusts, trust banks, financial institutions, financial instruments license holders, money lending license holders, etc.
  • Property managers in connection with property management, financial institutions receiving fund transfers, administrative personnel
  • Professional advisors such as lawyers, public accountants, tax advisers, appraisers, insurances providers, etc.
  • Real estate information and survey providers
  • National and local governments and other service providers
  • APL Group counterparties and business partners


Article 4 (Shared Use of Personal Data)

Personal Data collected in connection with recruiting and hiring APL Group directors and officers may be shared; provided that Specified Personal Information is excluded.

  • Personal Information subject to Shared Use

APL Group director and employee information collected in connection with recruiting and hiring including name, address, telephone number, e-mail address and family information

  • Extent of Shared Use

APL Group subsidiaries, affiliates and related companies

  • Purpose of Shared Use discloses

Employee screening and review for purposes of APL Group recruiting and hiring

  • Responsible Person

Asia Pacific Land (Japan) Limited


Article 5 (Requests for Disclosure, Amendments, Suspension of Usage, etc.)

In cases where the individual concerned requests such actions as disclosure, amendment or suspension of usage of personal data the company retains, the identity of the said individual shall be confirmed and, unless there is a specific reason not to do so, the requested action shall be taken promptly in full compliance with the law.

Applications for such procedure must be submitted in the format prescribed by the Company.
All other inquiries regarding personal information should be directed as detailed hereunder.

Please also note that the requested information disclosure shall, as a basic rule, be forwarded by postal mail. However, confidentiality obligations to the provider of personal information prohibit us from disclosing the same.


Article 6 (Contact for Personal Information Related Matters)

The administrator of personal information within the company and contact information is detailed below.
Hotline for complaints and consultation regarding personal information:


Asia Pacific Land (Japan) Limited, Japan Branch

Internal Control & Compliance Department

03-4560-7000 (Reception Time 10:00 to 17:00, Business Day)