1.Ichigo’s Commitment
All Ichigo directors and part- and full-time employees, regardless of their employment status (“Ichigo Employees”), shall be made aware of the contents of this Policy. Ichigo shall establish and maintain this Policy through the implementation of an appropriate corporate governance and internal rule framework.

2.Acquisition and Use of Personal Information
Ichigo establishes herewith that personal information shall be acquired and used only to the extent necessary to effect legitimate business purposes. However, Specific Personal Information as defined under Japanese law shall be acquired and used only to the extent prescribed in relevant laws and regulations.

3.Purpose of Use of Personal Information (Note 1)
Ichigo shall indicate the purpose for its use of personal information through public disclosure or written notification. Ichigo shall use personal information only in accordance with such stated purpose and in no case shall the use of personal information exceed the scope of consent received from the relevant person. However, Specific Personal Information shall not be used for any purpose beyond those permitted by law.

4.Provision of Personal Information to Third Parties (Note 2) (Note 4)
Ichigo shall not provide personal information to third parties without the consent of the relevant person unless required by applicable law. As for Specific Personal Information, Ichigo will not provide or disclose the information to third parties unless permitted by law.

5.Delegation of Handling of Personal Information
Ichigo may delegate the handling of personal information to third parties that handle personal information in a compliant and appropriate manner. In such case, Ichigo shall supervise such delegated parties as necessary.

6.Sharing of Personal Information (Note 3) (Note 4)
Ichigo may share and mutually use personal information within Ichigo companies in accordance with both applicable law and stated purpose of use. However, under no circumstance will Ichigo share Specific Personal Information within Ichigo companies.

7.Measures for Protection of Personal Information
Ichigo shall take appropriate technical and organizational measures to secure personal information from unauthorized access, loss, destruction, manipulation, and/or disclosure to any third parties.

8.Internal Rules and Training Regarding the Protection of Personal Information
Ichigo shall establish internal rules with respect to protection of personal information, and provide appropriate training to Ichigo Employees to ensure awareness and compliance.

9.Disclosure, Amendment and Cessation of Use Of Personal Information
In the event the relevant person so requests, Ichigo shall immediately disclose, amend and/or cease the use of personal information in accordance with procedures established separately by Ichigo.

10.Continual Review of Internal Governance Structure
Ichigo shall, in accordance with all relevant laws and ordinances, continually review and improve its internal governance structure for protecting Personal Information.

11.Inquiries Concerning Personal Information

（3） Ichigo Si Co., Ltd.
Address：The Imperial Tower 17F , 1-1-1 Uchisaiwaicho, Chiyoda-ku, Tokyo

(Note 1)Personal information acquired by Ichigo shall be used for the following purposes:

1.To solicit, sell and manage Ichigo’s real estate products, including quasi-partnership (tokumei kumiai) agreements for real estate funds, and to provide services related thereto;
2.To provide information regarding the solicitation, sale and management of real estate products for Ichigo and affiliated companies;
3.To assess the appropriateness of providing products and services to clients;
4.To verify the identity of the related person and any agents of the related person;
5.To report deposit balances and asset management results to clients;
6.To carry out business with clients and counterparties;
7.To carry out legal obligations and contract rights of Ichigo;
8.To use in research and data gathering and analysis in the course of Ichigo’s business;
9.To dispose of personal information in an appropriate manner in case of being delegated to do so by third parties;
10.To provide appropriate information to shareholders and investors and manage shares in the course of Ichigo’s investor relation services;
11.To report and exchange information with government authorities as necessary;
12.To contact job applicants and keep and manage employee records; and

(Note 2)Ichigo shall not provide any personal information to third parties without prior consent received from the relevant person except for the following (1) to (4).

1.In the event where disclosure is required by applicable law or ordinance;
2.In the event receiving timely consent is difficult and disclosure is necessary to protect life or property;
3.In the event receiving timely consent is difficult and disclosure is particularly necessary for educational purposes or to protect public health; and
4.In the event necessary to cooperate with government or local authorities in their execution of official work where the acquisition of consent from the affected person may interfere with such official work.

2.
Notwithstanding the above, in the event Ichigo provides personal information (excluding sensitive personal information and personal information that requires special attention) to third parties, Ichigo will cease to provide information that can be used to identify the affected person if so requested, and pursuant to the rules of the Personal Information Protection Commission will either pre-notify the affected person or make readily accessible on its website the following items. Ichigo shall also notify the Personal Information Protection Commission of any such disclosure to third parties.

1.Purpose of use includes disclosure to third parties
2.Personal information to be disclosed to third parties
Name, address, and property information of persons engaging in real estate or debt transactions
3.Methods of disclosure to third parties
Written materials, mail correspondence, telephone, FAX, electromagnetic mediums, or advertising channels
4.Disclosure to third parties can be ceased upon request
5.Method for receiving requests

3.
Ichigo shall pre-notify the relevant person of any changes to the above stipulations or make the content of changes readily accessible, and will also notify the Personal Information Protection Commission of such changes.

4.
Immediately upon the Personal Information Protection Committee officially announcing information with respect to notifications made pursuant to Articles 2 and 3, Ichigo shall disclose via its website or other appropriate methods the content of each items of Article 2 (in the event items (2), (3) or (5) are amended, the amended items).

5.
Where personal information is provided under the following cases, the recipient will not be deemed a third party with respect to each article above:

1.In the event Ichigo delegates the handling of all or part of personal information within the scope of its purpose of use
2.In the event personal information is provided as a result of merger, business succession, etc.
3.In the event personal information is provided pursuant to Note 3 below and the following items have either been pre-notified to the relevant person or made readily accessible: the fact that personal information would be shared, the items of personal information to be shared, the scope of users, purpose of use, and name of the person responsible for managing relevant personal information

(Note 3) Ichigo may share and mutually use personal information within Ichigo companies in accordance with both applicable law and stated purpose of use.

1.Information Sharing Entities
All Ichigo companies (including Ichigo Office, Ichigo Hotel, and Ichigo Green)
2.Subject Information
Names, addresses, building information, etc.
3.Purpose of Use
As specified in Note 1
4.Manager Responsible for Supervision of Personal Information
Managers Responsible for Supervision of Personal Information
Compliance Officers of each Ichigo company (except for Ichigo Investment Advisors where the manager responsible is the Head of Risk Management & Compliance; Ichigo Real Estate Services Fukuoka and Ichigo Owners, where the manager responsible is the Head of Administration; Ichigo ECO Energy and Ichigo Marche where the manager responsible is the Head of Administration & Planning; and Ichigo Land Shinchiku, where the manager responsible is Director).

(Note 4) Notwithstanding Note 2 and Note 3, Ichigo will not provide Specific Personal Information to third parties unless required by law.