Privacy Policy

Privacy Policy

Aetos Japan, LLC, Japan Branch (hereinafter “the Company”) will comply with the “Act on the Protection of Personal Information” (Act No. 57 of 2003, hereinafter, “Personal Information Protection Act”) and its related laws, ordinances and guidelines of supervisory authorities, and disclose our privacy policy as follows.

  1. Reasonable Acquisition of Personal Information
    The Company will obtain and use personal information required for execution of business in a manner appropriate and just, within the scope of the objective to be achieved, and will not obtain personal information through falsification or other unjust means.
  2. Prohibition on Use Other than for Intended Purposes
    The Company will use personal information within the scope necessary to achieve the intended purpose.
    Regarding intended purposes, please refer to “Other Matters Disclosed under the Act on the Protection of Personal Information 1.”. The intended purpose can be modified within the scope reasonably deemed as being related and will be disclosed in such cases.
  3. . Disclosure Procedures
    The Company will respond quickly to any requests to disclose, amend, delete, suspend use of an individual’s personal information. Please refer to “Other Matters Disclosed under the Act on the Protection of Personal Information 4.” for details regarding these procedures.
  4. Contact Information for Inquiries regarding the Handling of Personal
    Information
    Please contact the following for any inquiries regarding the Company’s handling of personal information.
    Aetos Japan, LLC Corporate Services Division, Legal and Compliance
    16F Mita Kokusai Building, 1-4-28 Mita, Minato-ku, Tokyo, 108-0073
    Phone: 03-6275-1950
    (Business Hours: Monday – Friday 9:00~17:00)

Basic Policy concerning Safe Management of Personal Data

  1. Name of Business Operator Handling Personal Information
    Aetos Japan, LLC, Japan Branch
  2. Contact Information for Inquiries and Complaints regarding Safe Management Measures
    Aetos Japan, LLC Corporate Services Division, Legal and Compliance
    16F Mita Kokusai Building, 1-4-28 Mita, Minato-ku, Tokyo, 108-0073
    Phone: 03-6275-1950
    (Business Hours: Monday – Friday 9:00~17:00)
  3. Safe Management of Personal Data
    The Company will enforce the following organizational, physical, and technical measures for the appropriate safe management of personal data to prevent leakage, loss, or damage.

Other Matters Disclosed under the Personal Information Protection Act

Matters disclosed under the Personal Information Protection Act (hereinafter, “the Act”
is as follows.

  1. Intended Purpose (Article 18 of the Act)
    The company will obtain and use personal information within the scope necessary to accomplish the intended purpose listed below.

    1. With regards to type 2 financial instruments business/investment advisory business/personal investment for real estate related investments, to purchase (including consideration of purchase)/ manage/dispose (including consideration of disposition) assets for investment, and to introduce/provide various services incidental or related, and to conduct business related to these transactions.
    2. To exercise rights and perform duties in compliance with contracts and laws and ordinances, as necessary for ① above.
    3. To adequately and smoothly execute the Company’s business related to ①② above.
    4. To manage employment and hiring practices of the Company.
    5. To provide to a third party within the scope necessary to appropriately execute business, in compliance with contracts and laws and ordinances, as related to ①to④ above.
  2. Matters regarding the Provision of Personal Information to Third Parties
    (Article 23 of the Act)
    The Company will not provide personal information to a third party without the consent of the person concerned (including cases where consent of the person concerned can be assumed from the actual circumstances of the transaction) or as otherwise stipulated by law and regulation. Furthermore, information considered sensitive under the guidelines of personal information protection in the financial sector, unless recognized by law and such guidelines, will not be provided to a third party. However, if the handling of personal data is outsourced, for the succession (or consideration for succession) of the real estate rental business of the investment assets, where legally, it is not considered a provision to a third party, within the scope necessary to accomplish the intended purposes outlined in “1. Intended Purpose”, personal data can be provided to the outsourcing company, successor (including prospective successor), or other legally recognized party.
  3. Matters regarding Shared Use of Personal Data (Article 23, Paragraph 5, No. 2 of the Act)
    The Company could share the use of personal data obtained with specific entities, for the following reasons.

① Items of personal data to be shared

② Entity to be shared with
The Company’s parent company, Aetos Capital Real Estate LP

③ Intended purpose of user
As previously stated in “1. Intended Purpose”

④ Responsibility for management of personal data to be shared
The Company.

4. Matters regarding Personal Data in Possession (Article 27, Paragraph 1 of the Act)
Matters regarding personal data in possession by the Company are as follows.

① Name of operator handling personal information
Aetos Japan, LLC, Japan Branch

② Intended purpose of all personal data in possession
As previously stated in “1. Intended Purpose”.

③ Procedure for disclosure, amendment, elimination, and suspension of use With regards to personal data in possession by the Company, if disclosure, amendment, elimination, or suspension of use is requested, please first contact the Company’s management or the point of contact listed in “5. Contact for Inquiries and Complaints”. We will provide information on documents (such as documents to verify identity of the requester) to be prepared. Once identity is confirmed, we will respond as soon as possible upon investigation.

④ Inquiries and complaints regarding disclosure, etc.
Per 5. below.

5. Contact for Inquiries and Complaints (Article 35 of the Act)
For inquiries and complaints regarding personal data in possession by the
Company, please contact the following point of contact.

Aetos Japan, LLC Corporate Services Division, Legal and Compliance
16F Mita Kokusai Building, 1-4-28 Mita, Minato-ku, Tokyo, 108-0073
Phone: 03-6275-1950
(Business Hours: Monday – Friday 9:00~17:00)