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Privacy Policy for State Street Trust & Banking Co., Ltd.

State Street Trust & Banking Co., Ltd. (hereinafter referred to as "the Company"), in performing business operations, will establish the policy regarding appropriate protection and use of personal information and take every measure for personal information protection.

1. Compliance with relevant laws and regulations

In handling of personal information, the Company will comply with the "Act concerning Protection of Personal Information" and other relevant laws and regulations.

2. Acquisition / use of personal information

The Company will obtain personal information by appropriate methods. In obtaining personal information, the Company will promptly notify to the relevant individual or publicize the purpose of use unless otherwise publicized in advance.

The Company will not obtain / use / provide to third parties any sensitive information except under certain exceptional circumstances, such as requirement by laws and regulations or protection of the person’s life, body or its property, etc.

The Company will not use personal information obtained beyond the extent necessary for achievement of the specified purpose of use unless prior consent is obtained from the relevant person in advance or unless required otherwise under laws and regulations.

3. Provision of personal information to third parties

The Company will not provide the acquired personal data to third parties except the following cases; when mandated by laws and ordinances, when necessary to protect life, body or property of a person and it is difficult to obtain the consent of the relevant individual, when entrusting all or part of the personal data within a scope of the purpose of use, and when necessary to cooperate with the execution of legally-defined duties by central government institutions, local government agencies or their entrusted deputies and obtaining the consent of the relevant Individual would potentially impair execution of said duties.

Such consent of provision to a third party shall include on a written form the name of a third party the personal data is provided, the purpose of use by the third party and the information to be disclosed.

4. Notification / publication of purpose of use of personal information

Upon obtaining personal information, the Company will promptly notify to the relevant individual or publicize the purpose of using the personal information unless otherwise clearly stated in advance,

The details of the purpose of use is stated and publicized as per “Purpose of Use and Joint Use of Personal Information at the Company”.

5. Disclosure, etc. of personal information

Upon receiving request from the relevant person for disclosure of his/her retained personal data, unless the disclosure would cause a serious problem with appropriate implementation of the business, the Company will disclose data to such person.

Upon receiving request from the relevant person for correction, addition, or deletion of the content of the retained personal data or suspension of use, elimination, etc. of the relevant personal data, the Company will respond to such request by taking appropriate measures in accordance with the Company’s defined procedure without any delay,

Please refer to the notice posted in our office for the specific procedure for disclosure, etc.

6. Security management of personal data

In handling personal data, the Company will implement the basic policy and the rules for handling, etc. for security management, establish an organization for implementation and take necessary and appropriate security management measures in order to prevent leakage, loss, damage, etc. concerning personal data.

Organizational security measures: The Company assigns an chief personal data security manager for personal data security, implement the rules for handling and establish a method to check the management and its status as audit system to prevent leakage,

Human resources security measures: The Company executes the non-disclosure agreement with its employees, clarifies their roles and responsibilities, trains the management rules to raise awareness and check all of the human resources management.

Technical security measures: The Company identifies / authenticates the users of the personal data, sets up the management type, controls access, manages access authority and implements the preventive measures of leakage / damage of the personal data.

7. Outsource the personal data

When the Company needs to outsource all or any part of handling of the personal data within the scope necessary to achieve the purpose of use, the Company shall conduct necessary and appropriate supervision over the outsource contractors for security management of the personal data.

8. Complaint handling concerning personal information

Upon receiving complaints concerning the handling of personal information, the Company will address them quickly and appropriately.

9. Contact point for inquiries and complaints

Phone No.: 03-4530-7200

Service hours: Monday – Friday (except for national holidays and other bank holidays) 9:00 am – 5:00 pm

The Company is a member of the Trust Companies Association of Japan, an authorized personal-information protection organization acknowledged under the Personal Information Protection Law. The contact point for complaints and consultation (Trust Consultation Center) of the Trust Companies Association of Japan responds to complaints and consultation about the handling of personal information by its member companies.

Trust Companies Association of Japan (Contact Point for Trust Consultation)
http://www.shintaku-kyokai.or.jp/
Contact Point for Complaints / Consultation:
Phone: (03) 6206-3988 or 0120-817335 (toll free number)

10. Complaint handling concerning personal information

Upon receiving complaints concerning the handling of personal information, the Company will address them quickly and appropriately.

Privacy Policy for State Street Global Advisors (Japan) Co., Ltd.

We hereby announce this Declaration of Personal Information Protection as part of our policy on handling your personal information.

1. Compliance with relevant laws and regulations

We hereby declare that we will comply with any and all the laws and regulations including the Personal Information Protection Act 2005 of Japan, the guidelines set by the ministers in charge and the policies of the authorized personal information protection organizations, and this Declaration of Personal Information Protection.

2. Purposes of Use

We will limit the use of your personal information to the extent necessary to carry out our purposes of use. Such limitation of use will not be applicable when you consent otherwise, and the laws or regulations require exceptional handling of it.

The notice of our purposes of using your personal information is posted at the head office and on our website, etc.

3. Measures to Ensure Safety Control

We will endeavor to keep your personal information accurate and the most up-to-date. In addition, we will take necessary and appropriate measures to ensure safety control of your personal information, and properly supervise our managers and employees, and the subcontracting parties in order to prevent the leakage or other unauthorized use of your personal information.

4. Continuous Disclosure

We will continue to seek improvements of this Declaration of Personal Information Protection by the appropriate review in order to make the handling of your personal information better and more appropriate.

5. Procedure for Requesting Disclosure

We will endeavor to properly and promptly respond to your request to, for example, disclose, correct, or suspend the use of your personal data held by us after confirming your identification.

6. Questions and Remarks

We will endeavor to properly and faithfully respond to your questions and remarks about our handling of personal information. Please contact our following division for questions and remarks:
Compliance and Risk Management Department
Toranomon Hills Mori Tower 25F, 1-23-1 Toranomon, Minato-Ku, Tokyo 105-6325
(phone number: 03-4530-7085) (service hours: 9 a.m.-5 p.m. on weekdays)

7. Authorized Personal Information Protection Organization

We are a member firm of the Japan Investment Advisers Association, the Investment Trusts Association and the Japan Security Dealers Association, which are the personal information protection organizations authorized by the Financial Services Agency. Please contact the common “Complaints Counseling Services Center” managed by these organizations for complaints and counseling on our handling of personal information.

(Complaints and Counseling)
Complaints and Counseling Services Center
for Financial Instruments Transactions
(phone number: 0120-64-5005).

Privacy Policy for State Street Global Markets (Japan)

We hereby establish and publicly announce this Declaration of Personal Information Protection as part of our policy on handling of your personal information.

1. Compliance with Laws and Regulations

We hereby declare that we will handle your personal information in compliance with any and all the laws and regulations including the Personal Information Protection Act 2005 of Japan, the guidelines set by the competent ministers and the authorized information protection organization, and this Declaration of Personal Information Protection to ensure the protection of your personal information.

2. Purposes of Use

We will limit the use of your personal information to the extent necessary to carry out our purposes of use. Such limitation of use will not be applicable when you consent otherwise, and the laws or regulations require exceptional handling of it.

The notice of our purposes of use is posted at the head office, the copy of which is attached hereto as Exhibit

3. Administrative Measures to Ensure Safety

We will endeavor to keep your personal information accurate and the most up-to-date. In addition, we will take necessary and appropriate administrative measures to ensure safety of your personal information, and properly supervise our managers, employees, and parties having contractual relations with us to prevent leakage or other unauthorized use of it.

4. Continuous Improvement

We will continue to seek improvements by regularly reviewing this Declaration of Personal Information Protection to make the handling of your personal information better and more appropriate.

5. Request for Disclosure

We will endeavor to properly and promptly meet your request of us to, for example, disclose, correct, or delete your personal information held by us by asking for your identification.

6. Questions and Remarks

We will endeavor to properly and faithfully respond to your questions and remarks about our handling of personal information. Please contact our Compliance Department (phone number: 03-4530-7583) for questions and remarks.

7. Authorized Information Protection Organization

We are a member firm of Japan Security Dealers Association, one of the information protection organizations authorized by the Financial Services Agency. Please contact your local office of the Mediation and Counseling Services Center, Japan Security Dealers Association for complaints and counseling on our handling of personal information.

(Complaints and Counseling)
Mediation and Counseling Services Center,
Japan Security Dealers Association
Phone Number: 0120-25-7900
http://www.jsda.or.jp/.

Privacy Policy for State Street Bank & Trust Company,
Tokyo Branch

State Street Bank and Trust Company, Tokyo Branch (the “Bank”) hereby establishes this policy regarding the appropriate protection and use of personal information in accordance with the “Personal Information Protection Act (Law No. 57 of 2003) of Japan,” thereby taking all possible measures to ensure the protection of your personal information.

1. Compliance with Laws and Regulations

The Bank hereby declares that the Bank will comply with any and all laws, regulations and other requirements, and matters set out in this Declaration in relation to the appropriate protection and use of personal information.

2. Purposes of Use of Personal Information

The Bank shall identify the purposes of use of your personal information in advance. The notice of our purposes of use is posted at the office of the Bank.

The Bank shall never use your personal information without your consent for purposes other than those specified in advance, unless otherwise required by any law or regulation.

The Bank will suspend the use of your personal information for direct mail, telemarketing or other direct marketing, if you request us to do so. If you do not wish that the Bank uses your personal information for direct marketing, please call the contact center described in 8 below.

3. Acquisition and Provision of Personal Information

The Bank shall acquire your personal information via lawful and fair means to the extent necessary to achieve the specified purposes of use. In addition, except under exceptional circumstances, such as requirement by any law or regulation, the Bank shall not acquire, use or provide to third parties any sensitive information.

The Bank shall not provide your personal information to third parties without your prior consent, unless otherwise required by any law or regulation.

If the Bank outsources the handling of personal information, the Bank shall select the person whom the Bank considers appropriately handles personal information, and exercise the necessary and appropriate supervision over such person.

4. Disclosure and Other Procedures

Upon receiving request from you for disclosure, correction, or suspension of use of the personal data held by the Bank (the “Disclosure etc.”) pursuant to laws and regulations, the Bank will appropriately and promptly respond to such request by asking for your identification. To request the Disclosure etc. of personal data held by the Bank, please call the contact center described in 8 below.

5. Security Management Measures

The Bank will implement the security management measures necessary and appropriate to prevent illegal access, loss, destruction, falsification, leakage, or other unauthorized use of your personal information.

6. Complaint Handling

Upon receiving complaints concerning the handling of personal information, the Bank will appropriately handle such complaint by the prompt investigation of the facts.

7. Efforts for Continual Improvement

The Bank will strive for continual improvement in handling personal information (including security management measures), such as reviewing as needed.

8. Contact Center

For inquiries, counseling or complaints regarding the Disclosure etc. of personal data held by the Bank or handling of personal information, please call the following Department:
Contact center for personal information: Compliance Department

Phone: 03-4530-7690

Service Hours: 9 a.m.-5 p.m. (Monday-Friday, except public holidays and other bank holidays)

 

Authorized information protection organizations to which the Bank belongs

The Bank is a member firm of the All Banks Personal Data Protection Council, an authorized information protection organization in the financial field. The Complaints Counseling Services Center of the All Banks Personal Data Protection Council (bank transaction counseling center) receives complaints and gives counseling regarding the handling of personal information by member firms.

All Banks Personal Data Protection Council: http://www.abpdpc.gr.jp

(Complaints and Counseling) phone number: 03-5222-1700 or your nearest bank transaction consulting center.