Privacy Policy

Enex Infrastructure Investment Corporation (“EII”) shall comply with the Act on the Protection of Personal Information (the “Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the "Numbers Act") and other related laws and regulations, applicable guidelines (the “Guidelines”) and “guidelines for protecting personal information” set forth by the Investment Trusts Association, Japan; and shall do its utmost to properly handle personal information in accordance with the following privacy policy.

1. Basic Policy

EII shall strive for proper and secure handling and management of personal information in compliance with the Personal Information Protection Act, the Numbers Act and other related laws and regulations, the Guidelines, etc.; not using personal information for purposes other than originally intended; and appropriately responding to complaints, etc.

2. Acquisition of Personal Information

EII shall acquire personal information to the extent necessary for carrying out operations through proper and legal means. Prior to acquiring personal information, EII shall announce the purpose of use on its website, etc. When receiving personal information directly from the person in documents, through the website, etc., EII shall specify the purpose of use of the personal information in advance. However, when the purpose of use is clear from the circumstances in which the personal information is acquired, or in other cases where it is in accordance with laws and regulations, explicit statement of purpose of use may be omitted.

3. Purpose of Use of Personal Information

EII shall use personal information for the following purposes. Personal information will not be used for any other purpose, except as the following purposes. Also, personal information will not be used in a method that is likely to encourage or induce illegal or wrongful conduct.

  1. To verify the identity of individuals stated in documents exchanged between EII and third parties, including applications received by EII and contracts concluded by EII, and to conduct credit checks on said individuals.
  2. To carry our operations such as research and analysis, collection of data, discussion, conclusion of contracts, execution of contractual rights and obligations for acquisition, management, maintenance, disposition of EII’s assets.
  3. To ensure exercising of rights of unitholders of EII (the “Unitholders”) and fulfillment of obligation to Unitholders.
  4. To provide information concerning business operations, etc. to Unitholders.
  5. To handle preparation and submission of EII’s notifications, reports, etc. pursuant to the Act on Investment Trusts and Investment Corporations, the Financial Instruments and Exchange Act, and other relevant laws and regulations.
  6. To prepare EII’s unitholder register and other data, and manage other unitholder information.
  7. To handle provision of information, communication, marketing, etc. concerning investment units, investment corporation bonds and investment unit acquisition rights issued by EII.
  8. To handle EII’s issuance of investment units and investment corporation bonds, issuance of investment unit acquisition rights, debt financing and other fund procurement as well as IR activities and operations.
  9. To carry out other tasks and operations incidental or related the purposes of use listed in (1) through (8) and that are deemed necessary to facilitate appropriate and smooth execution of tasks entrusted by EII.
  10. To facilitate appropriate and smooth execution of other tasks of EII.

4. Provision of Personal Data to Third Parties

EII may provide retained personal data to third parties within the scope necessary to achieve the purpose of use described in 3 above, after obtaining consent from the individual. However, EII may provide personal information to third parties without obtaining the individual’s consent in cases where it is permitted by the Personal Information Protection Act and other related laws and regulations, the Guidelines, etc. EII shall cease provision to third parties upon request from the individual after verifying their identity. Please contact the “Inquiry Desk” below for further details.

5. Handling of Sensitive Information

EII shall not acquire, use or provide to third parties any sensitive information unless otherwise provided for in the Personal Information Protection Act and other related laws and regulations or in the Guidelines, etc.

  • Sensitive information refers to sensitive information defined in Article 5, Paragraph 1 of the ”Guidelines for Personal Information Protection in the Financial Field” compiled by the Financial Services Agency.

6. Request for Notification of Purpose of Use, Disclosure, Etc. of Retained Personal Data

Concerning personal data of an individual retained by EII, EII shall appropriately respond to requests for notification of purpose of use and requests for disclosure (including disclosure by methods such as provision of electromagnetic records), correction of contents, addition, deletion, suspension of use, removal or cessation of provision to third parties (collectively, the “Disclosure, etc.”) if so requested by the individual, after verifying that the individual is entitled to such request(s). However, if notification of purpose of use or the Disclosure, etc. violates other laws or regulations, EII may not be able to respond to demands for notification of purpose of use or the Disclosure, etc. In such case, EII will endeavor to explain the reason to the individual. When requesting notification of purpose of use of retained personal data or requesting the Disclosure, etc., please contact the inquiry desk below. No fees are charged for handling the request for the Disclosure, etc.
The same will apply to disclosure of records of provision to and from third parties regarding acceptance or provision of personal data.

7. Security Control Measures Concerning Personal Data

EII shall take necessary and appropriate control measures for security to ensure prevention of leakage, loss or damage of personal data. EII shall provide education, training, etc. on protection and appropriate management of personal information to officers, and thoroughly implement appropriate handling of personal information. In addition, in cases where EII outsources the handling of personal data, EII shall exercise the necessary and appropriate supervision over the service provider to ensure the security of the outsourced personal data.

8. Continuous Improvement

EII shall establish internal rules and procedures concerning protection of personal information, including this policy, to handle personal information properly, and continually make improvements by informing officers, performing review as needed, etc. to ensure such measures are effective.

9. Handling of Complaints

EII shall respond sincerely to complaints regarding handling of personal information, and make efforts to handle such in a prompt and appropriate manner.

10. Inquiry Desk

  • Please contact below to request Disclosure, etc. of personal information on personal data retained by EII, inquire about control measures for security, file a complaint, etc.
Name
Finance & Accounting Department, Enex Asset Management Co., Ltd.
Address
Kasumigaseki Building 29F, 3-2-5, Kasumigaseki, Chiyoda-ku, Tokyo 100-6029
TEL
+81-3-4233-8330
Business hours
10:00 a.m. to 5:00 p.m.
(excluding Saturdays, Sundays, national holidays, and year-end and New Year holidays)
  • For matters concerning unitholder register entries, please contact the following department at Sumitomo Mitsui Trust Bank, Limited, which is our transfer agent.
Name
Stock Transfer Agency Business Planning Department, Sumitomo Mitsui Trust Bank, Limited
TEL
0120-782-031 (toll free, Japan only)
Business hours
9:00 a.m. to 5:00 p.m. on weekdays
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