Personal Information Protection Policy

Policy

The Company recognizes the importance of personal information, complies with the Act on the Protection of Personal Information, other related laws, standards, internal rules, etc., refrains from using personal information outside of the designated purposes, responds in good faith and appropriately to any related complaint, etc., received by the Company, strives to handle personal information appropriately, and strives to ensure safe and reliable management/operation of personal information. The Company also continuously reviews and strives to improve this policy from the perspective of security control of personal information.

Usage Purposes for Personal Information

The usage purposes for personal information collected by the Company are listed below.

• Analyze customer trends and survey/analyze product development, etc., in relation to the Company’s business(*1)
• Confirm stakeholders and provide information(*2) on business progress in relation to the Company’s business(*1)
• Conduct sales activities(*2) in relation to the Company’s business(*1)
• Confirm personal identity and check credit during applications, contracts, etc., in relation to the Company’s business(*1)
• Provide information(*2) on the processing of applications, contracts, etc., in relation to the Company’s business(*1)
• Provide information(*2) on questionnaires dealing with customer satisfaction, etc., in relation to the Company’s business(*1)
• Conduct PR activities by the Company (provide company information(*2) and information on events, questionnaires, etc.(*2))
• Recruit shareholders of the Company and provide information(*2) to shareholders as the issuing company
• Confirm the identity of visitors to the Company and record the details of services provided to visitors
• Conduct personnel and labor management and hiring activities (provide information on screening and hiring (*2)) for employees (executives, employees, temporary workers, employees of other companies stationed at the Company, etc.) engaged in the Company’s business activities
• Disclose/provide personal information to a third party within the scope required to conduct the Company’s business (*1) if permission is obtained from the information source (person who provided the information)
• When accepting an outsourced business within the scope of the Company’s business (*1), usage purposes predefined by the outsourcer of that business

Moreover, at the time of collecting personal information, if a usage purpose that differs from the usage purposes defined above is notified or clearly indicated to the information source (person who provided the information), then that usage purpose is given priority over the usage purposes defined above.
When collecting personal information, which is described or recorded in writing (including electromagnetic records; the same applies hereinafter), directly from the information source (the person who provided the information), the Company will clearly indicate in advance the usage purposes to such information source. In other cases where personal information is collected for a usage purpose that differs from the usage purposes defined above, the Company will promptly notify the person who provided the information of such usage purpose in writing, or otherwise announce it on the Company’s website or through other appropriate media.

Disclosure/Provision of Personal Information to a Third Party

In the cases listed below, the Company may provide a third party with personal information collected by the Company. The types of personal information provided include addresses, names, real estate information, services provided, etc., and the information is provided by hand delivery, postal mail, telephone, internet, e-mail, advertising media, etc. The Company will stop the disclosure/provision of personal information upon receiving a request from the information source (person who provided the information). However, except where the Company is required by the Act on the Protection of Personal Information, the Order for Enforcement of the Act on the Protection of Personal Information or any other relevant law or regulation to stop such disclosure/provision of personal information, depending on the circumstances of each case, it may not be possible for us to respond to such request.

• When permission has been obtained from the individual providing the information
• When required by law
• When required to protect the life, health, assets of a person, and when it is difficult to obtain permission for disclosure/provision of personal information from the person who provided the information
• When especially necessary to improve public health or to promote the healthy growth of children, and when it is difficult to obtain permission from the person who provided the information
• When it is necessary to cooperate with the execution of legally stipulated duties by a national government agency, a local government group, or a person designated as an agent by the government, and when obtaining permission for the disclosure/provision of personal information from the person who provided the information creates the risk of interfering with the execution of said duties
• When such third party is a university or other institution for academic research and needs to handle such personal information for academic research purposes
• When outsourcing all or part of the handling of such personal information is within the scope required to conduct the Company’s business (*1) or to achieve the usage purposes
• The cases specified in the “Shared Usage of Personal Information” below

Examples of third parties to which personal information is disclosed/provided

• A national government agency, local government group, or a person designated as an agent by the government
• When outsourcing business within the scope required to achieve the usage purpose, the subcontractor charged with said business
• When accepting outsourced business within the scope of the Company’s business(*1), the outsourcer of that business
• Partners and prospective partners of agreements occurring in conjunction with the execution of the Company’s business(*1)
• When conducting advertising, etc., via newspaper, magazine, internet, etc., in conjunction with the execution of the Company’s business(*1), the publishing vendor and group for said advertising, etc.
• Judicial scriveners, etc., related to registration, etc., occurring in conjunction with the execution of the Company’s business(*1)
• Financial institutions, etc., related to financing, etc., occurring in conjunction with the execution of the Company’s business(*1)
• Real estate brokers who handle real estate mediation, etc. and the Real Estate Information Network System (organizations that have been designated by the Minister of Land, Infrastructure, Transport and Tourism per the Building Lots and Buildings Transaction Business Act)

※When requested to handle mediation, etc., of real estate, there are cases in which the requested real estate information, etc., is provided to the real estate broker or Real Estate Information Network System in order to search for a party to the contract. Furthermore, there are cases in which real estate information, etc., collected from other real estate brokers or the Real Estate Information Network System is provided to parties who wish to engage in real estate transactions or to other real estate brokers.

Shared Usage of Personal Information

When necessary, the Company may engage in shared usage of personal information collected from an information source as listed below.

• Types of information for shared usage: Company name, affiliation, position, name, address, telephone number, e-mail address
• Scope of shared users: The Company and affiliated companies listed in the Company’s annual security report
• Usage purpose of shared users: To achieve the purposes described in “Usage Purposes for Personal Information” above
• Party responsible for management of personal information: JINUSHI Co., Ltd. (its address and the name of its representative are available here)

Security Control of Personal Information

For purposes of preventing leakage, loss or damage of personal information or other security control thereof, the Company will take the necessary and appropriate measures by assigning managers and having the relevant rules in place as part of the security measures for personal information, and introducing mechanisms to prevent unauthorized access to the information system. In particular, in cases where personal information is handled outside of Japan, such as where personal information is used by and shared with our affiliates overseas and where the Company outsources the handling of personal information to subcontractors overseas, the Company will first understand the personal information protection systems of the relevant local government(s), and take the necessary and appropriate measures for the security control of personal information.

Inquiries on Personal Information

Point of Contact for Inquiries About Personal Information (Tel: 03-6895-0070) of JINUSHI Co., Ltd. accepts inquiries on the general handling of personal information, questions regarding the personal information provided, and requests for disclosure, correction, and stoppage of use, as well as complaints relating to the handling of personal information, etc. However, except where the Company is required by the Act on the Protection of Personal Information or any other relevant law or regulation to respond, depending on the details of the inquiry, there may be cases where response is not possible.

※1) The Company’s business activities consist of 1) sale, purchase, exchange, and rental of real estate, as well as agency and mediation for said activities, 2) sale and purchase of real estate trust beneficiary rights, 3) ownership, management, operation, and disposal of real estate, real estate trust beneficiary rights, etc., and 4) consulting on real estate, real estate trust beneficiary rights, etc.

※2) Information on sales activities, announcements, etc., is provided by making direct visits, by sending postcards or direct mail, by making telephone calls, by sending e-mails, etc.

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