Kenedix Property Design, Inc. (hereafter, “the Company”) and each entity of our corporate group (hereafter, “the Company's Group”) believes the secure protection of customers' privacy and personal information (customers' Individual Number and personal information that contains the Individual Number (collectively, “Specific Personal Information”)) is both a fundamental element of its business activities and an important social responsibility. The Company's Group has consequently established the Privacy Policy, set out below, to enable it to consistently fulfill this responsibility.

1. Basic Policies

The Company's Group shall recognize the importance of personal information, use through strict compliance with applicable laws, regulations and guidelines set by the Japanese government, ensure its appropriate handling as well as strive for its safe and secure management. Furthermore, we shall endeavor to improve our structure for protecting personal information on a continuous basis through timely reviews of the related framework.

2. Acquisition, Use and Provision of Personal Information

The Company's Group will acquire personal information by appropriate means and make a disclosure, notification or statement of the purposes of use. The Company's Group will not use any personal information for any purpose other than the purposes of use without the consent of the information owner. The Company's Group will follow the statutory procedures to provide or disclose personal information to third parties. The Company's Group will not provide Specific Personal Information to any third party except in cases clearly permitted under the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure.

3. Purpose of Use of Personal Information

3-1 Personal information that the Company acquires, such as name, home address, date of birth, business address, annual income, phone numbers, e-mail address and individual identification code including official certificate number, etc.; his or her Individual Number is not included, will be used for the following purposes:

⑴ Provision of information, making of proposals, conclusion and performance of agreements, provision of follow-up maintenance, marketing (requests for questionnaire surveys, and others) and provision of various information and services concerning the following businesses (including commissioned business) of the Company's group entities.

  1. Sale, purchase, operation, brokerage, leasing, development, management, administration, planning, appraisal, advisory services and so forth of real estate and other property (including trust beneficiary rights; the same shall apply hereinafter).
  2. Hotel business and Ryokan business under the Inns and Hotels Act.
  3. Travel agency business under the Travel Agency Act.
  4. Private rental lodging business under the Private Residence Lodging Business Act.
  5. Provision of activities, researches, and services accompanying the businesses described in (i) to (iv) above.

(2) Provision of responses to inquiries from customers.

(3) Provision of reference materials at the requests of a customer.

(4) Sales promotion activities such as distribution of free e-mail (e-mail newsletters) and mailing and distribution of direct mail.

(5) Management for the shareholders of the Company's Group.

(6) Management for the business partner of the Company's Group.

(7) Management for the officers, employees, contracted staff of the Company's Group.

(8) Invitation and selection of officers and employees to be appointed or hired by the Company's Group.

(9) Communication by documents, postal matter, telephone, facsimile, electronic mail and so on within the scope necessary to achieve the purposes described above.

(10) Provision of personal information to third parties within the scope necessary to achieve the purposes described in 1 to 9 above.

3-2 Specific Personal Information (including Individual Number) that the Company collects will be used for the following purposes:

(1) Affairs related to the Individual Number (including relevant tasks listed below) for employees and officers (including dependents) of the Company

  1. Tasks related to withholding tax, preparation of salary payment report, and preparation of salaried employees' transfer notification forms in relation to salary payment special tax collection, etc.
  2. Preparation of application for (change in) dependent deduction, application for deduction of insurance premium & salaried employees' special exemption for spouse, and preparation of application for change to special tax collection, etc.
  3. Preparation of payment report for a person receiving retirement allowance, etc. and preparation of application relating to retirement income, etc.
  4. Notification related to health insurance, employee pension and corporate pension, application and claim for health insurance, employee pension and corporate pension, and notification of category III of national pension, etc.
  5. Notification, application and claim for employment insurance, etc.

(2) Affairs related to Individual Number for individuals who are not employees and officers of the Company (including relevant tasks listed below):

  1. Preparation of payment report on remuneration/fee, etc.
  2. Preparation of distribution report on dividend and surplus, and payment report on interest from funds, etc.
  3. Preparation of payment report on real estate usage fees, etc.
  4. Preparation of payment report on remuneration for acquisition of real estate, etc.

4. Providing Personal Information to Third Parties

Apart from the case of providing personal information permitted by statutory provisions, necessary items such as real estate information, name and address of an information owner or his or her family from among personal information (excluding Individual Number and Special care-required personal information) collected by the Company may be provided to third parties (excluding parties receiving personal information by outsourcing, business succession or joint use.) to the extent necessary to attain the purpose of use, as well as by means of written documents, postal matter, telephone, facsimile, electronic mail, advertising media and similar.
This provision of information will be discontinued at the request of the information owner (Please address the request to the contact described in Article 9). However, this shall not apply to any personal information that the Company has collected with the individual consent of the information owner to the provision of that personal information to third parties.
[Examples of third parties to which personal information may be provided] *Listed below are some examples. Note, however, that third parties shall not be limited to those listed below.

(1) Parties with which the Company has entered into or may enter into contracts or transactions.

(2) Other Second Financial Instruments Business agencies or real estate agencies.

(3) Operators and organizations engaged in online or other advertising.

(4) Designated distribution organizations (registration of properties, notification of contract conclusion, business activities using data owned by the organizations, price appraisal, etc.)

(5) Judicial scriveners and land and house investigators involved in property registration.

(6) Financial institutions, Financial instruments firms, money-lenders involved in financing.

(7) Management operators, financial institutions administering the bank accounts to which payments are transferred, officials of the management association, etc. in connection with real estate management.

(8) Attorneys (including registered foreign lawyer), certified public accountants, licensed tax accountants, real estate appraisers and public consultant on social and labor insurance and so on offering expert advice and services.

(9) Credit information organizations, real estate research institutions, etc.

(10) Government, local public agency, or a private sector to whom the government or local public agency entrusted their work.

(11) Business partners of member companies in the Company's Group

5. Joint Use of Personal Information

In the event of inviting applications for employment, appointment as officers in the Company's Group, etc., personal information (excluding Individual Number) obtained by the Company will be jointly used.

(1) Items of personal information subject to joint use: Personal information concerning a person and his or her family, such as name and address, obtained at the time of inviting applications for employment, appointment as officers in the Company's Group, etc.

(2) Eligible joint users: Parent Company, subsidiaries and affiliated companies in The Company's Group

(3) Purpose of use: Selection of officers and employees to be appointment or hired by the Company's Group

(4) Responsible administrator: Kenedix, Inc.

6. Action for Safety Control of Personal Information

The Company's Group will take the necessary and appropriate actions to ensure the proper and careful control of personal information owned by the Company's Group and to protect personal information from unauthorized access, loss, falsification, leakage and suchlike.

7. Outsourced Handling of Personal Information

The Company's Group may contract with an external service provider to handle personal information owned by the Company's Group. In this event, the Company's Group will choose a service provider that takes appropriate measures to protect personal information and will exercise the necessary and appropriate supervision.

8. Procedures for Disclosure, Correction, etc. of Personal Information

The Company will immediately respond to any request received from any information owner for the disclosure, correction, discontinuation of use or similar of that information owner's personal information owned by the Company's Group. The response will follow procedures defined separately.

9. Inquiries about Personal Information

Please address any inquiries, comments and requests concerning the Company's handling of personal information to the following:

Contact for inquiries : Business administration department, Kenedix Property Design, Inc.

Address : 5-1-9 Shinbashi, Minato-ku, Tokyo 105-0004 Japan

Phone : +81-3-6633-8110
(10:00 to 17:00 Japan Standard Time (closed on weekends, national holidays and Dec. 29 to Jan. 4))

10. Revisions of This Policy

The Company will, from time to time, review and revise this policy in order to comply with related laws and regulations and improve the processes of protecting personal information.