Space Design Inc. (hereinafter, referred to as "the Company") believes that the secure protection and the appropriate management of personal information are fundamental elements of its business activities and important social responsibilities. Therefore, the Company has consequently established its Privacy Policy (hereinafter referred to as "the Policy"), set out below, to enable such protection of personal information to consistently fulfill these responsibilities.

1. Basic Policies

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

2. Acquisition, Use, and Provision of Personal Information

The Company shall acquire personal information by appropriate means, shall make an official announcement of, give notice of, specify, and so forth the purposes of use of personal information, and shall not handle any personal information beyond the scope of the purposes of use thereof. Furthermore, the Company shall, when necessary, provide, and so forth personal data (which means the personal data provided for in the Act on the Protection of Personal Information; the same shall apply hereinafter) to any third party in accordance with the statutory procedures.

3. Purposes of Use of Personal Information

The Company shall use the personal information that the Company acquires, such as name, home address, date of birth, business address, phone number, and e-mail address, 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 services concerning the following businesses (including commissioned business) of the Company and the Company's group entities.
(i) Sale, purchase, operation, brokerage, leasing, development, management, administration, planning, appraisal, and so forth of real estate and other property (including trust beneficiary rights; the same shall apply hereinafter).
(ii) Hotel business and Ryokan business under the Inns and Hotels Act.
(iii) Travel agency business under the Travel Agency Act.
(iv) Private rental lodging business under the Private Residence Lodging Business Act.
(v) Provision of activities, researches, and services accompanying the businesses described in (i) to (iv) above.
⑵ Provision of responses to inquiries from customers.
⑶ Provision of reference materials at the requests of a customer.
⑷ Sales promotion activities such as distribution of free e-mail (e-mail newsletters) and mailing and distribution of direct mail.
⑸ Management of the Company’s business partners.
⑹ Management of the Company’s officers, employees and contract employees.
⑺ Invitation and selection of, and communication with the applicants for recruitments of the Company and the Company's group entities.
⑻ Communication to achieve the above purposes by written documents, postal matter, telephone, facsimile, e-mail, and so forth.
⑼ Provision of personal information to third parties within the scope necessary to achieve the purposes described in ⑴ to ⑻ above.

4. Provision of Personal Data to Third Parties

Apart from the case of providing personal data pursuant to the statutory provisions, personal data such as name, home address, business address, and so forth of a person who has provided us with his/her personal information (hereinafter, referred to as "personal information origin") may be provided by the Company to third parties (which means any person and company other than those who are involved in outsourcing, succession of business or joint use), to the extent necessary to achieve the purposes of use as well as by means of written documents, postal matter, telephone, facsimile, e-mail, and so forth. For the sake of clarity, the provision of personal information shall be discontinued at the request of the personal information origin. However, this shall not apply to any personal information that the Company has collected with the individual consent of the personal information origin to the provision of that personal information to third parties.

 

[Examples of Third Party to Which Personal Information May Be Provided]

*Those listed below are no more than examples. Note that the third parties shall not be limited to those listed below.

⑴ Persons and companies who become, or are likely to become, the other party to contracts or transactions.
⑵ Managerial business entities and so forth that are engaged in real estate managerial duties and so forth.
⑶ Attorneys (including lawyers for foreign laws), certified public accountants, tax accountants, real estate appraisers, and certified social insurance labor consultants, and so forth offering professional advice and services.
⑷ Credit information organizations, real estate research institutions, and so forth.
⑸ The national government, the local public agency, or a private sector entity to whom the national government or the local public agency has entrusted its duties.
⑹ The owners of real estate items and so forth.
⑺ Business partners including, without limitation, the Company’s group entities.


5. Joint Use of Personal Data

The Company may make joint use of the personal data of the personal information origin, including, without limitation, the names, home addresses, dates of birth, business addresses, phone numbers, and e-mail addresses obtained for the recruitment of employees and other personnel, with the Company’s group entities (which refers to Kenedix, Inc. and its subsidiaries and affiliates) to the extent necessary for the employment and selection for the recruitment of the officers, employees and other personnel of the Company’s group entities. In this case, Kenedix, Inc. shall serve as the management supervisor of such personal data.

6. Safety Control Measures for Personal Data

The Company shall take the necessary and appropriate measures to ensure the proper and careful control of personal data retained by the Company and to protect personal data from any unauthorized access to, or loss, falsification, leakage or disclosure, and so forth.

7. Outsourced Handling of Personal Data

The Company may contract with an external entity to handle the personal data retained by the Company. In this event, the Company shall select an entity that takes appropriate and sufficient actions to protect personal information and shall exercise the necessary and appropriate supervision on the entity.

8. Procedures for Disclosure and Correction of Personal Data Retained

The Company shall immediately take necessary action with respect to any request or claim (hereinafter collectively referred to as the “Request for Disclosure”) received from any personal information origin for any notice, disclosure and correction of the purpose of use, and discontinuation of use, and so forth of personal data (which means the personal data retained provided for in the Act on the Protection of Personal Information; the same shall apply hereinafter) retained by the Company. The actions shall follow procedures separately defined by the Company.

9. Inquiries about Personal Information

Please address the Request for Disclosure of personal data retained by the Company, and any comments and inquiries concerning the Policy and the Company's handling of personal information, to the following.

Legal Examination Division
(Desk for Personal Information Disclosure, Grievance, and Inquiry)
Space Design Inc.
Inquiry
Tel: 03-3502-7000/E-mail: p-policy@space-d.co.jp
4th Floor, KDX Shinbashi Building, 2-2-9 Shinbashi,
Minato-ku, Tokyo, 105-0004
Available from 10:00 am to 5:00 pm
(except Saturdays, Sundays, national holidays, and the year-end and New Year holidays)

10. Revision of Policy

The Policy shall be timely reviewed and revised, in accordance with statutory requests and for further improvement in the protection of personal information.