The Company and its Group companies (hereinafter the “Group”) will comply with the Act on the Protection of Personal Information of Japan, as well as related cabinet orders, ministerial ordinances, and guidelines related to the handling of personal information and anonymized information.

The Group will only use personal information for purposes within the scope indicated at the time of obtaining such information, and within the scope necessary for the performance of business operations, and will not use it for any other purpose. Personal information obtained will be used for the following purposes:

• ・ Within the scope of the purposes indicated to the individual at the time of obtaining personal information
• ・ Within the scope necessary for the performance of business operations
• ・ To respond to inquiries from the individual
• ・ To provide information about the Group’s services or to send notifications of events.

Personal information may be shared within the Group only to the extent necessary for the performance of business operations and within the scope of the stated purposes of use.

The Group will not provide personal information to third parties without obtaining the prior consent of the individual, except when required by law.

• (1) The Group will ensure that personal information is accurate and manage it securely.
• (2) The Group will take appropriate information security measures against threats such as unauthorized access and computer viruses in order to prevent the loss, destruction, falsification, or leakage of personal information.
• (3) The Group will ensure that personal information is not leaked through means such as removal from the premises or external transmission.
• (4) When outsourcing the handling of personal information, the Group will conclude contracts etc. that stipulate proper handling and security measures, and supervise contractors appropriately to ensure compliance.

Regarding the collection of personal information from the Company’s website, SSL encryption technology is employed to ensure that personal information is transmitted securely. This website also uses Google Analytics, a service provided by Google, Inc., to analyze site usage for the purpose of improving user experience. In connection with this, analysis may be conducted through “cookies,” which are text files generated on the user’s computer. As part of this process, certain user information such as IP addresses may be collected by Google, Inc. This information is used solely for the purpose of analyzing site usage, creating reports for the site operator, and providing other services. By using this site, users are deemed to have consented to the processing of such data by Google in the manner and for the purposes outlined above.

• NOTE: Cookies may be disabled via your browser settings. However, please understand that some functions of this site may not be available if cookies are disabled. Information collected via Google Analytics is managed in accordance with Google’s Privacy Policy. Please refer to Google’s Privacy Policy for details. The Company shall not be liable for any damages arising from the use of Google Analytics services. In addition, the Company’s website may contain links to external websites. The Company is not responsible for the handling of personal information on such external websites.

• (1) The Group will appoint a Personal Information Protection Officer and Personal Information Protection Managers to ensure the proper management of personal information.
• (2) The Group will provide education and training about protection and proper management of personal information to officers and employees who handle personal information to ensure proper treatment of personal information during daily operations.

To implement these policies, the Group will establish internal regulations governing personal information protection and information security management. We will ensure thorough awareness and compliance among our officers, employees, and other relevant parties, as well as maintain and update these regulations to continuously improve them.

The Group recognizes that individuals have the right to request disclosure, amendment, cessation of use, or deletion of their personal information, and will respond promptly and appropriately to such requests.

The Company and its Group companies (hereinafter, the “Group”) will comply with all relevant laws, guidelines, and other standards relating to Specific Personal Information, etc .

The Group will use the Specific Personal Information, etc. it receives for the following purposes:

(1) Specific Personal Information, etc. of Business Partners

• ・ Preparation of payment records related to real estate transactions
• ・ Preparation of payment records related to remuneration, fees, contract payments, and monetary awards

(2) Specific Personal Information, etc. of Shareholders

• ・ Preparation of payment records related to distribution of dividends and surplus

(3) Specific Personal Information, etc. of Group Employees, etc.

Tax-related procedures

• ・ Preparation of withholding tax certificates
• ・ Administrative procedures related to the submission of declarations, notifications, and applications concerning employee housing savings funds and asset formation pension programs
• ・ Administrative procedures related to applications and notifications related to the small enterprise retirement allowance mutual aid system

Social insurance-related procedures

• ・ Administrative procedures related to notifications, applications, and claims for national health insurance and employees’ pension insurance
• ・ Administrative procedures related to notifications, applications, claims, and preparation of certificates for employment insurance and workers’ accident compensation insurance

(4) Specific Personal Information, etc. of Spouses and Relatives of Group Employees, etc.

Tax-related procedures

• ・ Preparation of withholding tax certificates

Social insurance-related procedures

• ・ Administrative procedures relating to notification concerning national health insurance and employees’ pension insurance

The Group will establish and ensure compliance with organizational structures and internal regulations governing the proper management of Individual Numbers and for preventing the leakage, loss, or damage of Specific Personal Information, etc., and will implement both physical and technological security control measures to prevent such incidents.

The Group may entrust the handling of Specific Personal Information, etc. to third parties. In such cases, the Group will exercise necessary and appropriate supervision over such third parties in accordance with applicable laws and regulations related to Specific Personal Information, etc.

When a request for disclosure of retained personal data relating to Specific Personal Information, etc. is made by the individual concerned or their representative, the Group will respond without delay, except in the following cases:

• ・ Where there is a risk of harm to the life, physical safety, assets, or other rights and interests of the individual concerned or a third party
• ・ Where there is a risk of significant disruption to the proper conduct of the Group’s business
• ・ Where disclosure would violate laws or regulations