The formal Privacy Policy is written in the Japanese language. The following is an English translation summarizing its contents. Please refer to the formal Privacy Policy here (in Japanese only).

*translation*

(Revised in May, 2008)

Policy on Handling Personal Information

Ken Corporation, Ltd.
2-7, Nishi-Azabu 1-chome, Minato-ku, Tokyo

Ken Corporation, Ltd. (the "Company") recognizes the importance of maintaining the confidentiality of personal information and resolves to handle such information with the greatest care, in accordance with the following privacy policy. The contents of the following statement are very important. Carefully read this privacy policy to understand how we handle your personal information.

1) Personal information protection policy

We at Ken Corporation Ltd. seek to make every effort to appropriately handle and protect personal information on our customers, complying with all applicable laws and regulations concerning the protection of personal information and meeting all the ethical obligations accepted as social norms.

2) Purpose of using personal information and personal data which we hold

1. To conclude contracts for real estate purchases/sales, exchanges, leases, lease brokerage services, repossession, management, agencies, appraisals, or consulting services, and to provide information, services, or housing plans
2. To plan, design, supervise, and undertake property construction; to own, use, and manage real estate; to provide consulting on property repairs or renovations
3. To plan, develop, own, sell, and manage real estate investment trusts (condominiums, hotels, commercial properties, and shopping centers managed by joint venture) and to engage in operations involving such business overseas; to provide consulting services on real estate investment at home and abroad; to own and buy/sell real estate trust beneficiary rights, and lease and manage entrusted real property
4. To operate and manage parking lots, warehouses, etc.; to design, execute, supervise, and undertake construction tasks
5. To engage in business activities in accordance with the Real Estate Specific Joint Enterprise Law
6. To provide enterprises with accounting and collection services
7. To engage in hotel management and operations; to operate hotels and Japanese-style inns and restaurants and banquet halls in these facilities; to operate restaurants and retail establishments in hotels and Japanese-style inns
8. To sell trust beneficiary rights or to serve as agent or broker for the sale of trust beneficiary rights
9. To manage and operate assets and provide consulting services concerning asset liquidations in accordance with the Law Concerning Asset Liquidation
10. To provide consulting on investment business and loan business; to provide consulting to find houses for foreigners in Japan
11. To conduct surveys on the economy, industries, and real estate in Japan and other countries; to serve as a damage insurance agent
12. To provide information on investment through publications; to operate movie theaters, theaters, concert halls, live music venues, and other amusement facilities
13. To operate studios for recording audio/images; to plan, create, manufacture, sell, lease, broadcast, show, and distribute audio/image software (including disks, tapes, and films) and to serve as agent or broker for the preceding businesses
14. To import and sell interior decorations, including curtains, carpets, furniture, and paintings
15. To provide personal information to third parties to the extent necessary to achieve the preceding purposes
16. To engage in business operations and marketing activities (including questionnaire surveys) by mail, telephone, and Email in order to provide the preceding goods, information, and services; to mail out complementary items, novelty goods, etc.; to analyze customer trends and survey and analyze product development
17. To contact our customers where appropriate
18. To confirm auditing
    * If requested by the customer, we will refrain from provision of our information/services.

3) Disclosure to third parties

We will not disclose or provide personal information on our customers to any third parties except in the following cases:

1. When we have obtained consent from the customer
2. When we disclose personal information in a manner that does not identify the customer individually
3. When we outsource operations to another company to advance business operations. In such cases, we will select companies that implement adequate measures to protect personal information, and we will provide all necessary and appropriate supervision of such companies.
4. When disclosure is required by laws or regulations
5. When disclosure is necessary to protect the life, safety, or property of an individual and obtaining consent from the customer would be difficult
6. When disclosure is essential to enhance public health or to promote sound child development, and obtaining customer consent would be difficult
7. When disclosure is necessary to cooperate with government institutions or local government organizations or individuals entrusted by these institutions or organizations to perform duties required by laws and regulations, and the undertaking of such duties may be impeded by seeking consent from the customer
8. When we disclose or provide names, addresses, telephone numbers, Email addresses, or customer codes for customers to the extent necessary to achieve the purpose set forth in Article 2 "Purpose of using personal information and personal data which we hold," in writing or by fax, telephone, electronic media (including floppy disk), or Email to individuals who will become contractual counterparties, financial institutions, management companies, and other third parties who require this personal information. If requested by the customer, we will suspend disclosure or provision of personal information.
9. When we disclose or provide names, addresses, telephone numbers, Email addresses, and customer codes of our customers in writing or by fax, telephone, electronic media (including floppy disk), or Email to individuals who will become contractual counterparties, financial institutions, management companies and other third parties who require personal information of the customer in sales of newly constructed homes. If requested by the customer, we will suspend disclosure or provision of personal information.
10. When we disclose or provide real estate information, names, addresses, telephone numbers, Email addresses, and customer codes of customers in writing or by fax, telephone, electronic media (including floppy disk), or Email to individuals who will become contractual counterparties, financial institutions, management companies, or other third parties who require personal information on customers to sell or purchase, broker a lease arrangement, or manage real estate. If requested by the customer, we will suspend disclosure or provision of personal information.
    * Third parties to which we anticipate providing personal information when we sell or purchase, broker a lease arrangement, or manage real estate:
    • Individuals who will become or are expected to become contractual counterparties; owner of the leased object, business agent; transferee of the leased object, prospective transferee; other real estate agents; companies that place advertisements on the Internet; associations of real estate agents; judicial scriveners who handle real estate registration; registered land and building investigators; financial institutions making loans; real estate management companies; credit information institutions; real estate investigation institutions
    • The Designated Real Estate Distribution Organizations when we serve as brokers (We engage in business activities and evaluate residential properties by making use of listings, completed contract reports, and data registered at the Designated Real Estate Distribution Organizations.)
      For information on the Designated Real Estate Distribution Organizations, please refer to Note 1 below.

4) Contact information for inquiries about personal information

If you have any inquiries about the personal information that we hold, please contact:
Personal Information Section, Information Management Div., Business Administration Dept.
Ken Corporation, Ltd.
Telephone: 03-5413-5721
Fax: 03-5413-5744
Email address: joho-hogo@kencorp.co.jp
Inquiries are accepted from 10:00 am to 5:00 pm, Monday through Friday (excluding public and Company holidays).
To request disclosure, correction, or suspension of use of your personal information, please contact us using the contact information given above.
* For the most recent version of the privacy policy, please visit the following website (in Japanese): http://www.kencorp.co.jp/privacy/

Note 1: Regarding matters involving Designated Real Estate Distribution Organizations

The Designated Real Estate Distribution Organizations ("Organizations") is a public interest corporation approved by the Minister of Land, Infrastructure and Transport in accordance with Article 50-2-4 of the Building Lots and Buildings Transaction Business Law (the "Law"). It undertakes the following activities specified under the Law:

1. Registration of building lots or buildings that are the objects of semi-exclusive listings (sennin baikai keiyaku) or other contracts related to real estate business activities
2. Provision of information on building lots or buildings registered in accordance with the preceding paragraph to real estate agents at periodic intervals or at the request of real estate agents
3. In addition to the operations set forth in Paragraphs 1 and 2, preparation of statistics on information described in the preceding paragraph and other operations necessary to ensure proper transactions and the smooth distribution of registered building lots and buildings

We will take the following steps in accordance with provisions concerning the Organizations under the Law:

• When we have concluded a brokerage contract to sell a residential property with the customer, we will register the listing information with the Organizations to find prospective buyers. Registered listing information and other information, including the name, address, and so forth of the seller will be provided to the member companies of the Organizations and to prospective buyers.
• When the contract of the registered residential property has been completed, we will report the contract date, sale price, etc. to the Organizations.
• The Organizations uses the listing information and completed contract information (including an overview of the residential property, contract date, sale price, etc., but excluding the names of the seller and buyer) for the operations of the Organizations specified under the Law. Such operations include the provision of listing information and completed contract information in electronic or other format to member companies of the Organizations and to public institutions.
• In the case of semi-exclusive listings (sennin baikai keiyaku) and exclusive listings (senzoku sennin baikai kaiyaku), the preceding information will be registered or reported to the Organizations in accordance with the provisions of the Law.
• A prospective buyer or an individual who becomes the buyer will purchase the registered residential property according to Step 1 through Step 4 above concerning the Organizations.
• When we engage in business activities to purchase residential property registered with the Organizations, we will provide prospective buyers with listing information, and provide real estate agents assigned to sell the property and the individual wishing to sell the property with the name, address, etc. of prospective buyers. If requested by the customer, we will refrain from provision of our information in accordance with Article 2 ("Purpose of using personal information and personal data which we hold") of this policy on handling personal information.
• We will provide customers with completed contract information (excluding names of sellers and buyers) provided by the Organizations or other completed contract information obtained from the transactions in which we engaged as a basis for the price or appraised value of the residential property presented to the customer. In such cases, we will provide the information in a manner that does not identify the completed contract. If requested by the customer, we will refrain from provision of our information in accordance with Article 2 ("Purpose of using personal information and personal data which we hold") of this policy on handling personal information.