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Privacy Policy (Safeguarding the Confidentiality of Personal Information)

Established April 2005
Revised September 2018

The following is our privacy policy. Please read it carefully and make sure you agree with the terms and conditions.
This privacy policy is effective as of April 1, 2005.

1. Name of business operator handling personal information

Ken Corporation Ltd.

2. Policy on protection of personal information

We respect and comply with laws and regulations and social norms concerning the protection of personal information and are committed to properly handling and protecting personal information.
This privacy policy describes how we handle your personal information.

3. Purposes of use of personal information and Retained personal data

1. We announce in this privacy policy or inform you in writing of the purposes of use of personal information and will not use personal information and for any other purpose unless otherwise specified by laws and regulations.
2. We use personal information provided by you and personal data retained by us for the following purposes. We will, however, cease the provision of any of the services described below at your request.
   1. Sale, purchase, exchange and leasing of real properties and brokerage therefor; performance of contracts and provision of information, services and housing plans concerning real property ownership, management, brokerage, appraisal, consulting and other transactions
   2. Building planning, design, supervision and construction
   3. Ownership, use and management of real properties
   4. Consulting services related to house repair and renovation
   5. Planning, development, ownership, selling and management of small-lot real estate products for investment purposes (e.g., condominiums, hotels, office buildings and shopping centers under joint ventures), and overseas operations relating thereto
   6. Sale of beneficial interests in trusts, or agency or intermediary services therefor
   7. Investment advisory services related to real properties, etc. in Japan and overseas
   8. Holding, sale or purchase of beneficial interests in real estate trusts, and leasing and management of the properties placed in the trusts
   9. Operation and management of parking and storage facilities
   10. Business under the Act on Specified Joint Real Estate Ventures
   11. Design, execution, supervision and contracting of construction work
   12. Money collection services and corporate accounting services
   13. Hotel management and business related to hotel operations
   14. Management of hotels, inns and restaurants, and banquet facilities attached thereto
   15. Management of restaurants and shops in hotels and inns
   16. Travel agency business under the Travel Agency Act
   17. Consulting services related to asset management and operations, and asset securitization under the Act on the Securitization of Assets
   18. Consulting services related to investment business and loan business
   19. Consulting services for foreign nationals concerning residing in Japan
   20. Researches on economic, industrial and real estate conditions in Japan and overseas
   21. Non-life insurance agency services
   22. Provision of investment information through publications
   23. Management of movie theaters, theaters, concert halls, live music venues and other entertainment facilities
   24. Operation of sound and video recording studios, and contracting of recording work
   25. Planning, production, manufacture, sale, leasing, broadcasting, on-screen presentation, and distribution of sound and video software (discs, tapes and films), and brokerage and intermediary services therefor
   26. Import and sales of furniture, paintings, curtains, carpets, and other interior decorations
   27. Provision of personal information to third parties to the extent necessary to achieve the purposes of use set forth above
   28. Business and marketing (e.g., questionnaire surveys) activities by post, telephone, email or otherwise, and sending of free gifts, novelty goods and other articles, for purposes related to providing the products, information and services set forth above; customer trend analysis, and research and analysis for product development and related purposes
   29. Contacting you when necessary
   30. Reviews for accounting audit purposes
3. We will not use your personal information in any manner that may encourage or induce an illegal or unjust act.
4. We will obtain your personZal information in a lawful and proper manner.
5. Unless otherwise specifically provided by laws and regulations, we will not obtain your special care-required personal information.

4. Security of personal information

1. We make every effort to control and manage your personal information safely and take all reasonable and appropriate security measures to protect your personal information against risks, including unauthorized access by external parties, loss, damage, destruction, alteration, leakage, unauthorized release to external parties. We have appointed a person responsible for information management at each department that handles personal information in order to ensure appropriate management of personal information. We have also established information security rules and made them known to all employees.
2. We strive to keep personal data accurate and up to date within the scope necessary to achieve the purposes of use and to delete the personal data without delay when the use thereof is no longer necessary.
3. In the event of occurrence of any leakage, loss, damage, etc. of personal information or personal data handled by us, we will report it in accordance with laws and regulations.
4. In the case of the preceding paragraph, we will notify the occurrence of the leakage, etc. to the person(s) whose personal information or personal data is affected in accordance with laws and regulations.

5. Provision to third parties

1. We will not disclose or provide your personal information to third parties except in the following cases:
   1. Your consent has been obtained.
   2. Your personal information is disclosed in a form in which you cannot be identified personally.
   3. The handling of your personal information is entrusted to another company for smooth operation of our business or other purposes. In such case, we select a company who has taken sufficient measures to protect personal information, and we supervise the entrusted company as necessary and appropriate.
   4. The disclosure of your personal information is legally required.
   5. The disclosure or provision of your personal information is necessary to protect a human life, body or property and it is difficult to obtain your consent.
   6. The disclosure or provision of your personal information is especially necessary to enhance public hygiene or promote fostering healthy children and it is difficult to obtain your consent.
   7. The disclosure or provision of your personal information is necessary to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations and there is a possibility that obtaining your consent would interfere with the performance of the said affairs.
   8. Within the scope of the purposes of use specified in Section 3 (Purposes of use of personal information and retained personal data), your name, address, telephone number, email address, and/or customer code are disclosed or provided in writing, by facsimile or telephone, in the form of electromagnetic data (e.g., floppy disk), or by email to a counterparty to your contract, financial institutions, management service companies, or other third parties to the extent necessary to achieve the purposes of use. Such disclosure or provision shall be ceased at your request.
   9. In the case of a sale of a newly built property for sale, your name, address, telephone number, email address, and/or customer code are disclosed or provided in writing, by facsimile or telephone, in the form of electromagnetic data (e.g., floppy disk), or by email to a counterparty to your contract, financial institutions, management service companies, or other third parties to the extent necessary to achieve the purposes of use. Such disclosure or provision shall be ceased at your request.
   10.  In the case of a sale, purchase, leasing brokerage, or management of a real property, the real property information and your name, address, telephone number, email address, and/or customer code are disclosed or provided in writing, by facsimile or telephone, in the form of electromagnetic data (e.g., floppy disk), or by email to a counterparty to your contract, financial institutions, management service companies, or other third parties to the extent necessary to achieve the purposes of use. Such disclosure or provision shall be ceased at your request. * Examples of third parties to whom your personal information may be provided in the case of a sale, purchase, leasing brokerage, or management of a real property:
       • The actual or prospective counterparty to your contract
       • The owner of the property leased to or occupied by you and the owner’s agent
       • Person acquiring or expected to acquire the property leased to or occupied by you
       • Other real estate brokers
       • Online advertising service providers, real estate trade associations
       • The Real Estate Information Network System (for such purposes as registering a property, notifying conclusion of a contract, and marketing and conducting evaluation of a price using data available in the system) in the case of brokerage services for sales and purchases — see note below.
       • Judicial scriveners, land and house investigators involved in registration and other related services
       • Financial institutions involved in loans
       • Management service companies involved in real estate management and other services
       • Credit information organizations, real estate research organizations

   (Note) Matters concerning the Real Estate Information Network System

   The Real Estate Information Network System is a public interest corporation designated by the Minister of Land, Infrastructure, Transport and Tourism pursuant to Article 50-3 of the Real Estate Brokerage Act and performs the following operations as specified in the Act:

   1. Operations relating to the registration of building lots or buildings pertaining to exclusive brokerage service agreements and other service agreements concerning real estate brokerage
   2. Provision of information concerning building lots or buildings pertaining to registration referred to in the preceding item to real estate brokers on a regular basis or in response to requests
   3. In addition to the operations listed in the preceding two items, preparation of statistics relating to the information referred to in the preceding item and other operations required to facilitate the proper securing of transactions and logistic involving building lots and buildings

   We will take the following measures pursuant to the provisions of the Real Estate Brokerage Act regarding the Real Estate Information Network System:

   1. When we have concluded a brokerage service agreement at the request of a person who wishes to sell his or her property, we will register the property information with the Real Estate Information Network System in order to facilitate searches for prospective buyers. The registered property information and the name, address and other information of the person who wishes to sell the property will be provided to member companies of the Real Estate Information Network System and persons who wish to buy the property.
   2. If a sales contract is concluded for the registered property, the date of conclusion, the purchase and sale price, and other information of the contract will be provided to the Real Estate Information Network System.
   3. The Real Estate Information Network System uses property and contract information (such as property summary, contract date, purchase and sale price, and other information, excluding the names of the seller and the buyer) for its operations as specified in the Real Estate Brokerage Act. This includes providing property and contract information to member companies of the Real Estate Information Network System and public organizations in electronic or other form.
   4. For exclusive brokerage service agreements and privileged and exclusive brokerage service agreements, the registration and notification of the information with and to the Real Estate Information Network System set forth above will be made in accordance with the provisions of the Real Estate Brokerage Act.
   5. A person who wishes to buy or who will buy the property will be required to make the purchase in accordance with the measures related to the Real Estate Information Network System set forth in (i) through (iv) above.
   6. When we search for potential property buyers on the basis of property information available in the Real Estate Information Network System, we will provide the property information to persons who wish to buy the property and provide information on the names, addresses, etc. of the persons who wish to buy the property to the real estate broker conducting sales activities for the property and to the person who wishes to sell the property. This provision shall be ceased at your request as specified in Section 3 (Purposes of use of personal information and retained personal data).
   7.  We will provide our customers etc. with contract information provided from the Real Estate Information Network System (excluding the names of the seller and buyer) or contract information obtained through sales transactions in which we were involved as the basis of opinions presenting the suggested sales price or appraised value when we are requested to provide our sales services. In so doing, we will ensure the property is not readily identifiable from the information. This provision shall be ceased at your request as specified in Section 3 (Purposes of use of personal information and retained personal data).
2. Please note that we may encrypt personal information obtained from you by means such as hashing so that it will be impossible to identify a specific individual and upload the encrypted information to advertising media or social networking service platforms, etc., to display our advertisements when the information matches you.

6. Handling of specific personal information

Unless otherwise required by laws and regulations, we will not obtain your Individual Number (so-called My Number) specified in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures. Should you provide a document containing your Individual Number (My Number), we advise you to mask or otherwise make the number illegible, unless otherwise required by laws and regulations.

7. Procedures concerning disclosure, correction, suspension of use of personal information and handling of complaints

1. We will respond to your request for disclosure of retained personal data, correction of any incorrect information contained in retained personal data, suspension of use or deletion of retained personal data in cases of violation of laws and regulations, etc., without delay in accordance with procedures separately established by us.
   *For detailed information on these procedures, please see Procedures for personal information disclosure.(Japanese only)

2. Our response to your requests set forth in the preceding paragraph will be provided by the Business Administration Department.
   The service desk is open from 10:00 a.m. to 5:00 p.m. from Monday through Friday (except on national and company holidays).

   1-3-10, Nishi-azabu, Minato-ku, Tokyo, 106-0031
   Business Administration Department, Ken Corporation Ltd.

   Telephone

   03-5413-5721

   Facsimile

   03-5413-5744

   Email address

   joho-hogo@kencorp.co.jp

3. If you wish to request disclosure, etc. of your personal data retained by us, please visit the “Procedures for personal information disclosure” page of our website or contact the service desk specified in the preceding paragraph. We will send you a prescribed form by facsimile or email. You will need to complete and submit the form along with your identification papers and other necessary documents. Please note that a prescribed fee will be charged for this disclosure procedure.
4. To ensure the safe management of retained personal data, we take reasonable and appropriate security measures to protect against risks, including unauthorized access by external parties, loss, damage, destruction, alteration, leakage, and unauthorized release to external parties.
5. The service desk specified in paragraph (2) will also respond to opinions, complaints, inquiries, and the like concerning our handling of personal information during the hours specified above.

8. Revision of this privacy policy

This privacy policy will be reviewed and revised from time to time to meet legal demands and further improve the way we protect personal information. The latest information will be made available at our website.

9. Cookies

Our website may use cookies to collect your browsing history information and provide greater convenience to you during your interaction with our website. This technology is used only for the purpose of the smooth operation of the services provided by our website, and information collected through cookies will be treated as confidential in the same manner as your personal information. We may link your behavior history information obtained through cookies with your personal information in our possession and deliver advertisements such as e-mail newsletter and banner advertisements. When you make an inquiry by filling out an inquiry form on our website, we will use the information provided by you to inform you about our services that we think may be of interest to you. Cookies enable our website to identify your computer. If you reject cookies, you will still be able to use our website but may not be able to use some features of our website.
You can reject cookies by changing your browser settings.

10. Links to other websites

Our website contains links to websites of other companies. Please note that we have no responsibility for privacy protection at the linked websites, including their use of cookies.

*For the latest version of our privacy policy, please see https://www.kencorp.co.jp/privacy/index.html(Japanese only)

Acquisition and usage of attribute information and behavior history that do not specify individuals

This website uses programs provided by advertisement distributors and other third parties to conduct behavior-targeting advertising (advertising method in which advertisements are delivered according to the interests of the user based on the user’s website browsing data, etc.) on specified sites, site management, and measurement of access status.
When doing so, this website uses cookies to gather information on the website visit history of users.
Advertisement distributors and other third parties use these cookies to conduct advertisement distribution based on data on past access to this website, website management, and measurement of access status.
Users who wish to have these advertisements and/or measurements disabled may access the opt-out page of the advertisement distributors and other third parties to disable the use of cookies.
If you change your browser, delete cookies, or change to a new device, you will need to opt out again.
Users may use Google’s advertising opt-out page to disable the use of Google cookies (Users may also use the opt-out page on Network Advertising Initiative to disable third-party distributor cookies.).

Without opting out, there is a possibility that Google cookies as well as third-party distributor or advertising network cookies may be used.
The opt-out website of Network Advertising Initiative may be used to collectively disable some (but not all) cookies.

Opt-out pages may be found at the below URLs:

• Google opt-out page: https://policies.google.com/technologies/ads?hl=en (Will open up in a separate window)
• Network Advertising Initiative opt-out page: http://www.networkadvertising.org/choices/#completed (Will open up in a separate window)