Privacy Policy of Mitsui Fudosan Realty Group of Companies

Important notice：This English translation is prepared solely for your reference purposes.

The Mitsui Fudosan Realty Group has established policies and a system for the protection of personal information as follows and hereby declares them as the Personal Information Protection Policy of the Mitsui Fudosan Realty Group.

Handling of Personal Information

Mitsui Fudosan Realty Co., Ltd., (hereinafter referred to as “the Company”) is a member of the Mitsui Fudosan Group of Companies.
The Mitsui Fudosan Group of Companies operates various types of businesses, such as commercial property business, hotel and resort business, office building business, and logistics property business, in addition to the business relating to housing and living. (For more details, please refer to the website of Mitsui Fudosan.)
As for the Privacy Policy of the Company, please find it below.

1. Acquisition, Use, and Provision of Personal Information

The Company acquires customers’ personal information through lawful and fair means, and any necessary information, such as the purposes of use of personal information, is specified at the time of acquisition or announced on the website of the Company. The Company handles personal information under the appropriate procedure and within the scope of the purposes of use.
When the Company provides or discloses personal information to a third party or takes other actions with regard to personal information, it will do so in accordance with the procedures prescribed by laws and regulations.

2. Purpose of Use

The Company and its group companies (meaning Mitsui Fudosan Co., Ltd., and the consolidated subsidiaries of Mitsui Fudosan Co., Ltd., that are listed on the Annual Securities Report; the same applies hereinafter) use their customers’ personal information to the extent necessary for the attainment of the purposes of use as listed below:

1. To provide products and services that are related to the businesses of the Company.
   ＜Examples of the businesses of the Company＞
   • Purchase & sale / leasing of real estate, agency / intermediation for the same, and the management or other businesses incidental thereto
   • Intermediation for purchase & sale of trust beneficiary interests in real estate, private placement of the same (hereinafter collectively referred to as “Intermediation for Purchase & Sale of Trust Beneficiary Interests in Real Estate”), and other businesses incidental thereto
   • Operation and management of parking facilities and other businesses incidental thereto
   • Car-sharing services
   • Sales of insurance policies

   ＜Examples of the intended use＞

   • Solicitation of business through postal items, e-mails, phone calls, and other means of communication
   • Execution of contracts and/or transactions with customers concerning real estate, such as residential properties
   • Management and operation of properties (including parking facilities) handled by the Company
   • Management of membership information of membership organizations in which the Company participates
   • Provision of services for members (such as housecleaning and remodeling)
   • Communication and/or responding to inquiries via postal items, e-mails, phone calls, and other means of communication with regard to the transactions with clients and/or provision of services to members
   • Provision of products and/or services offered by insurance companies which relegate insurance sales to the Company
2. To introduce products and services that the Company and its group companies offer to customers with regard to food, clothing, housing, recreation, and work* and to provide varieties of information and benefits related thereto. ＜Examples of the purposes of use＞
   • Invitation to various seminars, campaigns, and events*
   • Behavioral targeting advertising by advertisement distribution providers (an advertising method by which contents are adjusted based on attributes and interests deduced through an analysis of the history of browsing and/or service use)*
   • Offering benefits such as coupons, discounts at the time of service use
     * Including introduction of products and services offered based on attributes, interests, etc. of customers deduced through an analysis of information such as transaction history acquired by the Company or its group companies.
     The above-mentioned invitation, distribution, and offering are made through phone calls, letters, post cards, e-mail newsletters, direct mails, etc.
3. To develop and improve products and services that the Company and its group companies offer to customers with regard to food, clothing, housing, recreation, and work and for the Company and its group companies to conduct a market study and perform marketing activities, research, and analysis for the sake of providing the customers with better products and services.
   ＜Examples of the purposes of use＞
   • Development and improvement of products and services
   • Distribution of a questionnaire
   • Analysis of customer trends
   • Formulation of a sales promotion plan, and verification of its effectiveness
4. To provide information to a third party in order to attain the purposes of use stated in paragraphs 1 through 3 above.

Gathering of Information Related to Persons

The Company acquires history of web browsing and usage collected by a third-party data provider through cookies and ADID’s (i.e. device identifiers of smartphones) (hereinafter collectively referred to as “Cookies”) as well as result of analysis thereof, and after linking such history and result to customers’ personal data uses the same for the purpose of delivering advertisements, etc. Also, the Company acquires history of web browsing and usage collected by its group companies through Cookies, as well as result of analysis thereof, and after linking such history and result to customers’ personal data uses the same within the scope necessary to attain the purposes of use stated in paragraphs1 through 3 above.

3. Provision to a Third Party

1. In addition to the cases based on laws and regulations, the Company may provide the customers’ personal data for a third party, such as its group companies and business partners in the housing business within the scope necessary to attain the purposes of use stated in paragraphs 1 through 3 of the Purposes of Use above.
2. Personal data to be provided are those necessary to attain each of purposes of use including a name, address, phone number, property information, and contract information related to a transaction. However, they shall be limited to those items as few as possible.

   ＜Examples of personal data to be provided＞

   • Information registered with the Company at the time of requesting a tour of or information regarding a property handled by the Company
   • Information registered with the Company at the time of requesting a tour of or information regarding a property handled by the Company
   • Various types of drawings for a property handled by the Company (such as design and working drawings and plans in brochures)
   • Information that has been registered with or reported to the Company in relation to Intermediation for Purchase & Sale of Trust Beneficiary Interests in Real Estate handled by the Company
   • Information that has been registered with or reported to the Company in relation to the membership service called Mitsui no Sumai LOOP in which the Company participates
   • History of membership services provided

   ＜Examples of parties to which personal data are provided＞

   • Group companies of the Company (but limited only to the consolidated subsidiaries of the Company in the case of insurance sales business)
   • Counterparties, prospective counterparties, other building lots and buildings business operators, internet advertisers, and real estate business operators involved in the intermediation of purchase and sale or leasing of a real estate
   • Associations and designated REINS organizations (for listing of properties, notification of conclusion of contracts, sales activities and property assessment by using the data in the REINS)
   • Developers, participating agencies, and intermediary companies concerning the sale of newly-built properties
   • Building lots and buildings business operators, agencies, and intermediary companies to whom customers are introduced for the purpose of intermediation of purchase and sale or leasing of a real estate
   • Financial institutions, judicial scriveners, land and house investigators, real estate management companies, contractors for remodeling, and moving companies who are involved in the business incidental to real estate transactions
   • Financial institutions, judicial scriveners, land and house investigators, and real estate management companies of properties in trust who are involved in the business incidental to Intermediation for Purchase & Sale of Trust Beneficiary Interests in Real Estate
   • Counterparties, prospective counterparties, other building lots and buildings business operators, and owners and management companies of parking facilities involved in monthly parking contracts
   • Companies offering membership services
   • Business partners in car-sharing services
3. Provision to a third party shall be done in such forms as paper documents, postal items, phone calls, facsimiles, e-mails and other electronic media, and handled with due care for security control. In case of using electronic data, precautionary measures such as encryption shall be taken.
4. Provision of information to a third party can be terminated upon request pursuant to the provisions in the Act on the Protection of Personal Information. In such a case, please contact Personal Information Office of Mitsui Fudosan Realty Group as specified below. Please acknowledge beforehand, however, that the whole or a part of our services may not be available any more after such termination.

4. Shared Use

The Company may share and use its customers’ personal data in the following manner.

1. Items of personal data to be shared
   Name, address, date of birth, phone number, e-mail address, transaction history, and similar information

   ＜Examples of personal data to be provided＞

   • Information registered with the Company at the time of requesting a tour of or information regarding a property handled by the Company
   • Information reported to the Company at the time of a real estate transaction
   • Various types of drawings for a property handled by the Company (such as design and working drawings and plans in brochures)
   • Information that has been registered with or reported to the Company in relation to Intermediation for Purchase & Sale of Trust Beneficiary Interests in Real Estate handled by the Company.
   • Information that has been registered with or reported to the Company in relation to the membership service called Mitsui no Sumai LOOP in which the Company participates
   • History of services provided
   • History of business negotiations, deals reviewed, etc.
2. Entities to share with

   History of business negotiations, deals reviewed, etc.

3. Purposes of use by entities to share with

   Same as the purposes of use stated in paragraphs 1 through 3 of the Purposes of Use above

4. Party responsible for shared use

   Mitsui Fudosan Realty Co., Ltd. (Corporate Outline)
   In order to provide customers with services as an integral part of Mitsui Fudosan Group, the Company shares its customers’ personal data with each of its group companies and endeavors to always keep such data updated and as accurate as possible.

5. Measures Implemented for Security Control

The Company observes relevant laws, regulations, and guidelines, and takes necessary and appropriate measures to prevent divulgence, loss, and impairment of and to safely manage personal data to be handled (hereinafter referred to as “Security Control Measures”).

1. Formulation of basic policy

   The Company has formulated basic policy to ensure proper treatment of personal data

2. Establishment of rules on handling personal data

   The Company has established internal rules on such matters as the manner of treatment, persons responsible for and in charge of handling personal data together with their duties.

3. Organizational framework for security control measures

   The Company has posted Information Security Managers, who are held responsible for handling personal information, to each division and department. Security control measures are reviewed and improved every fiscal year by collecting reports on cases of handling personal data from Information Security Managers. There is also a framework in place to make employees (including contracted and dispatched employees) observe the internal rules on security control measures and report to the Information Security Managers when any fact or sign of a violation of laws or internal rules by an employee is detected.

4. Personnel training in security control measures

   The Company provides the employees with education and training regarding the appropriate handling of personal information.

5. Physical and technical security control measures

   The Company carries out entry and exit management of employees in and out of the area handling personal data and keep devices containing personal information under lock and key. The Company also controls accesses to personal data and to the information systems that contains personal data, implement measures against illicit software, and monitor the information system.
   Examples: Prohibition against saving personal data on a local disk, periodic change of an authentication password, and obtainment and analysis of operation logs

6. Understanding of external environment

   In case of storing personal data of customers on a server located offshore, the Company implements security control measures after understanding the system regarding protection of personal information applicable to a country / region in question. For more details, please contact Personal Information Office of Mitsui Fudosan Realty Group of Companies or any sales department that you deal with.

6. Inquiry contact for personal information

With regard to provision of information such as disclosure, correction, addition, deletion, suspension of use, and elimination of personal information pursuant to the provisions of the Act on the Protection of Personal Information (hereinafter collectively referred to as “Disclosure”), please contact the offices below or sales department in charge.

How to make a request for disclosure of personal information

In order to request disclosure of personal information, please fill in the required fields of the prescribed form for request of disclosure and send it to the above-mentioned office by mail with necessary documents attached. Certain fees are prescribed and will be charged for the disclosure of personal information.
For more details, please see the link below.

Procedure for Disclosure of Personal Information

7. Handling anonymized information

1. When we prepare or provide anonymized information, necessary matters required by laws, regulations, and other norms shall be posted on our website or its equivalent.
2. We shall take safety management measures stipulated by company rules pertaining to anonymized information.

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3-2-5, Kasumigaseki, Chiyoda-ku, Tokyo
(Personal Information Handling Business Operator) Mitsui Fudosan Realty Co., Ltd.

Established on April 1, 2005
Revised on April 1, 2022