Basic Policy

Personal Information to Be Handled by the Company

The personal information the Company has obtained and used, as well as any personal information it will obtain and use in the future, is outlined below:

1. Personal information obtained directly from customers, such as addresses, names, telephone numbers, desired conditions, and real estate information (including contract information), in connection with the management of rented company housing, offices, stores, warehouses, parking lots, and leased land; real estate brokerage; sale of residential land, condominiums, and detached houses; management of rental housing (including condominiums, apartments, and detached houses) and condominiums for sale; home renovation; property and life insurance agency services; various customer communications; and other sales activities (collectively, the “Company’s Sales Activities”).
2. Personal information, such as addresses, names, telephone numbers, and real estate information (including contract information), indirectly obtained from documents and other materials acquired in the course of the Company’s Sales Activities.
3. Personal information duly obtained from publicly available sources, such as certified copies of the register, housing maps, and building confirmation applications.
4. Personal information obtained through the Real Estate Information Network System (REINS), operated by a real estate information network organization designated by the Minister of Land, Infrastructure, Transport and Tourism, or through private property information websites and advertisements.
5. Personal information relating to employees (not only employees in an employment relationship but also officers, temporary staff, etc.), job applicants, and former employees.
6. Personal information relating to shareholders.
7. Specific personal information (personal information that includes individual numbers as defined under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures).

Purpose of Use of Personal Information

The purposes of use of personal information handled by the Company are as follows. Any changes to these purposes of use will be made only to the extent they are reasonably deemed to have a substantial degree of relevance. In principle, the content of any such changes will be notified to the individual in writing (including electromagnetic records; hereinafter the same) or announced on the Company’s website.

1. Contract work, contract-related support work, provision of information on rental properties, data management, preparation of monthly reports, rent transfers, communication, advertising, preparation of price assessments and property survey materials, performance of contracts, contract management, and inquiries to rental guarantee companies, credit information agencies, and search agencies in relation to the Company’s Sales Activities; as an agent for non-life insurance companies, life insurance companies, and small-amount short-term insurance providers, provision and guidance on insurance products and services, execution, maintenance, and management of contracts, and provision of other related services on behalf of insurance companies.
   The Company is an insurance agency entrusted with insurance operations by the following insurance companies.
   The purposes of use of personal information for each insurance company are listed on their respective websites (see below):
   • Sompo Himawari Life Insurance Inc. （https://www.himawari-life.co.jp/）
   • Sompo Japan Insurance Inc. （https://www.sompo-japan.co.jp/）
   • Aioi Nissay Dowa Insurance Co., Ltd. （https://www.aioinissaydowa.co.jp/）
   • AIG General Insurance Company, Ltd. （https://www.aig.co.jp/sonpo）
   • Zenkankyo Small Amount and Short Term Insurance Company, Limited （https://www.zkssi.co.jp/）
   • AEON S.S. Insurance Co., Ltd. （https://www.aeonssi.co.jp/）
2. Introduction of the Company’s new and pre-owned properties that we believe will be useful to our customers, as well as consultation and guidance on matters such as replacement purchases and sales; provision of information and services, marketing activities, and survey requests via post, email, and other means; management of rental housing; sales information related to housing renovations; and sales introductions for housing affiliated with the Company. Use of personal information for these purposes can be discontinued upon request from the customer.
3. Analysis of customer trends or research and analysis for product development.
4. In some cases, the Company may outsource tasks to external businesses within the scope necessary to achieve the above purposes of use. In such cases, we will ensure the outsourcing is conducted based on selection criteria that comply with the Company’s regulations.
5. Personal information relating to the Company’s employees will be used for the following purposes to the extent necessary: personnel management, including personnel allocation and transfers; operation and management of systems stipulated in the rules of employment, labor-management agreements, and similar documents; human resources development and self-development; implementation of education and training programs; management and certification of work status; calculation and management of salaries, bonuses, payments, and deductions; operation and management of social insurance systems; tax-related matters; operation and management of various welfare programs; health checkups; health and safety operations; entry and exit management; preparation of various documents; other internal business management and communication; implementation of procedures required by laws and regulations; and other activities necessary for company operations.
6. Personal information related to job applicants will be used for the following purposes: notifications and communications related to recruitment (via phone, mail, or email); provision of information related to the Company’s business to job applicants; preparation of reference materials for recruitment decisions; preparation of research and analysis materials to evaluate recruitment decision-making activities; and other matters incidental to these purposes.
7. Personal information relating to the Company’s former employees will be used for the following purposes to the extent necessary: contacting former employees if needed; sending notifications or information from the Company to former employees; managing records of employment, salary, health information, etc., during their tenure; responding to various inquiries related to social insurance; implementing procedures required by laws and regulations; and other activities necessary for company operations.
8. Personal information relating to the Company’s shareholders will be used for the exercise of rights and the performance of obligations in accordance with laws and regulations, provision of various benefits (such as shareholder benefit programs), implementation of shareholder initiatives (such as surveys), and management of shareholders in accordance with laws and regulations (including the creation of shareholder data).
9. If an individual requests notification of the purpose of use of their identifiable personal information, the Company will respond to that request without delay.
10. Specific personal information will be used to process individual number-related affairs under Article 2, Paragraph 11, of the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.

Security Control Measures for Personal Data

To prevent the leakage, loss, or damage of personal data (including individual numbers and specified personal information) it handles and to otherwise ensure the security control of personal data, the Company has put in place robust security measures that include the establishment of handling regulations and implementation systems for security control, as well as appropriate measures to ensure the accuracy and currency of the data necessary to achieve the purpose of use. The Company has established separate internal regulations regarding security control measures for personal data, and the specific details are as follows.

1. Development of the Basic Policy
   To ensure the proper handling of personal data, the Company has formulated a basic policy covering matters such as “compliance with relevant laws, regulations, and guidelines,” “security control measures,” and “contact points for questions and complaints.” This policy is reviewed and updated as necessary.
2. Development of Handling Rules for Security Control of Personal Data
   (2) Development of Handling Rules for Security Control of Personal Data
   The Company has established regulations covering handling methods, responsible persons, persons in charge, and their duties for each stage of personal data management, including acquisition, use, storage, provision, deletion, and disposal. These regulations are reviewed and updated as necessary.
3. Organizational Security Control Measures
   • Appointing a person in charge of managing personal data and related roles
   • Developing security control measures in employment regulations and other relevant documents
   • Conducting operations in accordance with the handling rules for security control of personal data
   • Developing mechanisms to monitor how personal data is being handled
   • Inspecting personal data handling practices and the development and implementation of an auditing system
   • Establishing a system to respond to cases of leakage or similar incidents
4. Human Security Control Measures
   • Entering into non-disclosure agreements or obtaining written pledges from employees regarding personal data
   • Clarifying the roles and responsibilities of employees related to personal data management
   • Thoroughly communicating security control measures to employees and providing education and training
   • Verifying employees’ compliance with personal data management procedures
5. Physical Security Control Measures
   • Managing areas where personal data is handled or stored
   • Preventing theft of equipment, electronic media, and similar items
   • Preventing leakages when transporting electronic media or similar devices
   • Deleting personal data and disposal of equipment, electronic media, and related materials
6. Technical Security Control Measures
   • Identifying and authenticating users who access personal data
   • Setting management categories for personal data and implementing access controls
   • Managing access permissions for personal data
   • Implementing measures to prevent the leakage, damage, or destruction of personal data
   • Recording and analyzing access to personal data
   • Recording and analyzing the operational status of information systems that handle personal data
   • Monitoring and auditing information systems that handle personal data
7. Supervision of Subcontractors
   When outsourcing the handling of personal data, the Company selects subcontractors who can appropriately handle personal data. To ensure that subcontractors implement security control measures, we have established handling regulations for outsourcing and regularly review and update those regulations.
8. Understanding the External Environment
   • We implement security control measures after understanding the personal information protection system in each country where personal data is processed.

Provision of Personal Information to Third Parties and Acquisition of Personal Information from Third Parties

The Company will not provide personal information to third parties without the consent of the individual, except in the following cases:

1. Where the individual has provided their prior consent
2. Where the handling of personal information is outsourced within the scope necessary to achieve the purpose of use
3. Where such provision is in accordance with laws and regulations
4. Where it is necessary to protect a person’s life, body, or property, and obtaining consent is difficult
5. Where it is particularly necessary to improve public health or promote the sound development of children, and obtaining consent is difficult
6. Where it is necessary to cooperate with a national organization or local government in executing duties prescribed by laws and regulations, and obtaining consent may hinder the execution of those duties
7. Where the third party is an academic research institution, etc., and handling personal data is necessary for academic research purposes (including cases where part of the purpose is academic research, except where there is a risk of unjust infringement on the rights and interests of individuals)

Handing of Sensitive Information

The Company will not acquire, use, or provide to third parties any sensitive personal information (meaning information such as race, creed, social status, medical history, criminal record, criminal history, and information on criminal victimization) or information about labor union membership, family origin, legal domicile, healthcare, or sexual life (“Sensitive Information”), except in the following cases:

1. Where it is in accordance with laws and regulations
2. Where it is necessary for the protection of a person’s life, body, or property
3. Where it is particularly necessary for the improvement of public health or the promotion of the sound development of children
4. Where it is necessary to cooperate with a national organization, local government, or a person delegated by them in the execution of duties prescribed by laws and regulations
5. Where Sensitive Information of employees, etc., regarding membership or affiliation with political, religious, or other organizations or labor unions is acquired, used, or provided to a third party within the scope necessary for collecting insurance premiums and performing other administrative tasks
6. Where Sensitive Information is acquired, used, or provided to a third party within the scope necessary for performing insurance claim payment tasks and other related processes involving inheritance procedures
7. Where Sensitive Information is acquired, used, or provided to a third party within the scope necessary for business operations, based on the consent of the individual, due to the necessity of ensuring the proper operation of the insurance business

Procedures for Cases Where the Individual Requests Disclosure (including Confirmation and Disclosure of Records), Notification of Purpose of Use, Correction, Addition, Deletion, Suspension of Use, Erasure, or Suspension of Provision to Third Parties

The Company responds to requests for disclosure, etc., from individuals or their representative regarding personal information held by the Company or records of providing personal information to third parties within a reasonable scope and time frame. However, please note that this does not apply to information for which the Company lacks the authority to directly implement such measures, such as information entrusted to the Company. When making a request for disclosure, etc., please prepare the following documents (1) and (2) and return them to the “Contact for Inquiries” address provided below.

1. Personal Information “Disclosure, etc.” Request Form (PDF)
   * Please click on the link above to download the Personal Information “Disclosure, etc.” Request Form, print it out, and fill in the required information.
   *PDF files require Adobe Reader for viewing.
2. Documents Confirming Identity of the Individual or Their Representative
   A. In the case of the individual:
   
   1. Proof of identity
      • A copy of a document that verifies the individual’s identity, such as a driver’s license, pension book, health insurance card, or passport
   B. In the case of a representative, please enclose the following documents in addition to a document listed in A:
   
   1. Proof of the representative’s identity:
      • A copy of a document that verifies the representative’s identity, such as a driver’s license, pension book, health insurance card, ㅋor passport
   2. Documents verifying the representative’s qualifications / Person with parental authority: A copy of the family register or certificate of residence
      • Guardian of a minor: A copy of the family register or a court order appointing the guardian
      • Guardian of an adult: A copy of a court order appointing the guardian or a certificate of registered matters for guardianship registration
      • Agent: Power of attorney (Please include the date of creation, the addresses and names of the principal and agent, the seal of the principal, and a certificate of seal registration for the seal.)
   * If the documents used as proof of identity contain sensitive information, such as legal domicile, please black out the relevant information using permanent ink before sending.
3. Fees for “Disclosure” Requests and Payment Method
   The fee is 900 yen per request.
   Please enclose postage stamps worth 900 yen with your request form.
   * You will be notified if the fee is insufficient or not enclosed. If payment is not received within the specified period, the request will be treated as no “Disclosure” request made.
4. How We Respond to “Disclosure, etc.” Requests
   The Company will provide a written response to the address stated in the requester’s application form.
5. Purpose of Use of Personal Information Obtained in Relation to “Disclosure, etc.” Requests
   Personal information obtained in relation to a “Disclosure, etc.” request will be handled only within the scope necessary to process the request. The submitted documents will be retained for the period stipulated in the Company’s regulations after the response to the “Disclosure, etc.” request has been completed and will then be destroyed.
6. Reasons for Not Disclosing Personal Information
   Disclosure will not be made in the following cases. If the Company decides not to disclose the information, you will be notified of its decision and provided with a reason.
   1. If the address on the request form does not match the address on the document for proof of identity or the address registered with the Company, or if it is otherwise not possible to verify the individual’s identity
   2. In the case of a request by a representative, if the authority of the representative cannot be confirmed
   3. If there are deficiencies in the prescribed request form
   4. If there is a risk of harm to the life, body, property, or other rights or interests of the individual or a third party
   5. If it would significantly hinder the proper execution of the Company’s business
   6. If it would otherwise violate laws or regulations

Personal Information Protection Manager

PMS officer

Contact for Complaints, Consultations and Inquiries Regarding the Handling of Personal Information

For complaints, consultations, and inquiries regarding the Company’s handling of personal information, please contact us at the address below. We will respond promptly and appropriately.
Please note that the Company cannot accept requests made in person at its offices.

Name of the Certified Personal Information Protection Organization to Which the Company Belongs and Where Complaints Should be Lodged

1. Name of the certified personal information protection organization: Japan Institute for Promotion of Digital Economy and Community (JIPDEC)
2. Where complaints should be lodged: Privacy Mark Promotion Center, Secretariat for Certified Personal Information Protection Organization
   ＜Address＞ Roppongi First Building, 9-9 Roppongi 1-chome, Minato-ku Tokyo, 106-0032
   ＜TEL＞ 03-5860-7565 / 0120-700-779

Notes

You are responsible for managing any IDs and passwords provided by the Company. Please note that the Company cannot be held liable for any damage resulting from the unauthorized use of IDs or passwords.